CSIR’S COMPREHENSIVE ALTERNATIVE INTEGRATED RESOURCE PLAN (IRP) FOR ELECTRICITY: MISSING COSTS

The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, submitted a letter to the Council for Scientific & Industrial Research (CSIR) on 11 August 2017. The letter argues that the CSIR's "comprehensive alternative" Integrated Resource Plan (IRP) for electricity fails to account for critical health, water, climate, and nuclear-related costs, which leads to an underestimation of the true cost of coal and nuclear energy compared to renewable alternatives.

• The CSIR's alternative IRP completely omits health costs associated with coal-fired power. In contrast, research by Dr Mike Holland indicates that air pollution from coal-fired generation in South Africa creates a substantial health burden, including premature deaths and illness, with a total quantifiable economic cost estimated at approximately R33 billion per year.
• The document asserts that neither the CSIR nor the Department of Energy (DoE) have fully calculated the costs of coal mining and power generation on freshwater resources, including acid mine drainage and coal washing. The CER notes a discrepancy in water consumption data: while the draft IRP Base Case indicates 1.15 litres/kWh, Eskom's actual 2016 consumption was 1.44 litres/kWh, totaling 314.685 million cubic metres.
• The CER highlights that the circulating fluidised bed combustion (CFB) technology planned for the Thabametsi coal-fired power station results in significant nitrous oxide (N2O) emissions. This makes the plant's greenhouse gas (GHG) emission intensity 60% worse than Eskom's new Medupi and Kusile power stations, a factor the CER claims was not considered in CSIR's modelling.
• The letter identifies missing costs in the nuclear energy modelling, stating that it is insufficient to only consider construction, operation, and fuel costs. The CER demands the inclusion of decommissioning costs, used fuel storage and handling costs, and insurance risk cover.

APA

Centre for Environmental Rights (2017). CSIR’S COMPREHENSIVE ALTERNATIVE INTEGRATED RESOURCE PLAN (IRP) FOR ELECTRICITY: MISSING COSTS. https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-CSIR-re-IRP_11-Aug-2017.pdf?x21779

Chicago

Centre for Environmental Rights. CSIR’S COMPREHENSIVE ALTERNATIVE INTEGRATED RESOURCE PLAN (IRP) FOR ELECTRICITY: MISSING COSTS. 2017. https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-CSIR-re-IRP_11-Aug-2017.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=CSIR’S COMPREHENSIVE ALTERNATIVE INTEGRATED RESOURCE PLAN (IRP) FOR ELECTRICITY: MISSING COSTS |date=11 August 2017 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-CSIR-re-IRP_11-Aug-2017.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2017csirs, author = {{Centre for Environmental Rights}}, title = {{CSIR’S COMPREHENSIVE ALTERNATIVE INTEGRATED RESOURCE PLAN (IRP) FOR ELECTRICITY: MISSING COSTS}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = aug, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-CSIR-re-IRP_11-Aug-2017.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }