ADDITIONAL WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN (IRP) UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN (IEP)

The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted additional comments to the South African Department of Energy regarding the Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP). The CER argues that these plans must incorporate missing cost calculations for coal and nuclear energy, as well as findings from recent studies suggesting that accelerating the decommissioning of coal plants and cancelling new coal and nuclear capacity is the most cost-effective path for Eskom and the national grid.

• The CER identifies several critical omissions in the Department of Energy and CSIR's modelling, including the failure to account for health and water costs of coal investments, the greenhouse gas nitrous oxide (N2O) emissions from circulating fluidised bed combustion (CFB) technology used by IPPs like Thabametsi and Khanyisa, and the exclusion of nuclear decommissioning, used fuel storage, and insurance risk costs.
• A study by Meridian Economics suggests that Eskom could save up to R17 billion by accelerating the decommissioning of the Grootvlei, Komati, and Hendrina coal-fired power stations and curtailing the completion of Kusile units 5 and 6, without compromising the security of supply.
• Analysis from the CSIR Energy Centre and the Frankfurt Institute for Advanced Studies indicates that new coal and nuclear plants are no longer competitive. The Frankfurt study specifically finds that a system based on wind and solar PV is 10%-30% cheaper than one based on new coal and nuclear, even when accounting for grid and transmission investments.
• The CER highlights that the health costs associated with Eskom's coal-fired power stations are significant, estimated at USD 2,372.78 annually according to a study commissioned by groundWork.

APA

Centre for Environmental Rights (2017). ADDITIONAL WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN (IRP) UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN (IEP). https://cer.org.za/wp-content/uploads/2017/11/CER-Letter-to-DOE-20-11-17.docx.pdf?x21779

Chicago

Centre for Environmental Rights. ADDITIONAL WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN (IRP) UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN (IEP). 2017. https://cer.org.za/wp-content/uploads/2017/11/CER-Letter-to-DOE-20-11-17.docx.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=ADDITIONAL WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN (IRP) UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN (IEP) |date=20 November 2017 |url=https://cer.org.za/wp-content/uploads/2017/11/CER-Letter-to-DOE-20-11-17.docx.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2017additional, author = {{Centre for Environmental Rights}}, title = {{ADDITIONAL WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN (IRP) UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN (IEP)}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = nov, url = {https://cer.org.za/wp-content/uploads/2017/11/CER-Letter-to-DOE-20-11-17.docx.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }