OBJECTION BY GROUNDWORK SOUTH AFRICA TO KARPOWERSHIP SA RICHARDS BAY (RF) (PTY) LIMITED'S APPLICATION FOR AN ELECTRICITY GENERATION LICENCE SUBMITTED TO THE NATIONAL ENERGY REGULATOR OF SOUTH AFRICA

Groundwork South Africa submitted an affidavit to the National Energy Regulator of South Africa (NERSA) objecting to Karpowership SA Richards Bay's application for an electricity generation licence. The objection argues that the project fails to meet the requirements of the Electricity Regulation Act (ERA) and the National Energy Regulator Act (NERA), citing severe environmental risks, lack of necessary permits, and the existence of cheaper, cleaner energy alternatives.

• The project is predicted to generate approximately 17 million tCO2e in scope 1 emissions over its 20-year lifespan, with an additional 670,000 tCO2e from FSRU operations and 126,000 tCO2e in scope 3 emissions. This would exhaust about 0.82% of South Africa's adjusted national carbon budget, leading to a "Very high" impact rating.
• The Department of Forestry, Fisheries and Environment (DFFE) rejected Karpowership's Environmental Impact Assessment (EIA) and refused environmental authorisation in June 2021. The DFFE cited gaps in reports regarding underwater noise, avifaunal impacts, and the effects of heated water discharge, as well as failures to meet minimum public participation requirements.
• The project's location is adjacent to ecologically sensitive habitats in the Richards Bay estuary, including the sandspit Kabeljous Flats, mangrove habitats, and the uMhlathuze Estuary sanctuary. It is situated in a "CBA irreplaceable" location critical for biodiversity targets and near the Richards Bay Nature Reserve and Enseleni Nature Reserve.
• The project poses risks to marine ecology, specifically regarding underwater noise and vibration. The final EIA lacked sufficient data on the Richards Bay port and relied on general data from commercial vessels and a project in Ghana, failing to consider impacts on the Ocean Humpback Dolphin, a species on the IUCN Red List of Threatened Species.
• Groundwork argues that the Risk Mitigation Independent Power Producer Procurement Programme (RMIPP) was skewed toward expensive fossil fuel projects by requiring bidders to be dispatchable from 05:00 to 21:30, which excluded lower-cost renewable options.
• Analysis suggests that a combination of solar PV, wind, and storage could provide the required 30 TWh of capacity more cost-effectively than the Karpowership projects. The Meridian Economics report indicates that new gas capacity is not needed to meet peak demand for at least 10 to 15 years.
• The project risks creating "stranded assets" and locking South Africa into high electricity costs for 20 years. The Power Purchase Agreement (PPA) requires Eskom to compensate Karpowership for at least 72.72% of net available capacity at prices linked to volatile LNG fuel prices.
• The licensing process is described as procedurally unfair due to inadequate public notification, a short comment period, and extensive redactions in the application documents, including details on fuel supply, tariffs, and project financing.

APA

Centre for Environmental Rights (2021). OBJECTION BY GROUNDWORK SOUTH AFRICA TO KARPOWERSHIP SA RICHARDS BAY (RF) (PTY) LIMITED'S APPLICATION FOR AN ELECTRICITY GENERATION LICENCE SUBMITTED TO THE NATIONAL ENERGY REGULATOR OF SOUTH AFRICA. https://cer.org.za/wp-content/uploads/2021/08/gW-Objection-Karpowership-Richards-Bay-NERSA-Comissioned-4.08.2021.pdf?x21779

Chicago

Centre for Environmental Rights. OBJECTION BY GROUNDWORK SOUTH AFRICA TO KARPOWERSHIP SA RICHARDS BAY (RF) (PTY) LIMITED'S APPLICATION FOR AN ELECTRICITY GENERATION LICENCE SUBMITTED TO THE NATIONAL ENERGY REGULATOR OF SOUTH AFRICA. 2021. https://cer.org.za/wp-content/uploads/2021/08/gW-Objection-Karpowership-Richards-Bay-NERSA-Comissioned-4.08.2021.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=OBJECTION BY GROUNDWORK SOUTH AFRICA TO KARPOWERSHIP SA RICHARDS BAY (RF) (PTY) LIMITED'S APPLICATION FOR AN ELECTRICITY GENERATION LICENCE SUBMITTED TO THE NATIONAL ENERGY REGULATOR OF SOUTH AFRICA |date=4 August 2021 |url=https://cer.org.za/wp-content/uploads/2021/08/gW-Objection-Karpowership-Richards-Bay-NERSA-Comissioned-4.08.2021.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2021objection, author = {{Centre for Environmental Rights}}, title = {{OBJECTION BY GROUNDWORK SOUTH AFRICA TO KARPOWERSHIP SA RICHARDS BAY (RF) (PTY) LIMITED'S APPLICATION FOR AN ELECTRICITY GENERATION LICENCE SUBMITTED TO THE NATIONAL ENERGY REGULATOR OF SOUTH AFRICA}}, publisher = {Centre for Environmental Rights}, year = {2021}, month = aug, url = {https://cer.org.za/wp-content/uploads/2021/08/gW-Objection-Karpowership-Richards-Bay-NERSA-Comissioned-4.08.2021.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }