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This research report assesses the impact of including two coal-fired independent power producer (IPP) projects—Thabametsi and Khanyisa—in South Africa's electricity system from 2022 to 2052. Using the South African Times Model (SATIM), the study finds that these plants are not necessary to meet demand and would increase both total system costs and greenhouse gas emissions across all analysed scenarios, potentially offsetting national energy efficiency and carbon tax mitigation efforts.

This research report assesses the impact of including two coal-fired independent power producer (IPP) projects—Thabametsi and Khanyisa—in South Africa's electricity system from 2022 to 2052. Using the South African Times Model (SATIM), the study finds that these plants are not necessary to meet demand and would increase both total system costs and greenhouse gas emissions across all analyzed scenarios, potentially offsetting national energy efficiency and carbon tax mitigation efforts.

The Centre for Environmental Rights (CER) submitted a statement to the Portfolio Committee on Environmental Affairs on May 22, 2018, opposing the approval of coal-fired Independent Power Producers (IPPs), specifically Thabametsi and Khanyisa. The CER argues that these projects are unnecessary, economically damaging, and environmentally catastrophic, citing high greenhouse gas emissions, water scarcity, and air pollution in priority areas.

A statement by Dr. A. Gray, an environmental engineer and atmospheric scientist, regarding the necessity of providing full computer modeling files alongside written reports to ensure the transparency and validity of air dispersion modeling assessments.

This document is an Environmental Management Programme (EMPr) prepared by SRK Consulting (South Africa) (Pty) Ltd for Mineral Sands Resources (Pty) Ltd (MSR). It is part of a Section 24G application under the National Environmental Management Act (NEMA) to rectify unlawful activities at the Tormin Mine, specifically the unauthorized expansion of a processing area and the construction of a process water dam.

The Centre for Environmental Rights (CER) submitted a formal response to the Portfolio Committee on Environmental Affairs regarding the National Environmental Management Laws Amendment Bill [B14-2017], providing a table of proposed amendments and requesting an oral presentation at public hearings.

The Centre for Environmental Rights (CER), acting for groundWork and Earthlife Africa, submitted comments on April 19, 2018, regarding the Draft Environmental Impact Report (DEIR) and Waste Management Licence (WML) Variation Application for the Flue Gas Desulphurisation (FGD) Retrofit Project at Medupi Power Station. The CER argues that Eskom has adopted a 'piecemeal approach' to the environmental impact assessment (EIA), deferring critical issues such as water security, waste minimisation, and health impacts to separate processes to 'fast track' the project. The submission specifically challenges the rejection of inlet gas cooler technology, which could reduce water consumption by approximately 30%, and criticizes the plan to co-dispose of gypsum and ash, which would destroy the commercial value of the gypsum.

A letter from the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign to South Africa's Minister of Energy, Jeff Radebe, expressing concerns over the lack of public consultation regarding the updated Integrated Resource Plan (IRP) for electricity and the Integrated Energy Plan (IEP).

A letter from the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign and Greenpeace Africa to the Portfolio Committee on Energy, expressing concerns over the lack of public consultation regarding the updated Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP).

The Centre for Environmental Rights (CER), acting for Earthlife Africa NPC and groundWork, submitted comments on 11 April 2018 regarding the draft Scoping Report for the Mokolo and Crocodile River (West) Water Augmentation Project (Phase 2) (MCWAP-2). The CER argues that the project is based on outdated assumptions regarding South Africa's energy needs and fails to adequately assess climate change, water reserves, and indirect environmental and health impacts.

The Centre for Environmental Rights (CER) provides written submissions on the March 2018 Final Draft Report of Climate Change Mitigation Policies and Measures (PAMs). The CER supports the examination of policy effectiveness but identifies several gaps, including the need for better alignment between various government climate projects, the exclusion of certain greenhouse gases and externalities in socio-economic analyses, and a lack of rationale for prioritizing coal-to-liquid production through 2050. The CER emphasizes that the report's findings—specifically regarding the electricity sector as the key to decarbonization—should inform the revision of the Integrated Resource Plan for Electricity (IRP 2010).

The Centre for Environmental Rights (CER), representing Earthlife Africa and groundWork, submitted a formal letter to the National Energy Regulator of South Africa (NERSA) on 4 April 2018. The letter follows a public hearing held on 27 March 2018 regarding generation licence applications for the Thabametsi and Khanyisa coal-fired power stations, raising concerns about the hearing process and requesting further information on NERSA's procedural compliance.

This report, prepared by Savannah Environmental (Pty) Ltd for Thabametsi Power Company Proprietary Limited, motivates for amendments to the Environmental Authorisation (EA) of the Thabametsi Coal-Fired Power Station in Limpopo Province. The proposed changes include extending the EA validity, altering the power line corridor, updating property details, and incorporating conditions from a 2016 Ministerial Appeal Resolution.

The Centre for Environmental Rights (CER) and Greenpeace Africa submitted joint comments on the Draft Carbon Tax Bill, 2017, arguing that the proposed tax rate and extensive allowances are insufficient to incentivize a transition to energy efficiency or meaningfully reduce South Africa's greenhouse gas (GHG) emissions.

Air dispersion modeling by Dr. Ranajit Sahu indicates that the proposed Thabametsi power plant and mine, combined with existing facilities like Matimba and Medupi, would likely cause air pollution levels (specifically SO2, NOx, and PM2.5) to exceed South Africa's National Ambient Air Quality Standards. The report highlights significant underestimations of PM emissions from the mine in previous assessments and notes a critical lack of accurate local air monitoring data.

A letter from the Life After Coal Campaign and Greenpeace Africa to the South African Minister of Energy, objecting to the proposed Thabametsi and Khanyisa coal-fired independent power producer (IPP) projects. The authors argue that these projects are legally precarious, environmentally damaging, and economically unnecessary compared to renewable energy alternatives.

The Centre for Environmental Rights (CER) submitted a letter to the National Energy Regulator of South Africa (NERSA) on 6 March 2018, requesting procedural details for public hearings regarding generation licence applications for the proposed Khanyisa and Thabametsi coal-fired power stations.

The Centre for Environmental Rights (CER), representing several environmental justice organizations, formally opposes the Department of Environmental Affairs' (DEA) proposal to establish an expert panel to find solutions for sulphur dioxide (SO2) abatement. The CER argues that such a panel would unnecessarily delay compliance with Minimum Emission Standards (MES), duplicate previous multi-stakeholder processes, and potentially lead to an unlawful weakening of environmental standards for major polluters Eskom and Sasol.

The Centre for Environmental Rights (CER), on behalf of Earthlife Africa Johannesburg and groundWork, submitted supplementary objections on 5 March 2018 against the Water Use Licence Application (IWULA) and Integrated Water and Waste Water Management Plan (IWWMP) for the proposed Thabametsi coal-fired power station. The objections argue that the project is unnecessary due to excess electricity capacity, poses severe risks to the water-stressed Mokolo Catchment, and fails to account for climate change impacts and toxic coal ash disposal risks.

This report evaluates the potential risks to water resources posed by the proposed Thabametsi Power Plant's coal ash dump and pollution control dams. The author concludes that the chosen site is unsuitable and the proposed mitigation measures are insufficient to protect groundwater, surface water, and wetlands.