The Department of Environmental Affairs (DEA) could be giving the go-ahead for what will be one of the most greenhouse gas (GHG) emission intensive coal-fired power stations, not only in South Africa, but in the world.
The final climate change impact assessment for the proposed Thabametsi coal-fired power station, to be built near Lephalale, Limpopo, indicates that its GHG emissions could be 60% higher than Eskom’s new Medupi and Kusile coal plants.
On Monday 31 July 2017, Earthlife Africa Johannesburg (ELA), with the assistance of the Centre for Environmental Rights (CER), submitted comments on Thabametsi’s climate change impact assessment.
Thabametsi was in the spotlight earlier this year when the North Gauteng High Court – in South Africa’s first climate change court case – ordered the Minister of Environmental Affairs to reconsider ELA’s appeal of Thabametsi’s environmental authorisation, but this time with a climate change impact assessment for the power station.
The court confirmed that a climate change impact assessment needed to form part of Thabametsi’s environmental impact assessment (EIA) and should have been considered before a decision was made on whether the power station could go ahead.
This climate change impact assessment is the first of its kind for a coal-fired power station in South Africa. It confirms that Thabametsi’s GHG emissions are going to be high – it will release 9,9-million tons of carbon dioxide equivalent (CO2e) per year, and will have a GHG emission intensity of 1,23 tons of CO2e per megawatt hour. This is roughly equivalent to, if not slightly worse than, Eskom’s oldest coal-fired power plants, according to ELA.
The climate change impact assessment also looks at whether the proposed power station will cope with the impacts of climate change. It shows that water availability and deteriorating water quality in the already water-stressed Lephalale area pose a high risk to the power station’s operation over its intended 30 year lifespan, especially because planned industrial expansion in the area will make water increasingly scarce.
ELA’s comments state, among other things, that:
* The technology proposed for the Thabametsi plant means that South Africa will be bringing online a new coal plant which will emit the same amount or even more climate-changing GHGs than Eskom’s old coal plants. This means that Thabametsi is clearly not going to be “newer and better” than South Africa’s existing coal fleet; but, in fact, from a GHG emissions perspective, it is going to be worse;
* The impact assessment has not considered the external costs of the project’s GHG emissions, such as costs arising from climate change impacts on human health; water availability; and changes in agricultural productivity, which would be required in order to reflect the true costs of building and operating a coal-fired power station, particularly one as emission-intensive as Thabametsi;
* The impact assessment has failed to consider how the power station will exacerbate the vulnerability of the communities and environment in the Lephalale area to the impacts of climate change. This is a fatal flaw;
* The impact assessment fails to propose any measures to substantially and adequately mitigate the plant’s emissions. Short of implementing carbon capture and storage – which is neither technically nor financially feasible – it is not possible meaningfully to mitigate the GHG emissions of a coal plant – Thabametsi’s assessment says as much. The mitigation measures proposed in the climate impact assessment simply look at maintaining the status quo of the plant’s already high GHG emissions. The climate impact assessment also has no means of ensuring that the water availability risks to the power station are avoided – this is beyond Thabametsi’s control. Because the significant climate impacts cannot be avoided, the assessment fails to recommend – as it should – that the power station cannot go ahead; and
* In light of the staggering climate impacts of the proposed Thabametsi power station, which will be emitting significant GHGs for at least 30 years (up until 2050 at least), it would be unlawful for the environmental authorisation to remain in place.
However, the climate assessment summary report concludes that the power station’s overall impacts are of low to medium significance, and that Thabametsi should go ahead.
ELA believes the findings of the climate change impact assessment are concerning, given South Africa’s vulnerability to the impacts of climate change and the fact that South Africa has made international commitments to reduce its GHG emissions.
ELA’s Makoma Lekalakala says: “It is not clear why the DEA authorised Thabametsi to begin with, as it will have irreversible climate impacts. We hope that the findings of the climate change impact assessment now make it clear that this power station should not have been given approval.”
In accordance with the High Court order, the Minister, once she has considered the climate impact assessment and comments on it (including ELA’s comments), must make a decision on whether to uphold or (again) dismiss ELA’s appeal of the environmental authorisation. In doing this, the Minister can set aside Thabametsi’s environmental authorisation, uphold it (with or without amendments), or refer the application back to DEA for reconsideration. Until the Minister makes her decision, Thabametsi’s environmental authorisation is suspended.
CER attorney Nicole Loser points out: “As with all proposed new coal plants which have not adequately assessed climate change impacts, or which have been authorised to go ahead despite the irreversible climate change impacts, if the Minister allows Thabametsi to proceed despite these impacts, our client will consider further legal action.
“Either way, it seems imprudent to commit South Africa to a project that will emit GHGs for at least 30 years, in circumstances when the revised Integrated Resource Plan for electricity – expected to be published early in 2018 – may substantially reduce the amount of coal in South Africa’s energy mix.”
Thabametsi, as a preferred bidder under the Coal Baseload Independent Power Producer Procurement Programme, is required to reach commercial and financial close (meaning that it must have all necessary authorisations – including an environmental authorisation – in place) by 3 November 2017.
As things stand, apart from the suspended environmental authorisation, Thabametsi also does not have a generation licence, an air emission licence, or a water use licence.