Submission on the Gas Master Plan, 2022

Natural Justice argues that South Africa's Gas Master Plan is incompatible with the country's climate commitments and the Climate Change Bill. The submission highlights risks including fugitive methane emissions, fossil fuel dependency, and the potential for inadequate compensation for land expropriation. It calls for a transition toward renewable energy, the adoption of the 'free prior and informed consent' (FPIC) principle for affected communities, and a more transparent public participation process.

• The Gas Master Plan is viewed as incompatible with South Africa's international climate obligations under the UNFCCC and Paris Agreement, as it contradicts the Climate Change Bill's call for reduced fossil fuel investment.
• Natural Justice asserts that natural gas is not a clean energy source due to fugitive methane emissions resulting from mining activities, which increase greenhouse gas emissions.
• The document warns that developing a gas sector will create fossil fuel dependency, hindering the transition to renewable energy sources like solar and wind, which are more viable in South Africa than hydropower due to water scarcity.
• There are significant concerns regarding the lack of a compensation framework for communities whose land or property may be expropriated to build gas pipelines from regional fields in Mozambique and other countries.
• The submission identifies financial and economic risks, including the high cost of building infrastructure from scratch, the volatility of US dollar-denominated gas prices, and the potential for increased electricity tariffs.
• The DMRE is criticized for a flawed public participation process, specifically for releasing the 100-page report in December 2021 during summer holidays and failing to provide necessary modeling tools or demand projections before the comment deadline.
• Natural Justice recommends that the government adopt the international principle of free prior and informed consent (FPIC) and ensure that the National Environmental Management Act (NEMA) governs environmental rehabilitation rather than the Energy Regulator.

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} }