Consequences for Eskom of the Listed Activities under Section 21 of the National Environmental Management: Air Quality Act, 2004 Submission to the Portfolio Committee on Water and Environmental Affairs 7 May 2013

In support of Overview In general, Eskom supports the Listed Activities published in terms of section 21 of the National Air Quality Management: Air Quality Act, 2004, and the proposed amendments Eskom is committed to reducing emissions from power generation activities, and is busy with an extensive retrofit programme to achieve emission reductions. However, full compliance with the Minimum Emission Standards for Listed Activities will have significant implications for energy security, the electricity tariff and resource consumption in South Africa. We would like to request that the Minimum Emission Standards for Listed Activities be amended. 2

In support of Emission reduction: particulates 3 At risk due to funding constraints

In support of Planned emission reduction: NO x and SO 2 4 Oxides of nitrogen Sulphur dioxide

In support of Compliance with ambient air quality standards Particulate (ash) and nitrogen oxide (NO x ) emissions from Eskom’s power stations do not result in non-compliance with ambient air quality standards There is only non-compliance with sulphur dioxide (SO 2 ) standards in non-populated areas (indicated in orange below) 5 Air quality monitoring shows compliance in Kriel town

In support of Typical resource requirements and waste production for compliance for a 3600 MW power station 6 Capital costs: R billion Water: 3-6 million m 3 /annum Sorbent: > tons/annum Operating costs: >R300 million/annum INPUTSOUTPUTS Reduced SO 2, NOx & particulate emissions Additional CO 2 : ~ tons/annum FGD by-product: ~ tons/annum Outage requirements: Up to 150 days per unit

In support of Recommendations The Minimum Emission Standards should be amended as follows: a grandfathering clause, allowing older plant to operate under more lenient limits, needs to be included. the ability to use offset projects to improve air quality in populated areas and much more effectively reduce human exposure to poor air quality more lenient compliance timeframes are required. the 48-hour period allowed for start-up in the Minimum Emission Standards needs to be increased for cold starts after long outages 7

In support of Motivation for requested amendments Investing in more emission abatement technologies at Eskom power stations will not solve the air quality challenges faced in South Africa. The largest air quality problem in South Africa is poor indoor air quality in low income areas, caused by domestic coal and wood combustion. Eskom is committed to air quality offset projects that will minimise domestic combustion emissions in order to improve the quality of air in populated areas. The retrofits will require an increase in the electricity tariff The emission abatement technologies have negative environmental impacts such as resource requirements and waste products 8

In support of Conclusion Eskom is committed to continued improvement in environmental performance and would like to work with Government and all stakeholders in achieving this objectives. Unfortunately, full compliance with the Minimum Emission Standards is not possible without severely compromising energy and water security. Should the Minimum Emission Standards not be amended, Eskom will need to be granted an exemption from compliance in many instances. Eskom continues with preparations for fabric filter plant retrofits to reduce particulate emissions, and with preparations for de-NOx and de-SOx retrofits at selected stations. 9

In support of 9/21/ Thank you