COMMENTS ON CONSULTATION PAPER 1: CONCURRENCE WITH THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY FROM A RANGE OF ENERGY TECHNOLOGIES 2020

The Centre for Environmental Rights (CER), writing on behalf of the Life After Coal Campaign, submitted comments to the National Energy Regulator of South Africa (NERSA) regarding a draft ministerial determination to procure 2,000 MW of new generation capacity. The CER argues that this procurement must prioritize clean, affordable, and renewable energy sources over fossil fuels to align with constitutional obligations and public interest, while criticizing the lack of transparency regarding Request for Information (RFI) responses and the inadequacy of the public consultation process.

• The draft determination proposes the procurement of 2,000 megawatts (MW) of new generation capacity from a range of energy source technologies for the years 2019 to 2022, based on the 'Others' category in Table 5 of the Integrated Resource Plan (IRP) 2019.
• The CER contends that fossil fuel-based electricity, specifically coal and gas, is not in the public interest due to severe climate, health, and economic harms. They cite that coal-fired power stations in South Africa are estimated to cause approximately 2,000 deaths annually and that new-build solar is significantly cheaper (less than R0.60c/kWh) than baseload coal (approximately R1.08/kWh).
• The CER argues that a transition to renewable energy would provide greater socio-economic benefits and job creation than coal. They reference modelling indicating that a decarbonised scenario could create between 112,000 and 144,000 jobs by 2030, and a DMRE study finding 30% more permanent direct jobs per unit of energy are created with a renewable energy mix than with coal.
• The CER criticizes the lack of transparency in the procurement process, noting that responses to the Department of Mineral Resources and Energy's (DMRE) Request for Information (RFI) have not been made public, which hinders the ability of stakeholders to participate effectively in the consultation.
• The document challenges the legal validity of the IRP 2019, citing concerns that it forces 1,500 MW of new coal capacity into the plan, imposes arbitrary annual constraints on solar PV and wind, and recommends continuing the operation of coal plants that do not comply with minimum emission standards (MES).
• The CER asserts that NERSA's concurrence is a 'vital link' for a section 34 determination to have legal effect and argues that NERSA has failed to adequately communicate the consultation process to affected communities, particularly those in the Mpumalanga Highveld, the Vaal Triangle, and the Waterberg.

APA

Centre for Environmental Rights (2020). COMMENTS ON CONSULTATION PAPER 1: CONCURRENCE WITH THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY FROM A RANGE OF ENERGY TECHNOLOGIES 2020. https://cer.org.za/wp-content/uploads/2020/04/NERSA-DMRE-Determination1-LAC-Comment-14-4-20.docx-002.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON CONSULTATION PAPER 1: CONCURRENCE WITH THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY FROM A RANGE OF ENERGY TECHNOLOGIES 2020. 2020. https://cer.org.za/wp-content/uploads/2020/04/NERSA-DMRE-Determination1-LAC-Comment-14-4-20.docx-002.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON CONSULTATION PAPER 1: CONCURRENCE WITH THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY FROM A RANGE OF ENERGY TECHNOLOGIES 2020 |date=14 April 2020 |url=https://cer.org.za/wp-content/uploads/2020/04/NERSA-DMRE-Determination1-LAC-Comment-14-4-20.docx-002.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2020comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON CONSULTATION PAPER 1: CONCURRENCE WITH THE MINISTERIAL DETERMINATION ON THE PROCUREMENT OF NEW GENERATION CAPACITY FROM A RANGE OF ENERGY TECHNOLOGIES 2020}}, publisher = {Centre for Environmental Rights}, year = {2020}, month = apr, url = {https://cer.org.za/wp-content/uploads/2020/04/NERSA-DMRE-Determination1-LAC-Comment-14-4-20.docx-002.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }