Yesterday, Greenpeace Africa (www.Greenpeace.org) submitted comments to Naledzi Environmental Consultants [1] opposing Eskom's application for postponements and suspensions [2] from complying with South Africa's Minimum Emission Standards (MES). The MES, which are relatively weak [3], are designed to improve air quality in the country, but this has been significantly compromised by Eskom’s almost complete reliance on coal for electricity production and repeated requests for postponements from complying.

“Greenpeace Africa is vehemently opposed to Eskom’s application for further postponements and/or suspensions from air quality legislation. In the interests of realising our constitutional right to a healthy environment, absolutely no further postponements should be given to Eskom (or, indeed, any other entity).

“Eskom should either comply with the MES or its coal-fired power stations must be retired (at an accelerated pace) because thousands of people’s lives are on the line,” said Melita Steele, Senior Climate and Energy Campaign Manager for Greenpeace Africa. 

Eskom was granted a five-year postponement from compliance in 2015, and the embattled utility is now applying for yet another set of postponements and, in some cases, complete suspensions from complying.

“While we acknowledge that Eskom is in crisis, we can no longer ignore the deadly impacts of Eskom’s dirty fleet of coal-fired power stations. It is unacceptable that in Eskom’s application, the utility is significantly downplaying the health impacts and premature deaths from their coal-fired power stations.

“Eskom consistently ignores international research standards and uses outdated research, unacceptable timelines and highly exaggerated cost assumptions for retrofitting pollution abatement technology. According to international best practice, compliance with the MES is absolutely possible [4]; Eskom is simply choosing instead to seek out a new licence to kill,” continued Steele.

Air pollution, with its devastating impacts on human health and well-being, remains a critical problem in South Africa. This is particularly worrying in areas such as the Highveld, where air quality remains poor or has further deteriorated from “potentially poor” to “poor” and is out of compliance with air quality legislation. Mpumalanga province in South Africa is the largest NO2 air pollution hotspot in the World, as new satellite data assessed by Greenpeace showed for the period of 1 June to 31 August 2018 [5].

To date, Eskom’s levels of compliance have been abysmal. Between April 2016 and December 2017, Eskom’s seventeen coal-fired power stations reported nearly 3,200 exceedances of their daily Atmospheric Emissions Licenses limits for particulate matter, sulfur dioxide, and oxides of nitrogen. Eskom’s 'Emission Reduction Plan' would allow the company to operate its entire existing fleet without even rudimentary controls for two of the most dangerous pollutants emitted from coal-fired power plants, sulphur dioxide and mercury [6].

“As far as Greenpeace Africa is concerned, no further postponements or suspensions can legally be granted to the utility by the National Air Quality Officer and Eskom’s application should be dismissed. We take this position given the air pollution crisis in Mpumalanga, the length of time that Eskom has had available in which to prepare to comply, the flawed application, and the thousands of premature deaths that will be caused if Eskom does not comply.

“Eskom has presented no evidence in this application or otherwise that indicates its commitment to decommissioning, which makes suspensions from complying an impossible choice. We call on Eskom to abandon its renewed  attempt to avoid complying with air quality legislation that has been put in place to protect people’s health,” ended Steele.

Notes to the editor:

1. Naledzi Environmental Consultants (www.Naledzi.co.za) are running the public participation process on behalf of Eskom as they finalise their submission. The comments are submitted as part of the public participation process that Eskom is conducting for their application. Their application is due to be submitted to the National Air Quality Officer by 31 March, after which the National Air Quality Officer will make a decision. There is no deadline for this decision to be taken.
2. Greenpeace Africa was an Interested and Affected Party for Eskom’s original application for postponement from complying with Minimum Emission Standards (MES) in 2014, and we remain an Interested and Affected Party for Eskom’s revised request for postponements. We strongly opposed the decision to allow Eskom to postpone complying with the MES in 2015, and we believe that the grounds for opposing Eskom’s updated application are even stronger in 2019.
3. Compared to many other countries, South Africa has very weak Minimum Emission Standards that allow coal-fired power stations to emit close to 100 times more sulfur dioxide (SO2) than allowed in China’s key regions, 20 times more than existing stations in India, over 45 times more than new plants in India and over 20 times more than current regulations in the European Union. They also allow emissions of about 6 times more particulate matter than allowed in the EU and China’s key regions, and almost 5 times what is allowed for new stations in India; and 15 times more nitrogen oxides (NO2) than allowed in India (new builds) and China (key regions) and more than 7 times more than currently in the EU.
4. China retrofitted approximately 250 gigawatts of existing coal-fired capacity with air pollution controls (FGD) between 2005 and 2011, bringing share of capacity with SO2 controls from 14.3% to 89.1% in six years; and India is targeting bringing its entire coal fleet into compliance with stricter standards than the MES by 2022, requiring retrofits in much of its 220GW of operating capacity. According to India’s Ministry of Power, the procurement, construction and connection of an FGD takes 30-36 months, and according to the International Energy Agency 24-36 months.
5. Here (https://bit.ly/2PYsngQ) is a link to the interactive NO2 map on Facebook.
6. There would also be substantial exemptions for controlling NOx and dust emissions.