IEJ-COSATU SAREM public comment submission (5).docx

This document is a joint public comment submission by the Congress of South African Trade Unions (COSATU) and the Institute for Economic Justice (IEJ) regarding the draft South African Renewable Energy Masterplan (SAREM). The submission argues that the current draft over-relies on private investment and market liberalisation, neglecting the role of state-led industrial policy, public ownership, and the protection of workers' rights during the energy transition.

• The authors argue that the SAREM draft fails to sufficiently account for the global supply chain crisis, which has seen costs for key inputs like steel rise by 40%, aluminium by 100%, and copper by 90% between January 2021 and April 2022. This crisis has led to project costs increasing by up to 25% above pre-pandemic levels, yet the SAREM incorrectly attributes project delays to local content requirements without substantiating analysis.
• COSATU and the IEJ advocate for a state-led approach to the energy transition, proposing that Eskom should be the primary vehicle for implementing renewable energy initiatives. They suggest Eskom could operate pilot projects with high local content at decommissioned sites like Komati and Grootvlei to showcase local manufacturing capabilities.
• The submission criticizes the current use of Broad-Based Black Economic Empowerment (B-BBEE) to meet inclusive ownership goals, noting that in Bid window 5 of the REI4P, three private developers (Mainstream Renewable Power, Scatec, and Red Rocket) accounted for 21 of 25 projects while using the same B-BBEE partner, H1 Holdings.
• The authors highlight a lack of clear, numerical local content targets in the SAREM draft after three years of development. They recommend that local content requirements be set at 50% for the next wave of public procurement RFPs, starting with Bid Window 6, and call for the use of import tariffs to protect infant industries, citing a pending 10% import duty application by ARTsolar that has been with ITAC for over 50 months.
• The submission asserts that the SAREM does not adequately define or integrate the concept of 'decent work,' focusing too much on new skills while ignoring the casualised nature of existing jobs in the REI4P. They propose tying public incentives to strict worker-centred benefits, similar to the US Inflation Reduction Act's requirements for prevailing wages and apprenticeship ratios.
• The document notes that the Just Energy Transition Investment Plan (JET-IP) requested R1.48 trillion, with 70% for electricity, 21.5% for green hydrogen, and 8.5% for new energy vehicles. However, the authors argue that the associated JETP finance package allocates disproportionately low funding to skills development (0.15%) and social investment and inclusion (0.2%).

APA

Institute for Economic Justice (n.d.). IEJ-COSATU SAREM public comment submission (5).docx. https://iej.org.za/wp-content/uploads/2023/10/IEJ-COSATU-SAREM-public-comment-submission-18-August-2023.pdf

Chicago

Institute for Economic Justice. IEJ-COSATU SAREM public comment submission (5).docx. n.d. https://iej.org.za/wp-content/uploads/2023/10/IEJ-COSATU-SAREM-public-comment-submission-18-August-2023.pdf.

Wikipedia

{{cite report |author=Institute for Economic Justice |title=IEJ-COSATU SAREM public comment submission (5).docx |url=https://iej.org.za/wp-content/uploads/2023/10/IEJ-COSATU-SAREM-public-comment-submission-18-August-2023.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{instituteforeconomicjusticendiejcosatu, author = {{Institute for Economic Justice}}, title = {{IEJ-COSATU SAREM public comment submission (5).docx}}, institution = {Institute for Economic Justice}, url = {https://iej.org.za/wp-content/uploads/2023/10/IEJ-COSATU-SAREM-public-comment-submission-18-August-2023.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }