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): MISSING COSTS

The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, submitted additional comments to the South African Department of Energy regarding the Integrated Resource Plan (IRP) and Integrated Energy Plan (IEP). The letter argues that current energy modelling fails to account for critical externalities, specifically the health and water costs of coal, the high nitrous oxide emissions associated with circulating fluidised bed combustion technology, and comprehensive nuclear lifecycle costs.

• The Life After Coal Campaign and Greenpeace Africa argue that both the Department of Energy's draft IRP and the Council for Scientific & Industrial Research's (CSIR) alternative IRP fail to adequately incorporate the health and water costs associated with new and existing coal investments.
• The circulating fluidised bed combustion (CFB) technology proposed for the Thabametsi coal-fired power station and other bidders in the Coal Baseload Independent Power Producer Procurement Programme (CBIPPPP) produces significant nitrous oxide (N2O) emissions. This makes Thabametsi 60% worse in greenhouse gas (GHG) emission intensity than Eskom's Medupi and Kusile power stations, a factor the CER claims was not considered in the Department's modelling.
• The CER asserts that the Department's costing model for nuclear energy is insufficient because it only considers construction, operation, and fuel costs. It demands the inclusion of decommissioning costs, used fuel storage and handling costs, and insurance risk cover.

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): MISSING COSTS. https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-DoE-re-IRP_11-Aug-2017.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): MISSING COSTS. 2017. https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-DoE-re-IRP_11-Aug-2017.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): MISSING COSTS |date=11 August 2017 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-DoE-re-IRP_11-Aug-2017.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): MISSING COSTS}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = aug, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-Letter-to-DoE-re-IRP_11-Aug-2017.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }