COMMENTS ON NATIONAL PLANNING COMMISSION ECONOMY SERIES: ENERGY DISCUSSION PAPER

The Centre for Environmental Rights (CER) submits that South Africa must urgently transition from coal to renewable energy due to the declining competitiveness of coal, severe health and environmental impacts, and extreme vulnerability to climate change. The CER argues against new coal and nuclear infrastructure, recommends the decommissioning of non-compliant coal plants, and calls for a transformation of Eskom into an organ of state promoting clean energy. It further emphasizes the need for meaningful public consultation in energy planning and warns against the continued operation of high-emission facilities like Sasol's Secunda complex.

• The CER argues that current energy planning lacks adequate public consultation, which is a legal requirement. They propose a minimum 30-day comment period for draft documents and the implementation of the right to free, prior, and informed consent for affected communities.
• Renewable energy is now significantly cheaper than new coal. The CER cites that solar PV and wind costs in recent IPP procurement rounds were 0.62 rand per kWh, compared to the 1-2 rand per kWh estimated in IRP 2010 and the R1.03 per kWh projected for the Thabametsi and Khanyisa plants.
• Coal-fired power generation causes severe health and environmental damage. A 2017 study linked PM2.5 emissions from Eskom's coal plants to 2,239 attributable deaths annually and costs exceeding USD 2.3 billion. Additionally, acid mine drainage from approximately 6,000 abandoned mines as of 2014 contaminates water resources.
• The CER recommends that South Africa abandon further coal and nuclear infrastructure. They specifically suggest reconsidering the completion of Kusile units 5 and 6, stopping the Thabametsi and Khanyisa projects, and prioritizing the decommissioning of the Grootvlei, Komati, and Hendrina plants.
• The document argues that nuclear energy is an inflexible and costly source that is becoming obsolete globally and should be removed from the NPC's recommendations.
• Sasol's Secunda complex is identified as one of the world's largest single sources of CO2. In 2017, Sasol's total GHG emissions were 67,632 kilotons, which is more than the total annual emissions of countries such as Portugal, New Zealand, Ireland, or Switzerland.
• The CER suggests that carbon pricing will be ineffective unless consumers have alternatives to Eskom's monopoly, as the tax will otherwise simply increase costs for the consumer without incentivizing a shift to renewables.

APA

Centre for Environmental Rights (2018). COMMENTS ON NATIONAL PLANNING COMMISSION ECONOMY SERIES: ENERGY DISCUSSION PAPER. https://cer.org.za/wp-content/uploads/2018/05/CER-NPC-ENERGY-PAPER-SUBMISSIONS-26-4-18.pdf?x21779

Chicago

Centre for Environmental Rights. COMMENTS ON NATIONAL PLANNING COMMISSION ECONOMY SERIES: ENERGY DISCUSSION PAPER. 2018. https://cer.org.za/wp-content/uploads/2018/05/CER-NPC-ENERGY-PAPER-SUBMISSIONS-26-4-18.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=COMMENTS ON NATIONAL PLANNING COMMISSION ECONOMY SERIES: ENERGY DISCUSSION PAPER |date=26 April 2018 |url=https://cer.org.za/wp-content/uploads/2018/05/CER-NPC-ENERGY-PAPER-SUBMISSIONS-26-4-18.pdf?x21779 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2018comments, author = {{Centre for Environmental Rights}}, title = {{COMMENTS ON NATIONAL PLANNING COMMISSION ECONOMY SERIES: ENERGY DISCUSSION PAPER}}, publisher = {Centre for Environmental Rights}, year = {2018}, month = apr, url = {https://cer.org.za/wp-content/uploads/2018/05/CER-NPC-ENERGY-PAPER-SUBMISSIONS-26-4-18.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }