Comments on South Africa 2018 Integrated Resource Plan

Synapse Energy Economics identifies several critical flaws in South Africa's draft 2018 IRP, arguing that it relies on an unreasonably high load forecast, overstates the costs of renewable energy and battery storage, and ignores the economic optimality of retiring aging coal plants. The report highlights a significant disconnect between the IRP's optimized modeling—which suggests no new coal in the 2020s—and the proposed resource plan, which calls for over 6,500 MW of new coal capacity. Additionally, the authors criticize the plan for inadequate carbon budgeting, failure to account for water scarcity, and a lack of transparency in providing modeling data to stakeholders.

• The 2018 IRP uses a load forecasting methodology that is likely to result in the procurement of unnecessary generating capacity, repeating mistakes from the 2010 IRP which over-forecasted 2016 electricity sales by nearly 18 percent.
• The IRP overstates the future costs of renewable energy and battery storage by up to 50 percent, failing to account for rapid global cost declines in solar, wind, and battery technologies.
• There is a major contradiction between the IRP's modeling and its proposed plan: while the optimized scenarios show no new coal capacity needed during the 2020s, the resource plan proposes adding more than 6,500 MW of new coal capacity over the next six years.
• The Department of Energy hard-coded retirement dates for existing coal units and start dates for contracted capacity instead of allowing the PLEXOS model to determine the economically optimal dates.
• The IRP imposes annual build limits on solar (1,000 MW) and wind (1,600 MW) without providing the necessary resource potential studies or market analysis to justify these constraints.
• Fuel price assumptions are poorly supported, with most scenarios assuming gas prices remain flat in real terms without independent market analysis.
• The IRP's approach to greenhouse gas emissions is insufficient; it is unlikely South Africa will meet a 400 million metric ton annual emissions target if the power sector alone emits 275 million metric tons.
• The document notes a failure to consider the power sector's impact on water consumption and quality, which is critical given a forecasted shortage of 234 gigalitres of water in 2025.
• The IRP process lacks transparency, as it did not provide stakeholders with essential data such as peak load forecasts, reserve margins, and load and resource balances.

APA

Allison, A., Wilson, R., Glick, D., & Frost, J. (2018). Comments on South Africa 2018 Integrated Resource Plan. Centre for Environmental Rights. https://cer.org.za/wp-content/uploads/2018/10/Annexure-A-Synapse-Report-on-2018-South-Africa-IRP.pdf?x21779

Chicago

Allison, Avi, Rachel Wilson, Devi Glick, and Jason Frost. Comments on South Africa 2018 Integrated Resource Plan. Centre for Environmental Rights, 2018. https://cer.org.za/wp-content/uploads/2018/10/Annexure-A-Synapse-Report-on-2018-South-Africa-IRP.pdf?x21779.

Wikipedia

{{cite report |last1=Allison |first1=Avi |last2=Wilson |first2=Rachel |last3=Glick |first3=Devi |last4=Frost |first4=Jason |title=Comments on South Africa 2018 Integrated Resource Plan |publisher=Centre for Environmental Rights |date=24 October 2018 |url=https://cer.org.za/wp-content/uploads/2018/10/Annexure-A-Synapse-Report-on-2018-South-Africa-IRP.pdf?x21779 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{allison2018comments, author = {Allison, Avi and Wilson, Rachel and Glick, Devi and Frost, Jason}, title = {{Comments on South Africa 2018 Integrated Resource Plan}}, institution = {Centre for Environmental Rights}, year = {2018}, month = oct, url = {https://cer.org.za/wp-content/uploads/2018/10/Annexure-A-Synapse-Report-on-2018-South-Africa-IRP.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }