LAC Comments on IRP 2023: In the face of the climate emergency, the IRP2023 lacks climate commitment 

Share this post:


DATE: 27 MARCH 2024

In the face of the climate emergency, the IRP2023 lacks climate commitment

The Life After Coal Campaign, a joint environmental justice campaign by  Earthlife Africa (“ELA”), groundWork (“gW”), and the Centre for Environmental Rights (“CER”), along with Black Girls Rising (“BGR”) have submitted comments on the Draft Integrated Resource Plan (IRP) 2023. The submission highlights fundamental flaws and skepticism in the plans’ ability to ensure cost-effective electricity supply, energy security, and upholding South Africa’s Constitutional Right to a live in a healthy environment. The plan supports substantial fossil fuel-based generation, which is likely to exacerbate energy poverty. Expensive and economically risky technologies, such as extensive gas to power, are not necessary.

Delayed decommissioning of unreliable existing coal fleet perpetuates the costly and dangerous health crisis caused by deadly air pollution from coal fired power. The plan fails to account openly for the costs of these related impacts. In 2023, Eskom stated that its coal pollution kills more than 300 South Africans a year.  Adding to that, 32 000 South Africans could die if the country does not transition to a more sustainable pathway.

The energy plan also envisages new coal in its long-term outlook, falsely relying on unproven technology to capture carbon emissions in the pursuit of so-called clean coal, a myth supported by fossil fuel interests.

“The IRP 2023 does not, in real terms, commit to a least cost pathway, and instead opts for expensive technology and fuel choices. This will perpetuate energy poverty, making essential services for poor communities even more unaffordable and impacting on local economies. It is not aligned with a just transition, and takes us further into the direction of an exploitative, carbon intensive economy and society,” Makoma Lekalakala, Director of Earthlife Africa. 

The plan lacks sound climate commitment with questions and concerns about its impact on future greenhouse gas emissions reduction pathways. The Life After Coal submission highlights recent climate science findings and underscores the disproportionate impacts of climate change on vulnerable groups such women and children.

Xoli Fuyani, Founder and Director of Black girl rising commented that “We are not seeing, in this IRP, a commitment to reducing the climate impacts of our electricity system. Climate impacts are already severe, and we know that women and girls are disproportionately impacted. Future generations will have to pay for these unacceptable choices. IRP 2023 compromises gender, intergenerational, socio-economic and climate justice.”

As an exercise of public power, adopting an IRP is subject to the principle of legality. This means that, among others, the IRP must be rationally connected to its purpose and subject to adequate and reasonable public participation. Engagement with the public has been exceptionally poor in this process, with short commenting periods, and only two online public engagements. In addition, the provision of underlying information has been limited and there are few explanations or available calculations to provide motivation for the choices that the IRP claims to prefer.

“We are seeing a plan that not only locks us into coal fired power for longer, but also locks us into fossil gas, which is just as bad for the climate. This also makes us reliant on global gas markets with untold economic risks. This is unnecessary as there are pathways and technologies to deliver clean, affordable and reliable electricity in a shorter time period,” said Bobby Peek, Director of groundWork.     


Notes for Editor

Read Life After Coal comments on the Draft Integrated Resource Plan 2023

Life After Coal (Impilo Ngaphandle Kwamalahle) is a joint campaign by Earthlife AfricagroundWork, and the Centre for Environmental Rights. We aim to: discourage the development of fossil fuel developments; reduce emissions from existing coal infrastructure and encourage a coal phase-out; and enable a just transition from fossil fuels.

Black Girls Rising creates a community where girls are seen and given space to amplify their voices. They expose girls to new possibilities by breaking down barriers, giving them a window to dream and tools to realize their dreams

CONTACT: Lerato Balendran, , Tsepang Molefe,