COMMENTS ON THE GAS MASTER PLAN BASECASE REPORT

The Centre for Environmental Rights, on behalf of the Life After Coal Campaign, submits a formal objection to the Department of Mineral Resources and Energy's draft Gas Master Plan Basecase Report. The submission argues that the plan is 'reckless and unnecessary', contradicting South Africa's constitutional obligations to protect citizens from climate change and ignoring energy modelling that suggests gas-to-power is not required for energy security.

• The Gas Master Plan is viewed as a threat to the constitutional rights of South Africans because it facilitates new fossil fuel development despite the country's extreme vulnerability to climate change, where regional temperatures are increasing at twice the global average.
• The claim that natural gas is a 'clean' bridging fuel is rejected as a fallacy. The document asserts that gas is as emission-intensive as coal, or more so, due to potent methane leaks during extraction, processing, and transport, which have a climate impact 80 times stronger than CO2 over a 20-year period.
• Energy modelling from Meridian Economics and the CSIR Energy Centre indicates that gas-to-power is only justified for balancing the system during peaking demand and that no new investments in gas power are currently needed for energy security.
• The report criticizes the Department's PESTEL analysis for failing to account for 'transition risks', such as the possibility of gas projects becoming stranded assets as they are outcompeted by cheaper renewable alternatives or rendered illegal by tightening climate regulations.
• The submission highlights a contradiction between the Gas Master Plan and other national policies, such as the draft National Infrastructure Plan 2050, which advocates for reduced reliance on coal and increased reliance on solar and wind as the least-cost technologies.
• The document argues that the Report improperly characterizes the National Environmental Management Act (NEMA) as a 'barrier' to gas market development, suggesting this reflects an attempt to weaken environmental regulations to serve industry interests.

APA

Centre for Environmental Rights (2022). COMMENTS ON THE GAS MASTER PLAN BASECASE REPORT. https://cer.org.za/wp-content/uploads/2022/02/LAC-Comments-on-Gas-Master-Plan-Basecase-Report-2022_vf.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON THE GAS MASTER PLAN BASECASE REPORT. 2022. https://cer.org.za/wp-content/uploads/2022/02/LAC-Comments-on-Gas-Master-Plan-Basecase-Report-2022_vf.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON THE GAS MASTER PLAN BASECASE REPORT |date=31 January 2022 |url=https://cer.org.za/wp-content/uploads/2022/02/LAC-Comments-on-Gas-Master-Plan-Basecase-Report-2022_vf.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2022comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON THE GAS MASTER PLAN BASECASE REPORT}}, publisher = {Centre for Environmental Rights}, year = {2022}, month = jan, url = {https://cer.org.za/wp-content/uploads/2022/02/LAC-Comments-on-Gas-Master-Plan-Basecase-Report-2022_vf.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }