LIFE AFTER COAL CAMPAIGN COMMENTS ON THE DRAFT REGULATIONS AMENDING THE ELECTRICITY REGULATIONS ON NEW GENERATION CAPACITY, 2011

The Centre for Environmental Rights (CER), on behalf of the Life After Coal Campaign, submitted comments on the Draft Regulations Amending the Electricity Regulations on New Generation Capacity, 2011. The CER argues that the Draft Regulations are redundant and legally inconsistent because the Electricity Regulation Act (ERA) does not require prior Ministerial approval for municipalities to establish their own electricity capacity. The submission emphasizes the urgent need for a transition to clean energy to mitigate severe health, environmental, and climate harms caused by South Africa's coal-dependent power sector.

• The Draft Regulations are considered redundant and legally inconsistent because neither the Electricity Regulation Act (ERA) nor the Regulations for New Generation Capacity, 2011 require prior approval from the Minister for municipalities to establish electricity capacity.
• South Africa's reliance on coal for 86% of its electricity has caused significant harm, including an estimated 2,000 annual deaths from Eskom's coal-fired power station emissions, costing the government USD$ 2,372.78 annually.
• The energy sector is the primary driver of South Africa's greenhouse gas emissions, accounting for 77% of the total, with electricity generation contributing 40-45%.
• The Integrated Resource Plan for Electricity (IRP 2019) is criticized for placing unjustified constraints on renewable energy (solar PV and wind) while including 1,500 MW of new coal and 3,000 MW of new gas capacity, which the CER claims is not a least-cost plan.
• South Africa is ranked as one of the worst-prepared countries globally for the energy transition; the 2019 World Economic Forum Energy Transition index ranked it second worst, and the 2020 index ranked it 10th worst.
• The CER recommends that the Draft Regulations be amended to include mandatory considerations for human health, the environment, and climate in feasibility studies, as well as established timeframes for decisions (e.g., 60 days) and requirements for transparency and public consultation.
• The requirement for municipalities to demonstrate "sound financial standing" may be unduly restrictive and could exclude under-resourced municipalities from developing clean energy, necessitating national government financial support mechanisms.

APA

Centre for Environmental Rights (2020). LIFE AFTER COAL CAMPAIGN COMMENTS ON THE DRAFT REGULATIONS AMENDING THE ELECTRICITY REGULATIONS ON NEW GENERATION CAPACITY, 2011. https://cer.org.za/wp-content/uploads/2020/06/Life-After-Coal-Campaigns-comments-to-the-Department-of-Mineral-Resources-and-Energy.pdf?x21779

Chicago

Centre for Environmental Rights. LIFE AFTER COAL CAMPAIGN COMMENTS ON THE DRAFT REGULATIONS AMENDING THE ELECTRICITY REGULATIONS ON NEW GENERATION CAPACITY, 2011. 2020. https://cer.org.za/wp-content/uploads/2020/06/Life-After-Coal-Campaigns-comments-to-the-Department-of-Mineral-Resources-and-Energy.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=LIFE AFTER COAL CAMPAIGN COMMENTS ON THE DRAFT REGULATIONS AMENDING THE ELECTRICITY REGULATIONS ON NEW GENERATION CAPACITY, 2011 |date=4 June 2020 |url=https://cer.org.za/wp-content/uploads/2020/06/Life-After-Coal-Campaigns-comments-to-the-Department-of-Mineral-Resources-and-Energy.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2020life, author = {{Centre for Environmental Rights}}, title = {{LIFE AFTER COAL CAMPAIGN COMMENTS ON THE DRAFT REGULATIONS AMENDING THE ELECTRICITY REGULATIONS ON NEW GENERATION CAPACITY, 2011}}, publisher = {Centre for Environmental Rights}, year = {2020}, month = jun, url = {https://cer.org.za/wp-content/uploads/2020/06/Life-After-Coal-Campaigns-comments-to-the-Department-of-Mineral-Resources-and-Energy.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }