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AIR QUALITY BILL Comments from Eskom Steve
Lennon Managing Director - Resources Strategy
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Share of Global Energy Consumption (WEC)
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SA ENERGY POLICY

• The Energy Policy of South Africa, provides
  valuable high level guidance regarding the
  priorities related to the energy sector. The five
  priority areas for South African energy policy
  are
• ? increasing access to affordable energy
  services
• ? improving energy governance
• ? stimulating economic development
• ? managing energy related environmental impacts
• ? securing supply through diversity.

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PARTICULATE EMISSIONS
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CURRENT GASEOUS EMISSION CONTROL

• LOW SULPHUR COAL USED FROM INCEPTION
• INTERNATIONAL NORM FOR SO2 EMISSION REDUCTION
  PROGRAMMES
• EXPORT BENEFIT

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ESKOM AMBIENT AIR QUALITY MONITORING NETWORK
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AIR QUALITY IN MPUMALANGA
70
60
50
40
30
20
10
0
Vaal Triangle
Central Mpumalanga
Leandra
NOx (ppb)
SO2 (ppb)
FPM (µg/m3)
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ESKOMS RESPONSE TO THE BILL

• Process
• The consultation process could have been improved
• Essential requirement to consider the economic,
  social and technical implications in decision
  making, whilst recognising the need for long term
  improvements in ambient air quality and
  environmental performance

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ESKOMS RESPONSE TO THE BILL

• There are many areas of the AQB where
  consultation with stakeholders is a necessity
• establishment of a national framework
• management plans
• pollution prevention plans and
• issues related to the licensing authority

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ESKOMS RESPONSE TO THE BILL

• Strategic issues for the Electricity Supply
  Industry
• The ESI has been established as a single
  integrated power distribution network and not
  individual power stations
• National Integrated Resource Plan, is carried out
  at a strategic level and projections of supply
  and demand side options to meet long-term load
  forecasts
• Regulation by entities may have an unintended
  knock-on effect in terms of impact on the network
  as a whole, and can be disproportionate to the
  originally intended impact

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ESKOMS RESPONSE TO THE BILL

• Strategic issues for the Electricity Supply
  Industry
• The ESI is and has always operated as a strategic
  entity in relation to the vital resource of
  electricity within South Africa
• Electricity underpins many of the objectives of
  sustainable development and in particular,
  government policy as articulated in the White
  Paper on the Energy Policy for South Africa and
  GEAR
• The ESI should therefore be accorded the status
  of a strategic industry, as a result of the
  special challenges that intimately affect the
  national interest

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ESKOMS RESPONSE TO THE BILL

• Strategic issues for the Electricity Supply
  Industry
• Licensing considerations should occur at a
  national level for the ESI, in conjunction with
  the relevant local and/or provincial authorities
• Exemptions should be structured to allow for
  emergency or abnormal start-up situations

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ESKOMS RESPONSE TO THE BILL

• The AQB provides for a national framework,
  setting national norms and standards
• Standards South Africa initiated a process for
  defining ambient air quality standards through a
  multi-stakeholder committee
• The suggested framework outlines a comprehensive
  process for
• defining current air quality,
• time frames for implementation or achievement

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ESKOMS RESPONSE TO THE BILL

• Ambient air quality standards need to be set
  within a defined framework, which takes into
  consideration the varied and sometimes
  conflicting factors associated with the
  management of air quality
• Ambient air quality must be managed in a holistic
  manner and standards cannot be set in isolation
  without consideration of associated
  socio-economic factors and the implications of
  setting timeframes for the achievement of
  standards.

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ESKOMS RESPONSE TO THE BILL

• It is strongly recommended that the proposed
  Standards South Africa standard provide the basis
  of the National Framework identified in the Air
  Quality Bill in Chapter 2

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ESKOMS RESPONSE TO THE BILL

• Environmental impact assessments
• A parallel process for conducting an EIA on a new
  plant and obtaining a emissions licence must be
  considered
• Environmental impact assessments in terms of
  Section 24 of NEMA should not as a norm, be
  required retrospectively in respect of existing
  facilities

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ESKOMS RESPONSE TO THE BILL

• Offences
• Section 48 of the AQB provides for offences
• It is inappropriate that isolated contraventions
  should allow a person to be branded someone who
  is not a fit and proper person and be found
  guilty of an offence
• Proposed that section 48 (1) (b) be amended to
  read as follows
• (b) consistently and substantively contravenes
  or fails to comply with a condition or
  requirement of an atmospheric emission license

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ESKOMS RESPONSE TO THE BILL

• Transitional ambient air quality standards
• Section 60 has been substantially modified
• Specific interim guidelines have been detailed
  without stakeholder consultation
• It is abnormal to write guidelines into
  legislation
• The guidelines should retain their current status
  until standards have been determined

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ESKOMS RESPONSE TO THE BILL

• The Air Quality Bill also be tabled before other
  relevant parliamentary portfolio committees, in
  particular the Minerals and Energy Portfolio
  Committee

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Thank you