South Africa’s leaders have known since at least the beginning of September 2017 that Eskom’s emissions were believed to be responsible for an estimated 2,239 deaths a year when air quality and health expert Dr Mike Holland presented his report to them.
Eskom’s own figure of the number of deaths caused by its pollution come in at 333 a year (according to the Mail & Guardian last week) – but it still wanted a fourth postponement of compliance (and in some cases exemption) from compliance with air pollution laws; laws it has known about since 31 March 2010 at the very latest, and which were set in a multi-year, multi-stakeholder process in which Eskom was an active and vocal participant.
Holland told South Africa’s leaders emissions caused 2,781 cases of chronic bronchitis per year in adults, 9,533 cases of bronchitis per year in children aged six to 12, 2,379 hospital admissions per year, 3,972,902 days of restricted activity per year, and 94,680 days of asthma symptoms per year in children aged five to 19.
This week, Dr Ranajit Sahu released his 2018 study that determined “the coal-fired power stations reported nearly 3,200 exceedances of applicable daily Atmospheric Emissions Licenses (AEL) limits for particulate matter (PM), sulphur oxides (SO2), and oxides of nitrogen (NOx)”.
“Because the applicable limits in the AELs are quite lax compared to those recommended by the World Bank Group, or those adopted by China, for example, having any exceedances of the AEL limits is very troubling,” Sahu said.
“Even perfect compliance with AEL limits allows for discharges of pollution at unhealthy levels. Exceedances are even more troubling since most of these plants are located in areas already significantly impaired from an air pollution standpoint.”
Sahu noted many of the exceedances were frequent at particular plants instead of being sporadic, “indicating the underlying causes of such exceedances are not being addressed by Eskom”.
“My analysis of plant emissions exceedances was severely limited by inconsistent, incomplete and unclear reporting. When faced with uncertainty, I gave the benefit of the doubt to Eskom, and so my calculations underrepresent the extent of AEL exceedances,” Sahu said.
“More accurate and comprehensive reporting would significantly enhance government enforcement of AELs and public scrutiny of power plant compliance.”
In December, caretaker environmental minister Nomvula Mokonyane announced her intention “to appoint experts to provide strategic and technical guidance towards effective management of sulphur dioxide emissions from power generation plants”.
“The industries have been unable to adequately and effectively manage sulphur dioxide emissions, thereby failing to comply with the minimum emission standards (MES),” Mokonyane said, inadvertently confirming the findings of Sahu, Holland, and a host of other scientists who’d made similar findings.
Professors Rajen Naidoo and Harro von Blottnitz, and GreenPeace energy analyst Lauri Myllyvirta are a few of the names recommended for appointment on this expert panel.
Since then, nothing has happened, with Mokonyane still to apply her mind in the middle of an election.
The Life After Coal Campaign has objected to the expert panel because it would further delay action to achieve MES compliance; be a duplication of years of work that had already set the MES; and there was no legal basis upon which the DEA could weaken the MES.
National Air Quality Officer Dr Thuli N. Khumalo made a presentation on February 12 to the portfolio committee (PC) on environment, and noted yet again Eskom and Sasol were the “major sources” of SO2 emissions.
“The strategies, which pointed to a lack of sustainable solution on this matter, were presented to the PC on 6 February 2018,” said Khumalo in her presentation.
“The PC recommended Terms of Reference (ToR) for the appointment of a Technical Advisory Panel be developed that would help the affected parties find a lasting solution on this matter,” Khumalo said.
Instead, then environment minister Edna Molewa instructed a “Needs Assessment Report be produced on the progress of all the previous postponements granted and the challenges thereof for the past five years”.
According to Robyn Hugo, head of the Centre for Environmental Rights Pollution and Climate Change Programme, Minister Derek Hanekom had signed into law changes to the MES which effectively doubled the S02 MES which would apply from April 2020.
“In other words, making them twice as weak,” said Hugo.
“This was done despite the failure to publish the proposed amendment for public comment, as the Air Quality Act requires.”
Down and dirty facts
Eskom’s coal-fired power stations sent out 200,893GWh between April 1, 2016, to March 31, 2017, burning 113.74Mt of coal which had the following environmental implications when using one kilowatt hour (kWh) of electricity:
- Coal use: 0.53 kilograms
- Water use: 1.53 litres
- Ash produced: 151 grams
- Particulate emissions: 0.30 grams
- CO₂ emissions: 0.98 kilograms
- SOx emissions: 8.20 grams
One kWh of energy is the equivalent of an electric heater using 1000 watts (1 kilowatt) for one hour – Eskom
Eskom has initiated a process to complete an analysis and respond to Dr Sahu’s report.
Going forward Eskom is considering revising the format of monthly report to include such an analysis and to avoid misinterpretation of the information
Eskom denies that there are thousands of emission non-compliances. Dr Sahu’s report appears to have a number of errors which significantly over state the extent of the high emission levels.
Eskom has provided access to emission information through the Promotion of Access to Information Act. In addition during the recent public meetings for the MES postponement application there was a request for access to the annual emission reports and these were promptly made available to all interested and affected parties.
Dr Sahu’s report reflects a number of daily exceedances, many of these are permitted in terms of the conditions of the AEL and are therefore not non-compliance.
Where the authorities have identified significant recurring trends in terms of possible noncompliance they have issued Eskom with pre-compliance notices in terms of the National Environmental Management Act e.g. Kendal, Lethabo and Komati.
Eskom has responded to each of these generally indicating that the high emission levels are not non-compliances to the legislation.
The dispersion modelling and ambient air quality monitoring data indicate that the elevated pollution levels in the Highveld require a holistic approach, addressing all identified and potential sources.
Therefore, a single approach, only addressing Eskom power station emissions will not result in acceptable ambient air quality levels that are not harmful to human health and the environment.
Eskom has initiated an offset programme which will reduce emissions from household use of coal for heating and cooking.