Submission on the Gas Master Plan, 2022

Natural Justice (NJ) submitted a critique of the South African Department of Mineral Resources and Energy's (DMRE) Gas Master Plan Base Case report on January 31, 2022. NJ argues that the plan is incompatible with climate commitments, lacks sufficient risk analysis regarding financial and environmental costs, and fails to provide adequate mechanisms for public participation and community compensation.

• The Gas Master Plan is viewed as incompatible with South Africa's climate change commitments and the Climate Change Bill, specifically because it encourages investment in fossil fuels and fails to account for fugitive methane emissions from gas mining.
• Natural Justice identifies significant gaps in the report's risk assessment, noting a lack of scenarios for dealing with volatile international gas prices, the costs of liquefying domestic gas abroad, and the potential for electricity tariffs to increase for strained communities.
• The document highlights a lack of planning for the social and legal impacts of infrastructure development, specifically regarding the expropriation of land for pipelines from Mozambique and other regional fields and the lack of a compensation scale for affected families.
• The DMRE is criticized for failing to provide necessary modeling tools, expansion scenarios, and natural gas demand projections before the public comment deadline, and for publishing the report during the December summer holiday period.
• Natural Justice argues that the current regulatory and consultation processes are inadequate, recommending the adoption of the international principle of Free, Prior and Informed Consent (FPIC) and a review of the National Energy Regulator Act 40 of 2004 (NERA) to ensure fair administrative action.
• The submission warns that expanding the gas sector may create a fossil fuel dependency that hinders the transition to renewable energy, noting that South Africa's strengths lie in wind and solar rather than hydropower due to water scarcity.

APA

Natural Justice (2022). Submission on the Gas Master Plan, 2022. https://naturaljustice.org/wp-content/uploads/2022/02/Natural-Justice-public-comment-on-the-Gas-Master-Plan-Base-Case-report-Jan-2022.pdf

Chicago

Natural Justice. Submission on the Gas Master Plan, 2022. 2022. https://naturaljustice.org/wp-content/uploads/2022/02/Natural-Justice-public-comment-on-the-Gas-Master-Plan-Base-Case-report-Jan-2022.pdf.

Wikipedia

{{cite press release |author=Natural Justice |title=Submission on the Gas Master Plan, 2022 |date=31 January 2022 |url=https://naturaljustice.org/wp-content/uploads/2022/02/Natural-Justice-public-comment-on-the-Gas-Master-Plan-Base-Case-report-Jan-2022.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{naturaljustice2022submission, author = {{Natural Justice}}, title = {{Submission on the Gas Master Plan, 2022}}, publisher = {Natural Justice}, year = {2022}, month = jan, url = {https://naturaljustice.org/wp-content/uploads/2022/02/Natural-Justice-public-comment-on-the-Gas-Master-Plan-Base-Case-report-Jan-2022.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }