22 November 2016 - Earlier today, the Minister of Energy announced the publication of the long-awaited draft Integrated Energy Plan (IEP) and draft Integrated Resource Plan for Electricity (IRP) Assumptions and Base Case Reports – a move welcomed by the Life After Coal Campaign (made up of groundWorkthe Centre for Environmental Rights and Earthlife Africa, Johannesburg).  These are vital policy documents setting out government’s plans for South Africa’s future energy mix.

The Campaign, along with environmental justice organisation Greenpeace Africa, have previously released a set of basic principles that must, as a minimum, be met by the updated IRP. Among other things, any future energy mix must ensure that the fundamental constitutional right to an environment not harmful to health or well-being, and to have the environment protected for the benefit of present and future generations is realised.

The presentations released today are not adequate for purposes of comprehensive comment on the IRP or IEP, as the presentations do not represent a full set of assumptions, contain gaps, and have not been fully explained.

Initial comments
However, these are our initial observations based on the Minister’s presentations of today:

All of this is contrary to international developments, commitments and research by the Council for Scientific and Industrial Research (CSIR). In particular, the proposed percentage share for renewable energy (mostly wind and solar PV) is not nearly ambitious enough. Significantly, representatives from 47 of the world’s most disadvantaged nations – including Bangladesh and Ethiopia – pledged, at COP22, to generate all their future energy needs from renewables.

It is clear that both new coal and nuclear would significantly constrain the real potential growth in renewables, i.e. renewable energy potential would not be fully realised.

The Campaign objects to the inclusion of any new coal or nuclear generation into South Africa’s future energy mix, given the significant health, environment, climate change and cost implications of coal and nuclear. With South Africa’s world-leading potential for renewable energy sources, there is no place for risky and costly investments in coal and nuclear in our energy mix.

Consultation period inadequate

Consultation processes are scheduled to commence in December and to be completed by February 2017, with a “policy adjustment” planned for March 2017.  With only 2 months provided for consultation, and with this period falling over the festive season, the proposed consultation process is inadequate. As the Campaign previously submitted, the consultation process must provide for full and meaningful stakeholder engagement in all stages and especially in coal-impacted areas. Stakeholders must have a reasonable opportunity (of at least 90 days) to consider, and obtain the necessary advice to make submissions on these important documents.

Furthermore, it appears that only the Assumptions and Base Case Reports for the IRP will be released for comment. It would be unacceptable for the Department not to make the full IRP available for consultation and comment.

The draft documents are expected to be gazetted on 25 November 2016 and to be made available on the Department of Energy’s website soon. Once available, Life After Coal plans to (in consultation with community partners and experts) consider and comment more comprehensively on the IEP and IRP documents.