COMMENTS ON THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY, 2018

The Centre for Environmental Rights (CER) argues that the draft IRP 2018 is unlawful and irrational because it includes 6,732MW of new coal capacity despite its own findings that a least-cost plan would exclude coal. The CER highlights severe failures in the draft, including inflated electricity demand forecasts, outdated and high cost assumptions for renewables and battery storage, and a total lack of consideration for water and climate change externalities. The document specifically objects to the Thabametsi and Khanyisa coal projects, citing their high emissions and risks to water resources in the Waterberg and Highveld regions. Furthermore, the CER criticizes the Department of Energy for failing to conduct meaningful public consultations with impacted communities and for withholding the Plexos modelling data necessary for transparent stakeholder review.

• The draft IRP 2018 includes 6,732MW of new coal capacity between 2019 and 2024, consisting of 5,732MW of committed capacity from Medupi and Kusile and 1,000MW of new additional capacity, which the CER argues is unnecessary and contradicts the plan's 'least-cost' objective.
• The 1,000MW of new coal capacity, likely referring to the Thabametsi and Khanyisa projects, was 'forced in' to the plan for job creation reasons, despite the draft IRP's own admission that a scenario without renewable build limits provides the least-cost option by 2030.
• The draft IRP 2018 fails to consider critical externalities, specifically ignoring the costs of water usage, ecosystem degradation, and climate change, only accounting for air pollution externalities.
• The draft IRP 2018 uses outdated and overestimated costs for renewable energy and battery storage, assuming solar and wind costs will decline by only 20% by 2050, whereas experts project declines of 71% and 58% respectively.
• The draft IRP 2018 imposes arbitrary annual build limits on renewable energy (1,000MW for PV and 1,600MW for wind) up to 2030, which the CER argues serves to protect costly coal infrastructure.
• The plan proposes adding 8,100MW of new gas capacity by 2029, but fails to specify the source of the gas or the associated environmental impacts of potential fracking or offshore exploration.
• The Department of Energy failed to hold public engagement meetings on the draft IRP 2018, particularly in the most impacted regions such as the Mpumalanga Highveld, Vaal Triangle, and Waterberg.
• The CER asserts that the Department of Energy has refused to provide the Plexos modelling input and output data, preventing stakeholders from properly interrogating the plan's conclusions.
• The draft IRP 2018's decommissioning schedule for coal plants is based on an arbitrary 50-year lifespan and does not account for the legal requirement to shut down plants that cannot meet minimum emission standards by 2030.

APA

Centre for Environmental Rights (2018). COMMENTS ON THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY, 2018. https://cer.org.za/wp-content/uploads/2018/10/CER-IRP-2018-Comment-DoE_26-10-18.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY, 2018. 2018. https://cer.org.za/wp-content/uploads/2018/10/CER-IRP-2018-Comment-DoE_26-10-18.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY, 2018 |date=26 October 2018 |url=https://cer.org.za/wp-content/uploads/2018/10/CER-IRP-2018-Comment-DoE_26-10-18.pdf?x21779 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON THE DRAFT INTEGRATED RESOURCE PLAN FOR ELECTRICITY, 2018}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = oct, url = {https://cer.org.za/wp-content/uploads/2018/10/CER-IRP-2018-Comment-DoE_26-10-18.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }