No room for secrecy: Environmental organisations publish minimum requirements for SA’s overdue Integrated Resource Plan for electricity
31 October 2016 at 11:59 am
The Life After Coal Campaign (made up of groundWork, the Centre for Environmental Rights and Earthlife Africa, Johannesburg) together with Greenpeace Africa are deeply concerned about the current state of South Africa’s energy policy. Vital procurement decisions are being made in a turbulent, chaotic environment, mired by controversy, secrecy and misrepresentation. At this critical juncture in our energy future, our choices have to be based on sound, accurate, current and accepted energy policy that will benefit all South Africans.
Central to proper decision-making is the long-overdue update to the Integrated Resource Plan for Electricity 2010-2030 (IRP). The Minister of Energy has expressed intentions to release the updated IRP before the end of this year, but there is some doubt as to whether this will be subject to a reasonable and fair opportunity for the public to make input. Since these energy decisions have significant impacts for all South Africans, and for constitutional environmental rights, there is no room for secrecy or box-ticking: there must be full and meaningful stakeholder engagement in all stages of the process towards finalising an updated IRP.
Life After Coal and Greenpeace Africa jointly record the following basic principles that must, as a minimum, be met by the updated IRP before it is made available for public participation:
- 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.
- 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.
- 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 comparisons.
- 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 and costs of different technology options.
- It must not unnecessarily constrain or limit renewable energy projections and investments.
- 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.
- The electricity sector carbon constraint must be derived from integrated, full sector energy planning. It must take into account South Africa’s mitigation commitments in its Nationally Determined Contribution (NDC) under the Paris Agreement and, at a bare minimum, 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.
- 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.
- 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 as a result of proceeding with plans for future new coal and nuclear projects.
- 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; promoting the use of diverse energy sources and energy efficiency; promoting competitiveness and customer and end user choice; and facilitating a fair balance between the interests of customers and end users, Licensees, investors in the electricity supply industry and the public.
- 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 regard to the negative impacts of coal on human health, the environment (including our scarce water resources), global climate change, and the economy.