Centre for Environmental Rights – Advancing Environmental Rights in South Africa

One of Eskom’s coal-fired power stations on the Highveld

On 16 October 2014, on behalf of a group of civil society and community organisations, the CER submitted to the National Air Quality Officer additional objections to Eskom’s applications to postpone compliance with minimum emission standards commencing on 1 April 2015, to ensure that the decision-makers are in possession of relevant information, as required by the Promotion of Administrative Justice Act, 2000.

In December 2013, national electricity utility Eskom applied for postponement of their compliance with air pollution minimum emission standards for 16 of their power stations. At the same time, Eskom also applied for variation of the conditions of the air quality licences for 16 power stations. In February 2014, civil society and community groups (see the full list below) filed detailed objections to Eskom’s applications. In May 2014, the National Air Quality Officer sent letters to Eskom requesting further information on its applications, and Eskom responded to those requests in July 2014 (CER received copies only in late August 2014). The documents filed on 16 October 2014 constitute the response from the civil society and community groups listed above to those Eskom’s answers. All of these documents are available here.

As appears from these submissions, Eskom largely failed to provide the required information regarding health impacts and regarding its future compliance with the MES. Such health information as is available (both from the study contained in the February 2014 submissions and from Eskom’s own studies) demonstrates that Eskom’s applications will have significant and severe health impacts, with enormous economic costs. The information that Eskom provided revealed that:

• elevated daily average SO₂ and PM₁₀ concentrations occur frequently throughout the region in the vicinity of Eskom’s power stations, and throughout the year; and that
• these concentrations are frequently several times higher than the ambient air quality standards and/or World Health Organisation guideline value, with consequent health impacts.

Since Eskom is by far the largest source of SO₂ emissions in the region, the implication is that its emissions are mainly responsible for the high ambient concentrations and these health impacts.  In addition, the occurrence of high ambient particulate matter (PM) concentrations in the summer months contradicts Eskom’s argument that domestic solid fuel burning is the main source of PM, and that Eskom is only a very minor contributor to ambient PM. For these and the other reasons, the submissions reiterate that Eskom’s applications must be refused.

The outcome of Eskom’s applications is awaited.

List of civil society and community organisations: groundWork, Earthlife Africa Johannesburg (ELA), the Vaal Environmental Justice Alliance, and the following community groups: Middelburg Environmental Justice Network, Greater Middelburg Residents’ Association, Guqa Community Service Centre, Southern Africa Green Revolutionary Council, Greater Delmas Civic Movement, Highveld Environmental Justice Network, Wonderfontein Resettlement Forum, Mpumalanga Youth Against Climate Change, Outrageous Courage Youth and the Schoongesicht Community Movement.