Centre for Environmental Rights – Advancing Environmental Rights in South Africa

Media reports indicate that the Minister of Energy has instructed the Department of Energy to publish the long-overdue update to the crucially important Integrated Resource Plan for Electricity 2010-2030 (IRP) within the next week.

At this critical juncture in South Africa’s energy future, our choices have to be based on sound, accurate, current, and accepted energy policy that will benefit all South Africans. The Life After Coal/Impilo Ngaphandle Kwamalahle Campaign (made up of groundWork, the Centre for Environmental Rights and Earthlife Africa, Johannesburg) and Greenpeace Africa would like to reiterate our position on what we expect to see in the IRP.

We also express our alarm that, despite earlier statements in Parliament by the Department of Energy that there would be provision for further consultation on the draft IRP, the Minister has since suggested that a final policy-adjusted IRP will be promulgated without further public participation. To date, stakeholders have only had an opportunity to consider and comment on the draft IRP base case and assumptions published a year ago in November 2016. An open and democratic IRP process requires first, a new base case taking account of those comments, and then open discussion of any variations that will be taken into account in the drafting of a policy-adjusted IRP.  A policy-adjusted IRP without further public participation can only be viewed as illegitimate.

The Life After Coal campaign and Greenpeace Africa jointly record the following basic principles that must, as a minimum, be met by the updated IRP:

1. The Base Case scenario should be the least cost combination of technologies to achieve South Africa’s electricity requirements. After that, policy adjustments and constrained scenarios can be run, but any deviation from the least cost should be made public and fully explained, so that policy-makers and the public are able to make a value-for-money assessment of the deviation.[1]
2. It must take full account of the external costs of the different technologies, ensuring that all external costs to human health, the environment, and the climate are factored into cost calculations in respect of different technology options.[2]
3. It must be based on only the latest, accurate projections and input data, including data on South Africa’s GDP, electricity demand (with proper consideration of improved energy efficiency and grid defection), and technology cost and price comparisons.
4. It must clearly indicate and explain all assumptions on which all modelling is based, and it must verify and reference all sources of information, findings and conclusions; including those regarding job creation; GDP forecasts; energy-intensity; learning rates; and costs of different technology options.
5. It must not arbitrarily constrain or limit renewable energy projections and investments.
6. It must be based on the latest scientific information and international best practice, including the latest scientific conclusions on climate change, which clearly indicate that keeping global temperature rise to below 1.5 degrees Celsius is critical to avoid catastrophic climate change.
7. The electricity sector carbon constraint must be derived from integrated, full sector energy planning. It must, at a bare minimum, take into account South Africa’s mitigation commitments in its Nationally Determined Contribution (NDC) under the Paris Agreement and be consistent with South Africa’s obligations under the Paris Agreement and the United Nations Framework Convention on Climate Change, as well as South Africa’s National Climate Change Response Policy.  The NDC commitments must not be modelled as a potential future scenario, but as an existing commitment, with which South Africa has undertaken to comply.  It must also take into account that South Africa will need to submit stricter and more rigorous mitigation commitments in its NDC every 5 years. It should take into account that decarbonising the electricity sector is the lowest cost mitigation option for the country to meet these international commitments.
8. It must be consistent with South Africa’s other international obligations, including the Convention on Biological Diversity, the international law obligations to avoid transboundary air pollution and regional water treaties.
9. It must take into account the international move away from fossil fuels and nuclear and the financial implications of future stranded assets and of nuclear decommissioning costs – including the implications of managing the long-term risk of nuclear waste – as a result of proceeding with plans for future new coal and nuclear projects.
10. It must be consistent with the requirements of national legislation, as well as the objectives of the Electricity Regulation Act, 4 of 2006 including ensuring that the interests and needs of present and future electricity customers and end users are safeguarded and met, and promoting the use of diverse energy sources and energy efficiency.
11. It must promote the realisation of the fundamental human rights in the Constitution, in particular the rights: to an environment not harmful to health or well-being, and to have the environment protected for the benefit of present and future generations (section 24); to human dignity (section 10); to life (section 11); and to access to food and water (section 27).  In this regard, there must be a full assessment into the impacts of different technology and energy source choices on these constitutional rights.

In summary, decisions on our energy mix must be taken with full transparency and proper regard to what is in the best interest of all South Africans. In this regard, the Minister must give serious consideration to the negative impacts of coal on human health, the environment (including our scarce water resources), global climate change, and the economy.

Any IRP, and any subsequent decisions made relying on that IRP, that do not comply with these minimum requirements, will be challenged.

END

[1] http://www.ee.co.za/wp-content/uploads/2016/11/RE-Futures-Windaba-CSIR-3Nov2016_FINAL.pdf; http://www.engineeringnews.co.za/article/new-study-points-to-90-renewables-mix-being-least-cost-by-2050-2017-09-15; http://rodoyo.com/gtac/GTAC%20in%20Pretoria%20-%20Energy%20Planning%20-%20TBN%20-%204Aug2017.pdf

[2] https://cer.org.za/news/joint-media-release-cost-of-health-and-water-impacts-of-coal-still-missing-from-energy-plans

For media queries, please contact Annette Gibbs on [email protected] or 082 467 1295.

Life After Coal Campaign organisations:

• Centre for Environmental Rights: Annette Gibbs, Email: [email protected], Mobile: 082 467 1295
• groundWork: Bobby Peek, Email: [email protected], Mobile: 082 464 1383
• Earthlife Africa: Makoma Lekalakala, Email: [email protected], Mobile: 082 682 9177

Greenpeace Africa: Lerato Ngakane, Climate and Energy Communications Officer, Email: [email protected], Mobile 082 614 2676, email