RELEVANT INFORMATION IN RELATION TO THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY UPDATE & THE DRAFT INTEGRATED ENERGY PLAN

The Centre for Environmental Rights (CER), representing the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign, submitted a formal statement to the Portfolio Committee on Energy on 29 November 2017. The document outlines critical concerns regarding the lack of transparency, inadequate public consultation, and the omission of key economic and environmental data in the development of South Africa's draft Integrated Resource Plan (IRP) for Electricity Update and the draft Integrated Energy Plan (IEP).

• The Department of Energy (DoE) has failed to provide critical data and technical records requested by the CER and other stakeholders, including detailed input assumptions for IRP scenarios, decommissioning plans for Eskom's coal-fired power stations, and reports on the tariff implications of different IRP base cases. Despite requests made under the Promotion of Access to Information Act (PAIA), the Department has not provided the requested Excel sheets for costs, demand forecasts, or model constraints.
• The public consultation process for the draft IRP Update and IEP is described as inadequate and unfair. Specific failures include providing only a week for the public to review a 300-page document before workshops, holding meetings only in major cities while excluding heavily impacted areas like the Highveld, Vaal Triangle, South Durban basin, and Waterberg, and failing to provide clarity on whether the public could comment on subsequent versions of the plans.
• The CER argues that the Energy Indaba scheduled for December 2017 is an insufficient substitute for a proper public participation process due to its short notice, single venue in Gauteng, lack of a provided agenda, and a registration process that inexplicably omits coal as a sector of interest despite its significant impacts.
• The CER identifies several critical omissions in the DoE and Council for Scientific and Industrial Research (CSIR) modelling, specifically the failure to account for the health and water costs of coal investments, the nitrous oxide (N2O) emissions from circulating fluidised bed combustion (CFB) technology used by proposed IPPs like Thabametsi and Khanyisa, and the exclusion of nuclear decommissioning, fuel storage, and insurance costs.
• A study by Meridian Economics suggests that Eskom could save up to R17 billion by accelerating the decommissioning of the Hendrina, Grootvlei, and Komati coal-fired power stations and curtailing the completion of Kusile units 5 and 6, without compromising the security of supply.
• Research from the CSIR Energy Centre and the Frankfurt Institute for Advanced Studies indicates that new coal and nuclear plants are no longer cost-competitive in South Africa. The Frankfurt Institute study found that a system based on wind and solar PV could be 10%-30% cheaper than one based on new coal and nuclear, even when including grid and transmission investments.

APA

Centre for Environmental Rights (2017). RELEVANT INFORMATION IN RELATION TO THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY UPDATE & THE DRAFT INTEGRATED ENERGY PLAN. https://cer.org.za/wp-content/uploads/2017/11/LAC-letter-to-PCE_29-Nov-2017.pdf?x21779

Chicago

Centre for Environmental Rights. RELEVANT INFORMATION IN RELATION TO THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY UPDATE & THE DRAFT INTEGRATED ENERGY PLAN. 2017. https://cer.org.za/wp-content/uploads/2017/11/LAC-letter-to-PCE_29-Nov-2017.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=RELEVANT INFORMATION IN RELATION TO THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY UPDATE & THE DRAFT INTEGRATED ENERGY PLAN |date=29 November 2017 |url=https://cer.org.za/wp-content/uploads/2017/11/LAC-letter-to-PCE_29-Nov-2017.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2017relevant, author = {{Centre for Environmental Rights}}, title = {{RELEVANT INFORMATION IN RELATION TO THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY UPDATE \& THE DRAFT INTEGRATED ENERGY PLAN}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = nov, url = {https://cer.org.za/wp-content/uploads/2017/11/LAC-letter-to-PCE_29-Nov-2017.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }