Centre for Environmental Rights – Advancing Environmental Rights in South Africa

On 13 December 2019 the CER submitted a PAIA request to the DMRE for the following documents:

1. The Plexos modelling input and output data used for the Integrated Resource Plan for Electricity of 17 October 2019 (“IRP 2019”), to be made available and executable in formulas intact in Excel form.
2. The data and records that informed the emissions externality costs referred to in Table 2 (page 32) of the IRP 2019;
3. Records reflecting the total cost output, and the resulting average tariff, of the least-cost scenario (the baseline for the IRP);
4. Records reflecting the incremental cost output and tariff increase of all scenarios of the IRP 2019, including, but not limited to, the recommended plan in the IRP 2019;
5. Records of the costs and technology options that were considered in making the assumption in the IRP 2019 (at page 52) that “all new coal to power capacity beyond the already procured 900 MW will be in the form of clean coal technology”;
6. Records of the decisions to review the determinations made under the 2010 IRP – in particular the 2012 Ministerial Determination in terms of section 34 of the Electricity Regulation Act, 2006 (GN 1075) for 2500MW of new coal capacity – in reference to the statement on page 62 of the IRP 2019 that “Ministerial Determinations issued under the IRP2010 will be reviewed in consultation with NERSA, once the updated IRP is approved.”
7. Records of studies and considerations, including financial considerations, on the “supply and demand balance and the impact of load shedding on the economy” that were taken into account in making the recommendation against “shutting down of MES non-compliant power plants and Koeberg power station in 2024 (at the end of its design life)” (page 44);
8. Records of considerations that were taken into account in reaching the decision (on page 46) that “the application of renewable build limits “smoothes out” the capacity allocations for wind and solar PV which provides a constant pipeline of projects for investment; this addresses investor confidence”;
9. The supporting documentation for the annual build limits of 1000 MW for PV and 1600 MW for wind and how they were calculated.

The following documents were submitted by the CER on 13 December 2019:

• Cover letter
• Completed PAIA Request – Form A

The following documents were received from the Deputy Director General in the Department on 25 June 2020:

• Response from DMRE to CER
  • Annexure A – Technology Costs
  • Annexure B – CO2 output & Water use IRP
  • Annexure C – RE build Limits
  • Annexure D – Impact of MES on Installed Capacity

The following documents were sent by the CER on 02 September 2020:

• CER letter to DMRE