ANEXURE A: Responses to CER questions

This document contains the National Energy Regulator of South Africa's (NERSA) responses to questions from the Centre for Environmental Rights (CER) regarding NERSA's concurrence with section 34 determinations of the Integrated Resource Plan (IRP) 2019. NERSA asserts that its role is to implement national policy developed by the Department of Mineral Resources and Energy (DMRE), rather than to re-evaluate the IRP's modelling, cost assumptions, or technology choices.

• NERSA maintains that its role in concurring with section 34 determinations is the implementation of national policy, not the development or re-opening of the IRP 2019. Consequently, NERSA did not independently verify the cost estimations used in the IRP 2019, as it considers the development of the IRP to be the mandate of the DMRE.
• NERSA argues that gas power generation is a necessary complement to renewable energy to provide the flexibility required to back up intermittent Wind and PV technologies. NERSA suggests that while small-scale LNG (such as FSRUs) is suitable for the first tranche of capacity, a 'tipping point' in volume and demand will eventually necessitate permanent LNG infrastructure.
• NERSA identifies a looming gas supply crisis for industrial users, noting that current supplies may be depleted by 2029 and will begin declining in 2025. Industrial gas users, who contribute over R150 billion annually to the South African economy and employ over 50,000 people, have indicated that a lack of adequate gas supplies has stifled growth.
• Regarding gas pricing, NERSA recommends a pass-through mechanism for imported gas prices to consumers. This recommendation follows an analysis of 44 stakeholder comments, where 18 specifically addressed gas price risk; of these, only 3 proposed the pass-through mechanism and 5 suggested replacing gas capacity with battery storage, the latter of which NERSA rejected to avoid re-opening the IRP.
• NERSA views High Efficiency Low Emission (HELE) coal technologies as a 'reasonable compromise' because they allow for a net reduction in greenhouse gas emissions when combined with the decommissioning of older plants by 2030. NERSA emphasizes the socio-economic importance of coal, particularly in the Mpumalanga province, to ensure a 'just transition' for communities dependent on coal mining and power stations.
• NERSA states it is not mandated to assess climate change or health impacts, as these responsibilities fall under the Department of Environmental Affairs (DEA). NERSA relies on emission constraint scenarios provided by the DEA for the IRP 2019 models and requires potential licensees to conduct site-specific Environmental Impact Assessments (EIAs) during the licensing phase.

APA

Centre for Environmental Rights (n.d.). ANEXURE A: Responses to CER questions. https://cer.org.za/wp-content/uploads/2021/02/NERSA-reasons.pdf?x21779

Chicago

Centre for Environmental Rights. ANEXURE A: Responses to CER questions. n.d. https://cer.org.za/wp-content/uploads/2021/02/NERSA-reasons.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=ANEXURE A: Responses to CER questions |url=https://cer.org.za/wp-content/uploads/2021/02/NERSA-reasons.pdf?x21779 |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrightsndanexure, author = {{Centre for Environmental Rights}}, title = {{ANEXURE A: Responses to CER questions}}, publisher = {Centre for Environmental Rights}, url = {https://cer.org.za/wp-content/uploads/2021/02/NERSA-reasons.pdf?x21779}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }