DETERMINATION FOR NEW GENERATION CAPACITY FROM RENEWABLES, STORAGE, GAS AND COAL IN TERMS OF SECTION 34 ELECTRICITY REGULATION ACT 2006

The Centre for Environmental Rights (CER), acting for groundWork, sent a formal letter to the National Energy Regulator of South Africa (NERSA) on 30 October 2020. The letter requests detailed reasons and evidence for NERSA's decision to concur with a determination to procure 3,000 MW of gas and 1,500 MW of coal generation capacity between 2023 and 2027, as outlined in the Integrated Resource Plan for Electricity 2019–2030 (IRP 2019).

• The CER is challenging NERSA's concurrence with a determination to procure 3,000 MW of gas generation capacity for the years 2024 to 2027 and 1,500 MW of coal generation capacity for the years 2023 to 2027, both based on Table 5 of the IRP 2019.
• CER questions the cost estimations used by NERSA to claim gas is more attractive than other technologies, specifically citing NERSA's figures for overnight costs: R22,262/kW for gas plants with Carbon Capture and Storage (CCS), R27,432/kW for wind plants with 3 hours' battery storage, and R107,135/kW for solar thermal plants with 6 hours' storage.
• The CER seeks evidence for NERSA's claims that gas infrastructure investments would create a multiplier effect for other economic sectors and that domestic gas extraction would stimulate growth by reducing exposure to international market forces.
• CER requests clarification on NERSA's recommendation to use temporary LNG infrastructure, such as cryogenic containers via road or rail, and Liquefied Petroleum Gas (LPG), to meet a 2024 grid connection deadline for the first 1,000 MW of gas.
• The CER questions whether NERSA performed independent modelling to verify that the addition of 3,000 MW of gas and 1,500 MW of coal is consistent with the 'Peak-Plateau-Decline' emissions trajectory and South Africa's Paris Agreement commitments.
• CER challenges NERSA's position that new coal projects must use High Efficiency Low Emissions (HELE) technologies, requesting evidence on the local feasibility and desirability of technologies such as underground coal gasification and integrated gasification combined cycle.
• The CER highlights that NERSA suspended public hearings due to the COVID-19 pandemic, relying instead on written comments, and requests the legal reasons for declining a public inquiry under the Promotion of Administrative Justice Act (PAJA).

APA

Centre for Environmental Rights (2020). DETERMINATION FOR NEW GENERATION CAPACITY FROM RENEWABLES, STORAGE, GAS AND COAL IN TERMS OF SECTION 34 ELECTRICITY REGULATION ACT 2006. https://cer.org.za/wp-content/uploads/2020/11/CER-letter-to-NERSA_request-for-reasons_-30-October-2020.pdf?x21779

Chicago

Centre for Environmental Rights. DETERMINATION FOR NEW GENERATION CAPACITY FROM RENEWABLES, STORAGE, GAS AND COAL IN TERMS OF SECTION 34 ELECTRICITY REGULATION ACT 2006. 2020. https://cer.org.za/wp-content/uploads/2020/11/CER-letter-to-NERSA_request-for-reasons_-30-October-2020.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=DETERMINATION FOR NEW GENERATION CAPACITY FROM RENEWABLES, STORAGE, GAS AND COAL IN TERMS OF SECTION 34 ELECTRICITY REGULATION ACT 2006 |date=30 October 2020 |url=https://cer.org.za/wp-content/uploads/2020/11/CER-letter-to-NERSA_request-for-reasons_-30-October-2020.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2020determination, author = {{Centre for Environmental Rights}}, title = {{DETERMINATION FOR NEW GENERATION CAPACITY FROM RENEWABLES, STORAGE, GAS AND COAL IN TERMS OF SECTION 34 ELECTRICITY REGULATION ACT 2006}}, publisher = {Centre for Environmental Rights}, year = {2020}, month = oct, url = {https://cer.org.za/wp-content/uploads/2020/11/CER-letter-to-NERSA_request-for-reasons_-30-October-2020.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }