“Deadly Air: Much to be done to improve air quality in parts of South Africa”, Daily Maverick

Sotyu said their monitoring stations measurements have shown that particulate matter, sulphur dioxide and ozone continue to be the key pollutants of concern, especially in the three priority areas of the Vaal Triangle, the Highveld and Waterberg-Bojanala region, as well as in cities and towns.

Nicole Loser, attorney and programme head of pollution and climate change at the Centre for Environmental Rights (CER) told Our Burning Planet that “air pollution is the world’s largest environmental health threat, accounting for seven million deaths around the world every year.

“Air pollution causes and exacerbates a number of diseases, ranging from asthma to cancer, pulmonary illnesses and heart disease.”

Loser said the CER is most concerned that air quality management is not treated with the necessary priority in South Africa, despite the grievous health impacts of air pollution — particularly for young people and the elderly.

At the lekgotla, which brought together about 350 air quality officials from all three spheres of government, scientists, policymakers and practitioners to deliberate on topical air quality management issues, Sotyu explained that “our air is affected by pollutants emitted from numerous sources, particularly industries, from power generation, mining operations, the transport sector, waste burning and from households, especially those still reliant on wood burning for heat and power”.

Sotyu acknowledged that air pollution levels in some areas are often over the legal thresholds specified in the National Ambient Air Quality Standards, saying that “exceeding these indicates that part of the population is exposed to air quality that is potentially detrimental to their health and wellbeing, especially within the three declared priority areas and our cities”.

Ntombi Maphosa, an attorney at the CER, said the impact of air pollution on human health had not been adequately addressed at the lekgotla.

“It would have been more enriching had the Department of Health been invited to present, especially in light of the recently published National Burden of Disease Study by the Medical Research Council which speaks to diseases caused by air pollution.”

Loser said that “addressing the complex air pollution problems in South Africa requires integrated and dedicated solutions and cooperation at all levels and sectors of government. Notably and concerningly absent from the table are the Departments of Health, Mineral Resources and Energy, and Trade and Industry”.

Particulate matter

On the first day of the three-day conference, the National Air Quality Officer, Patience Gwaze, presented the 2022 State of the Air report which revealed that “particulate matter is still of great concern, especially in Gauteng and Mpumalanga provinces”.

Air pollutants that are regulated by legal standards and that affect health include particulate matter such as sulphur dioxide and nitrous oxide.

As demonstrated in the charts, many areas in SA — including Gauteng, Mpumalanga, Free State, the Vaal Triangle Airshed Priority area, and part of the Western Cape — have concentrates of fine particulate matter (PM2.5) and particulate matter (PM10) that exceed National Ambient Air Quality Standards (NAAQS).

Gwaze said they were working on a National Emission Reduction Framework to achieve compliance with ambient air quality standards:

“We’ve got a bigger framework that we’re looking at for emission reduction over the entire country because we can see that particulate matter continues to be a challenge.”

Sulphur dioxide

Gwaze’s presentation showed sulphur dioxide levels as being in compliance with the NAAQS across the country.

“The standards I was referring to were our levels of sulphur dioxide in ambient [air quality] — it’s different from our levels of sulphur dioxide emitted,” clarified Gwaze to OBP, explaining that by the time ambient air is measured, “you have done a lot of mixing of atmosphere… you have done a lot of transformation of pollution and a lot of other things, and a lot of other sources have come into play.”

Gwaze explained that there are two types of standards — minimum emission standards that speak to industry meeting specific concentrations so that they reduce their impact on the environment, and ambient air quality standards that set a threshold in the ambient air.

Ambient air quality standards in SA are not far off WHO [World Health Organisation] guidelines, except for particulate matter.

The lead analyst from CREA said “the standards are insanely weak. Modelling results indicate that even those weak standards are likely violated in the area around Medupi and Matimba, but if those violations happen, they happen at specific locations and there is no guarantee that those locations coincide with one of the few air quality monitoring stations.

“It’s also a bit of a misdirection as the main reason to be concerned about the enormous SO2 [sulphur dioxide] emissions from Eskom and Sasol is the fact that they contribute to PM2.5 concentrations.”

Gwaze told OBP that their ambient air quality standards are designed with an understanding of achieving compliance with respect to the status of the country’s economy and local conditions.

“We take care of health; that’s the main objective. But we also want to understand where we are as a country. And we set standards that we can achieve.”

South Africa might be fairly okay in terms of ambient air standards, but its sulphur dioxide emissions are among the worst in the world.

According to a data analysis by the Centre for Research on Energy and Clean Air released in October last year, Eskom emits more sulphur dioxide into the atmosphere than any single power-producing company in the world.

Lauri Myllyvirta, air pollution and climate expert and lead analyst of the report, previously told OBP that considering that the European Union requires new coal plants to limit its emissions to 55mg/Nm³ (when converted to the measurement standard used in South Africa), and China to 25mg/Nm³, Kusile’s 500mg/Nm³ “is an extremely lenient limit”.

“The fact that it is pointed to as an achievement gives some perspective on how dirty the rest of the fleet is — emitting around 3,500mg/Nm³,” he said.

Problems in the Highveld

Loser explained that the Highveld is SA’s most polluted area, with the main air pollution sources being 14 polluting facilities — 12 Eskom coal power plants, Sasol’s coal-to-liquids facility and a Natref refinery.

“Government needs to take enforcement action to ensure that these facilities take the necessary steps to either abate and reduce emissions or shut down. We understand that these measures come at high cost, but the external costs to health as a result of this pollution also range in the billions,” said Loser.

“In any event, it is not acceptable that human lives should be the price of doing business, particularly when feasible and cheaper electricity sources, which do not have these same harmful impacts, are readily available.

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“Eskom should — as a matter of urgency — be taking all steps possible to roll out clean renewable energy, and start to decommission its old polluting facilities in line with a just transition plan.”

Sotyu said in her address, “the historical urban planning and segregations legacy of South Africa means that unhealthy pollution levels are often highest in low-income communities, such as townships, in urban areas, and in areas close to large industries.”

‘Deadly air’ case

After a long legal battle, in March 2022 groundWork and the Vukani Environmental Movement succeeded in the “Deadly Air” litigation brought by the Centre for Environmental Rights, where the high court confirmed that air pollution in the Highveld Priority Area (HPA) breaches the constitutional right to an environment not harmful to health or wellbeing, and that government must hold big polluters to account.

Sotyu said in her address that the high court handed down a “watershed” judgment.

“It calls on government to fast-track improvements in air quality management and to ensure that we uphold the constitutional rights for all citizens.

“It requires of government to strengthen our air quality management systems, especially by capacitating the state in the implementation of legislation, the introducing of air pollution reduction programmes, improvement in the management of monitoring infrastructure, and in authorisation and compliance monitoring.”

However, since the judgment, Loser said to their knowledge they have not yet seen what steps — if any — have been taken to strengthen compliance and enforcement against SA’s big polluters.

When asked, Gwaze said they had published priority area regulations for public comment and were in the process of finalising them.

Gwaze said the priority area regulations “will provide mechanisms and measures for us to effectively take account of the polluters, follow the emissions, check the emissions reduction programmes, make sure that we account for the implementation of the air quality management plans in the priority areas towards reducing emissions and compliance with ambient air quality standards.”

Sotyu said to fast-track improvements, priority area regulations would be submitted to DFFE Minister Barbara Creecy in due course, which will “provide the much-needed mechanisms to improve accountability and enforcement of priority areas’ air quality management plans and implementation thereof”.

Loser said that in light of the legal win, “we expect more to be done by government and more urgently to achieve tangible and meaningful emission reductions and address this unacceptable breach of constitutional rights for communities in the Highveld”.

“Though we applaud the progress of implementation regulations, we need these regulations to be strong on transparency, compliance and enforcement, and we also need to see actual air pollutant reductions in the Highveld.

“This requires steps to be urgently taken against SA’s biggest emitters, as well as other emission sources in the area such as mines, to ensure compliance with legislated emission and health-based air quality standards.”

Eskom noncompliance

Loser said that several Eskom facilities were unable to meet legislated emission standards — and didn’t intend to. In its latest interim report (interim results for the six months ended 30 September 2021), Eskom said “particulate emissions performance has improved, although challenges are still encountered at Kendal Power Station”.

The Eskom report revealed that at the end of September 2021, seven units were operating in non-compliance with average monthly emission limits, adding that “poor-performing units are placed on outage to undertake repairs, and load losses are taken by non-performing units”.

However, Eskom said that “relative particulate emission performance has improved to 0.32kg/MWh sent out (September 2020: 0.35kg/MWh sent out) due to an improvement in performance at Kendal Power Station”.

According to Eskom’s 2021 sustainability report, after the power utility applied for postponement for minimum emission standards (MES) in March 2019, the DFFE in July 2020 “provided approval to Eskom to operate its stations under pre-1 April 2020 emission limits until decisions on the MES applications had been finalised… subject to Eskom providing all outstanding information by August 2020”.

Gwaze said Eskom had a road map for compliance and that many companies had applied for a postponement on MES.

“When the Air Quality Act was put into place, we recognised that we’re sitting with a lot of old industries,” said Gwaze.

“A lot of those old industries could not come into compliance within the specified times of 2015. So they were given the ability to apply for postponement until 2020. And also the ability to apply for postponement until 2025.

“And those that are decommissioning have until 2030, because then there’ll be decommissioning and you want to avoid the facilities, [like] Eskom… putting in huge investment when they are to be decommissioned by 2030.”

Creecy has set up an advisory forum to work on Eskom’s noncompliance.