Reminder: Environmental organisations’ minimum requirements for SA’s IRP and IEP, due for release tomorrow

November 21, 2016 - On Tuesday, 22 November 2016, the Department of Energy is briefing the media on the release the Draft Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP) for public consultation. The IEP “aims to guide future energy infrastructure investments over the period up to 2050, and identify and recommend policy options to shape the future energy landscape of the country. The IRP serves to guide government’s plan for electricity provision within the energy mix.”

On 31 October 2016, the Life After Coal Campaign (made up of groundWorkthe Centre for Environmental Rights and Earthlife Africa, Johannesburg) together with Greenpeace Africa released a set of basic principles that must, as a minimum, be met by the updated IRP. Here are those principles again:

  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.
  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.
  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 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 and costs of different technology options.
  5. It must not unnecessarily 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 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.
  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 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; 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.
  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 respect, 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.

The Minister must also take account of research by the Council for Scientific and Industrial Research (CSIR), which demonstrates that least-cost energy model does not include any new nuclear power generation and shows a decline in coal-based electricity production from 2020. The CSIR found that having 70 percent renewables by 2040 was not only technically feasible, but also the cheapest option for South Africa.

Here is the full media release of 31 October 2016, which also deals more expressly with the need for full and meaningful stakeholder engagement in all stages of the process towards finalising an updated IRP.

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