Joint Submission on the draft South African Renewable Energy Masterplan

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The submission argues that the draft SAREM over-relies on private investment and fails to sufficiently address the impact of the global supply chain crisis on renewable energy costs. It advocates for a state-led industrial policy, including the use of import tariffs and the central role of Eskom in renewable generation, to avoid 'boom-bust' cycles and ensure a just transition for workers. Key recommendations include establishing a 'decent work' framework, implementing aggressive local content requirements (suggesting 50% for future RFPs), and creating a technology transfer system to support local manufacturing.

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  • The draft SAREM fails to adequately analyze 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, leading to project costs up to 25% above pre-pandemic levels.
  • The authors argue that the SAREM's focus on a private-investment-led transition ignores the potential of public ownership and coordination, suggesting that Eskom should be the primary vehicle for implementing renewable energy initiatives to ensure better worker protections and lower capital costs.
  • There is a critical lack of specific, numerical local content targets in the draft SAREM despite three years of development; the submission recommends a 50% local content requirement for the next wave of public procurement RFPs starting with Bid Window 6.
  • The submission criticizes the SAREM for failing to define or provide a framework for 'decent work,' noting that many current opportunities in the REI4P are temporary and casualised.
  • The document highlights the failure of the International Trade Administration Commission of South Africa (ITAC) to process import duty applications, citing ARTsolar's 10% import duty application which has been pending for over 50 months.
  • The authors point to the 'boom and bust' cycle of private-led renewables in Vietnam as a warning, arguing that state-owned utilities like Electricity Vietnam (EVN) provide better control over prices and industrial development than a purely liberalised market.

Cite the original document

APA
Kamanzi, B. (2023). Joint Submission on the draft South African Renewable Energy Masterplan. Institute for Economic Justice. https://iej.org.za/wp-content/uploads/2023/10/IEJ-COSATU-SAREM-public-comment-submission-18-August-2023.pdf
Chicago
Kamanzi, Brian. Joint Submission on the draft South African Renewable Energy Masterplan. Institute for Economic Justice, 2023. https://iej.org.za/wp-content/uploads/2023/10/IEJ-COSATU-SAREM-public-comment-submission-18-August-2023.pdf.
Wikipedia
{{cite press release |last1=Kamanzi |first1=Brian |title=Joint Submission on the draft South African Renewable Energy Masterplan |publisher=Institute for Economic Justice |date=18 August 2023 |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
@misc{kamanzi2023joint, author = {Kamanzi, Brian}, title = {{Joint Submission on the draft South African Renewable Energy Masterplan}}, publisher = {Institute for Economic Justice}, year = {2023}, month = aug, 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} }

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