Integrated Resource Plan 2018 – groundWork comment

This document is a formal comment by groundWork submitted to the South African Department of Energy regarding the Integrated Resource Plan (IRP) 2018. The author argues that the IRP 2018 fails to address the urgency of the climate crisis, underestimates the health and environmental costs of coal, and maintains an outdated energy model that prioritizes coal and gas over a rapid transition to renewables.

• The IRP 2018 is criticized for lacking a meaningful carbon constraint, effectively allowing power sector emissions to remain high. The document asserts that the 'peak, plateau and decline' trajectory allows emissions of 275 Mt CO2 per year through 2035, and that the 'least cost' scenario is the only one that reduces emissions without arbitrary constraints on renewables.
• The author claims the IRP 2018 severely undervalues the social and health costs of local emissions. By comparing IRP externality costs for nitrogen oxides (NOx) and particulate matter (PM) with European Environment Agency (EEA) values, the document suggests that the South African government values European lives between 18 and 36 times more than South African lives.
• The document argues that the IRP's demand projections are unrealistic and that Eskom is attempting to boost sales through cut-price deals for energy-intensive industries. This is seen as a failure of demand-side management, which the author notes appears only in the plan's glossary.
• The IRP 2018's 'recommended plan' includes new coal-fired capacity through the Thabametsi (630 MW) and Khanyisa (300 MW) plants. The author contends these are unnecessary because the supply crisis ended in 2015 and that these plants will displace renewables at an additional cost of approximately R20 billion and 170 Mt CO2 over 30 years.
• The document expresses concern over the IRP's call for 8,100 MW of new gas, noting that this may lead to fracking in the Karoo or offshore exploration. The author warns that methane leaks from these processes could eliminate the carbon advantage of gas over coal, as methane is a potent greenhouse gas.
• The author advocates for a 'just transition' based on the Million Climate Jobs campaign, which proposes supplying all of South Africa's electricity from renewables by 2038. This would require building 15,000 MW of wind and solar power annually and could create 250,000 initial jobs and 88,000 maintenance and operations jobs.

APA

Centre for Environmental Rights (2018). Integrated Resource Plan 2018 – groundWork comment. https://cer.org.za/wp-content/uploads/2018/10/IRP-2018-gW-Comment-Final.pdf?x21779

Chicago

Centre for Environmental Rights. Integrated Resource Plan 2018 – groundWork comment. 2018. https://cer.org.za/wp-content/uploads/2018/10/IRP-2018-gW-Comment-Final.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=Integrated Resource Plan 2018 – groundWork comment |date=26 October 2018 |url=https://cer.org.za/wp-content/uploads/2018/10/IRP-2018-gW-Comment-Final.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018integrated, author = {{Centre for Environmental Rights}}, title = {{Integrated Resource Plan 2018 – groundWork comment}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = oct, url = {https://cer.org.za/wp-content/uploads/2018/10/IRP-2018-gW-Comment-Final.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }