Just Energy Transition Investment Plan (JET-IP) and Draft Electricity Recommendations: Comments on behalf of the Life after Coal Campaign and the Fair Finance Coalition Southern Africa

This statement, submitted by the Life after Coal Campaign (LAC) and the Fair Finance Coalition Southern Africa (FFCSA) to the Presidential Climate Commission, provides critical comments on South Africa's Just Energy Transition Investment Plan (JET-IP). The authors argue that the plan is overly skewed toward private sector interests and large-scale infrastructure, specifically green hydrogen, while neglecting social ownership models, local manufacturing, and the urgent needs of coal-affected communities.

• The JET-IP is criticized for prioritizing private sector involvement and large infrastructure over community benefits. Only R1.65 billion is allocated to piloting social ownership models, while R319 billion is estimated for green hydrogen support.
• The authors argue that the JET-IP relies on a dangerous 'trickle-down effect' assumption regarding private sector investment. They advocate for a shift toward small, local investments in sustainable projects, including manufacturing and small-scale agriculture, particularly in coal-affected areas like Mpumalanga.
• There are significant concerns regarding the lack of policy alignment between the JET-IP and other national plans, such as the Integrated Resource Plan (IRP) and the South African Renewable Energy Masterplan (SAREM). The authors warn that incoherent policies could undermine the mobilization of the additional USD 90 billion required between 2023 and 2027.
• The document highlights a critical need to prioritize transmission grid infrastructure over speculative projects. It notes that over 3GW of renewable projects from bid window 6 are stalled due to a lack of connection capacity, requiring an estimated R325 - 372 billion in investment.
• The authors strongly object to the prioritization of the green hydrogen economy, describing it as 'highly speculative'. They argue that green hydrogen is inefficient compared to direct electrification—citing that a hydrogen-powered car uses only 38% of original electricity compared to 80% for an electric vehicle—and that South Africa is at a market disadvantage due to distance from importers like Europe and Japan.
• Serious concerns are raised regarding air quality and health at the Medupi and Kusile power stations. Despite USD 6.43 billion in loans for Flue Gas Desulphurisation (FGD) technology at Medupi, the technology has not been installed, and Eskom has been granted exemptions at Kusile, potentially exposing communities to unabated pollution for another 27 years.
• The decommissioning process is criticized as lacking transparency and community participation, citing the Komati Coal Power station as a negative example where the Environmental and Social Impact Assessment (ESIA) was released only one day before a community meeting.
• The authors call for greater transparency regarding the debt accumulated through the JET-IP, specifically requesting access to loan agreements and repayment schedules between the South African government and international funders.
• The document identifies a critical gap in mine closure planning, noting that the JET-IP lacks a database of expected coal mine closures to 2030 and has struggled to secure costings for the remediation of derelict and ownerless mines.

APA

Centre for Environmental Rights (2023). Just Energy Transition Investment Plan (JET-IP) and Draft Electricity Recommendations: Comments on behalf of the Life after Coal Campaign and the Fair Finance Coalition Southern Africa. https://cer.org.za/wp-content/uploads/2023/05/LAC-and-FFCSA-Comments-on-the-JET-IP-3-April-2023-1.pdf?x21779

Chicago

Centre for Environmental Rights. Just Energy Transition Investment Plan (JET-IP) and Draft Electricity Recommendations: Comments on behalf of the Life after Coal Campaign and the Fair Finance Coalition Southern Africa. 2023. https://cer.org.za/wp-content/uploads/2023/05/LAC-and-FFCSA-Comments-on-the-JET-IP-3-April-2023-1.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=Just Energy Transition Investment Plan (JET-IP) and Draft Electricity Recommendations: Comments on behalf of the Life after Coal Campaign and the Fair Finance Coalition Southern Africa |date=3 April 2023 |url=https://cer.org.za/wp-content/uploads/2023/05/LAC-and-FFCSA-Comments-on-the-JET-IP-3-April-2023-1.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2023just, author = {{Centre for Environmental Rights}}, title = {{Just Energy Transition Investment Plan (JET-IP) and Draft Electricity Recommendations: Comments on behalf of the Life after Coal Campaign and the Fair Finance Coalition Southern Africa}}, publisher = {Centre for Environmental Rights}, year = {2023}, month = apr, url = {https://cer.org.za/wp-content/uploads/2023/05/LAC-and-FFCSA-Comments-on-the-JET-IP-3-April-2023-1.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }