WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN

The Centre for Environmental Rights (CER) argues that South Africa's draft Integrated Energy Plan (IEP) and Integrated Resource Plan (IRP) Update are inconsistent with the Constitution, the National Environmental Management Act (NEMA), and the National Energy Act (NEA). The CER contends that the plans unjustifiably constrain renewable energy while promoting new coal-fired power stations, which they claim cause severe health impacts and contribute to climate change. They highlight that coal-fired power is no longer the least-cost option and risks creating stranded assets. The document recommends removing build limits on wind and solar, excluding new coal and nuclear power, and conducting a comprehensive assessment of external social and environmental costs.

• The IRP Base Case imposes arbitrary annual build constraints on renewable energy, limiting new solar PV to 1000 MW and wind to 1600 MW per year until 2050, without technical justification.
• Coal-fired power stations in South Africa cause significant public health crises, with one 2014 report estimating 2,200 premature deaths per year due to fine particulate matter (PM2.5) exposure, costing society 30 billion rand annually.
• The CER argues that the IRP Base Case and draft IEP violate Section 24 of the Constitution by planning for coal-fired power to remain a significant part of the energy mix through 2050, despite its harmful impacts on health and climate.
• The document asserts that the Department of Energy used outdated and inflated tariffs for renewables in the IRP Base Case, citing 2016 solar PV and wind tariffs of R1.13 and R0.98 per kWh respectively, while actual tariffs were R0.62 per kWh.
• New coal-fired power plants, such as those under the Coal Baseload IPP Procurement Programme (CBIPPPP) including Thabametsi and Khanyisa, are identified as high-risk investments likely to become stranded assets.
• The CER claims the public participation process was flawed because consultation meetings were held in major cities rather than in the most impacted areas like the Highveld, Vaal Triangle, South Durban basin, and Waterberg.
• South Africa's commitments under the Paris Agreement are deemed insufficient by the CER, noting that current trajectories could lead to a temperature increase exceeding 3–4°C globally, which would be catastrophic for the country.
• The draft IEP is criticized for failing to accurately quantify external costs, specifically by assigning a CO2 emission cost of R270 per metric ton, which is significantly lower than the US federal government's social cost of carbon.
• A Stanford University study cited in the document suggests South Africa could meet 100% of its electricity needs from wind, water, and sunlight, potentially saving US$71.2 billion in annual health costs.

APA

Centre for Environmental Rights (2017). WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN. https://cer.org.za/wp-content/uploads/2016/08/CER-IRP-Base-Case-IEP-Comments-31-3-2017.pdf?x21779

Chicago

Centre for Environmental Rights. WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN. 2017. https://cer.org.za/wp-content/uploads/2016/08/CER-IRP-Base-Case-IEP-Comments-31-3-2017.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN |date=31 March 2017 |url=https://cer.org.za/wp-content/uploads/2016/08/CER-IRP-Base-Case-IEP-Comments-31-3-2017.pdf?x21779 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2017written, author = {{Centre for Environmental Rights}}, title = {{WRITTEN COMMENTS ON THE INTEGRATED RESOURCE PLAN UPDATE: ASSUMPTIONS, BASE CASE RESULTS AND OBSERVATIONS, REVISION 1 AND ON THE DRAFT INTEGRATED ENERGY PLAN}}, publisher = {Centre for Environmental Rights}, year = {2017}, month = mar, url = {https://cer.org.za/wp-content/uploads/2016/08/CER-IRP-Base-Case-IEP-Comments-31-3-2017.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }