Multiple applications by Eskom to postpone compliance with air pollution standards for its power stations should be rejected because the utility has failed to meet the prescribed conditions for a postponement application, say five environmental justice organisations.
Eskom's applications for postponement with the minimum emission standards (MES) include 11 coal-fired power stations in the heavily-polluted Highveld Priority Area (HPA) in Mpumalanga, which was declared an air pollution hotspot nearly 11 years ago, but where residents are still forced to breathe dirty, dangerous air.
Eskom also wants postponements for Lethabo station, located in the Vaal Triangle Airshed Priority Area, and has sought additional postponements for its Medupi and Matimba stations located in the Waterberg-Bojanala Priority Area.
"We wholly and unequivocally object to this further postponement application for multiple power stations and maintain that Eskom should not be permitted to apply for any postponements of MES compliance as it has not met the prescribed conditions for a postponement application," wrote the Life after Coal campaign, which consists of Earthlife Africa, groundWork, and the Centre for Environmental Rights (CER), together with the Highveld Environmental Justice Network and the Vaal Environmental Justice Alliance (VEJA), in a recent letter to Dr Thuli Khumalo, the national air quality officer and senior officials in the Department of Environmental Affairs (DEA), and senior colleagues in the department.
"As we have consistently argued, because all of Eskom's operations are in priority areas where there is consistent non-compliance with the national ambient air quality standards, their atmospheric emission licences should contain stricter emission limits than the MES.
"Eskom's power stations should not be granted postponements of MES compliance. Instead where stations cannot meet MES, they should not operate/or their decommissioning dates should be expedited."
The environmental justice organisations argue that allowing Eskom to continue will mean that at least 2 200 people in affected areas will die premature deaths every year.
Air pollution in several parts of SA, and especially in the three air-pollution priority areas, already exceeds the health-based national ambient air quality standards.
The organisations state that although Eskom was already granted widespread postponements from compliance with the MES under the Air Quality Act in early 2015, it has made "little effort" to ensure that it can comply timeously with South Africa’s "weak" MES.
"South Africa's MES are very weak, compared even to other developing countries. Our SO2 existing plant MES are 18.5 times weaker than those in China, Germany, and the European Union, nearly six times weaker than India, almost five times weaker than Indonesia's and almost double as lax as Thailand ... Our new plant MES also do not compare favourably to other jurisdictions," reads their letter.
Severe air pollution perpetuates environmental injustice in South Africa.
“Living in Middelburg, I see first-hand the health impacts of air pollution on my family and the communities around me," explained Thomas Mnguni, a community campaigner at groundWork, His two children suffered from asthma and chronic sinus problems, he said, and his family had to carry the expense of their medication because of Eskom's polluting activities.
“We have been warning the government since 2013 that Eskom intends to apply for 'rolling' postponements, reapplying every five years, until its older fleet of coal-fired power stations is eventually decommissioned. This application makes clear that has been their illegal plan all along.
"The DEA must refuse the postponement applications as it is well aware that Eskom is responsible for the overwhelming majority of SO2 and NOx emissions – and their health impacts – in the HPA. Eskom is seeking a licence to kill ... Eskom is non-compliant and the situation is getting worse, rather than getting better."
Samson Mokoena of VEJA termed the applications a "slap in the face. The health of our people in the Vaal is at risk".
The groups state that according to the DEA’s own reports, none of the priority areas comply with the country's already outdated national ambient air quality standards.
“This is the fourth time that Eskom has applied more time to meet the MES," said said CER attorney Timothy Lloyd. "This despite the fact that all of its coal-fired power stations fall within priority areas, in which residents are already being exposed to dangerous levels of air pollution.
"Not only has Eskom failed to meet the prescribed requirements for seeking postponements, but granting MES postponements will clearly – and unacceptably – exacerbate air pollution in priority areas."
In its background information document, the company states it does not continuously emit emissions that exceed the MES. "However, because emissions stemming from stations are variable, there are instances in which they exceed the emission standards, and it's for these instances that Eskom's stations need to request postponement from the compliance time frames, until relevant technology is installed to bring the station into continuous full compliance ...
"Eskom is requesting postponement for stations which are unable to comply with the new plant MES for S02 as this would place heavy strain on the tariff, the already strained water resources and would create new waste streams and create additional sources of carbon dioxide.
"Lastly Eskom is requesting postponement for some of its older fleet, which will be decommissioned within the next 12 years, "where, if the retrofit were to be applied, it would only operate for a few years ... before the power station is shut down according to its 50-year life expectancy".
The organisations cite the devastating health risks from Eskom’s stations, confirmed by various studies, including Eskom’s own reports. In 2016, UK-based air quality and health expert Dr Mike Holland assessed the health impacts and associated economic costs of current emissions of just one type of pollutant from Eskom’s coal-fired power stations (PM2.5), finding that Eskom emissions cause more than 2 200 equivalent attributable deaths every year, and cause thousands of cases of bronchitis and asthma in adults and children annually.
The organisations state that they are now planning to approach the High Court to challenge these ongoing violations of Constitutional rights in priority areas, like the HPA.