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The submission argues that the Electricity Regulation Amendment Bill [B23 – 2023] lacks sufficient provisions for a just transition, energy decentralisation, and transparency. It specifically criticises the potential for grid privatisation through wheeling agreements, the lack of regulatory support for energy storage and small-scale embedded generation (SSEG), and the expansion of Ministerial discretion over the Integrated Resource Plan (IRP) and procurement processes. The authors also object to proposed confidentiality clauses that could limit public access to licence applications and call for stronger public participation requirements aligned with PAJA and PAIA.

The 2023 Energy Services Market Intelligence Report by GreenCape identifies significant growth in South Africa's energy services sector, driven by national energy insecurity (load shedding) and rising electricity costs. Rooftop solar PV is the most immediate opportunity, with an estimated annual market value of R7.5 billion and a projected total capacity of 10 GWp by 2035. Behind-the-meter storage, particularly lithium-ion batteries, is growing as a backup solution, with a current market size of R4 billion expected to reach R32.5 billion by 2035. The energy efficiency sector remains sluggish despite a potential annual saving of 120 TWh, though smart meter upgrades present a market opportunity of R40–R60 billion. Key barriers include port inefficiencies causing long equipment lead times and a shortage of skilled technical labor. The report also details the regulatory landscape, including the removal of the 100 MW generation license threshold and the implementation of mandatory energy performance certificates for large buildings.

The report identifies significant growth potential in South Africa's large-scale renewable energy sector, driven by the Integrated Resource Plan (IRP) 2019 and the removal of licensing thresholds for private generation. While public procurement via the REIPPPP has historically led the market, grid constraints in the Northern and Western Cape now limit project viability. Private procurement is surging, particularly among energy-intensive mining companies. The report also highlights emerging opportunities in battery energy storage systems (BESS), green hydrogen, and local manufacturing of components, while noting the systemic risk posed by Eskom's debt and the ongoing unbundling of the national utility.

The document details technical improvements to the BWDSS, including the development of a PostgreSQL timeseries provider, the creation of maintenance scripts to optimize database size, and a guide for operationalizing FEFLOW groundwater models. It identifies performance bottlenecks in specific jobs and recommends the implementation of regular maintenance tasks and improved error handling in Python scripts to enhance system resilience.

The report describes the creation of a groundwater monitoring network in Brackenfell, Western Cape, commissioned by WWF South Africa and implemented by GEOSS South Africa. Following a significant increase in borehole drilling during the 2015-2019 drought, the project conducted desktop assessments and a hydrocensus of 111 properties to identify groundwater use patterns. The study found that most boreholes were drilled between 2016 and 2020, targeting the Tygerberg Formation. Four Solinst Leveloggers were deployed in private and public boreholes to track water levels, with data integrated into the Table Mountain Water Source Area Groundwater Dashboard. Key stakeholder concerns identified include high iron content in the water and risks of over-abstraction.

The report describes the creation of a groundwater monitoring network in Constantia and Bergvliet, Western Cape, commissioned by WWF South Africa. Following a significant increase in borehole drilling during the 2015-2019 drought, GEOSS South Africa conducted a desktop study and hydrocensus of 309 properties. The project resulted in the installation of five Solinst Leveloggers in private boreholes, with data fed into a public Groundwater Dashboard for the Table Mountain Water Source Area. Findings indicate that most boreholes target the Springfontyn and Peninsula Formations, with water levels ranging from 7 to 16 mbgl and quality classified as "good" to "marginal".

The report details the creation of a groundwater monitoring network in Noordhoek, Western Cape, commissioned by WWF South Africa and implemented by GEOSS South Africa. Following a drought from 2015 to 2019, the area saw a surge in private boreholes and wellpoints. The project involved a desktop study, a hydrocensus of 158 properties, and the deployment of four Solinst dataloggers in private boreholes. Key findings highlight stakeholder concerns regarding E-coli contamination from soakaway systems and the potential for seawater intrusion. Data from the network is integrated into the Table Mountain Water Source Area Groundwater Dashboard to provide public visibility of water level trends and seasonal fluctuations.

The report details the creation of a citizen-science groundwater monitoring network in Scarborough and Kommetjie, Western Cape, commissioned by WWF South Africa. Following a significant increase in borehole drilling during the 2015-2019 drought, the study employed desktop searches and a hydrocensus of 105 properties to identify groundwater users and monitoring sites. Four Solinst Leveloggers were deployed to track water levels and temperature, with data integrated into the Table Mountain Water Source Area Groundwater Dashboard. Findings indicate that borehole depths range from 1 to 60 metres, with water levels between 2.5 and 4 mbgl and electrical conductivity values between 54.8 and 150.7 mS/m. The report recommends continued stakeholder engagement and quarterly data downloads to ensure sustainable groundwater management.

The report identifies significant gaps in the governance of the Table Mountain Strategic Water Source Area (TMSWSA), noting that groundwater management is currently a national mandate that lacks local enforcement and clear delegation to Catchment Management Agencies (CMAs). It highlights the vulnerability of the Table Mountain Group and Cape Flats aquifers to over-extraction and pollution, exacerbated by unregulated borehole drilling during Cape Town's 2016-2018 drought. To address these failures, the document proposes a flexible, multi-stakeholder Partnership Framework based on adaptive management, recommending WWF South Africa as the host institution and secretariat to coordinate between the City of Cape Town, the Department of Water and Sanitation, and local communities.

The SAVi assessment of forest restoration in the Brantas River basin demonstrates that nature-based infrastructure is more cost-effective than building a reservoir for water storage. Over 20 years, the interventions are projected to generate net societal benefits between USD 104.34 million and USD 131.59 million through avoided flood and erosion damages, carbon storage, and improved water quality.

The South African energy services market is expanding due to rising electricity costs, energy insecurity, and falling technology prices. The market is segmented into small-scale embedded generation (SSEG), energy storage, and energy efficiency, with a total available market estimated at R131 billion by 2035. Key opportunities include rooftop solar PV for commercial and industrial (C&I) and agricultural sectors, behind-the-meter battery storage, and innovative energy efficiency models like Cooling-as-a-Service (CaaS). The Western Cape is highlighted as a leading regional hub due to its supportive municipal policies and high uptake of SSEG.

The 2022 Waste Market Intelligence Report by GreenCape identifies significant value-add potential in the waste sectors of Cape Town and the Western Cape, estimating a total potential of R320 million to R5 billion annually. The report highlights organic waste as the greatest opportunity, driven by provincial landfill restrictions aiming for 100% diversion by 2027 and the City of Cape Town's (CCT) goal of 100% organic waste diversion by 2027. Key drivers include rising landfill gate fees—with the CCT having the highest metropolitan fee in South Africa at R557 per tonne (excl. VAT)—and the implementation of mandatory Extended Producer Responsibility (EPR) for paper, packaging, electronics, and lighting as of November 2021. The report details specific opportunities in black soldier fly larvae production, biogas, and composting, while noting barriers such as inadequate source separation and the lack of reliable e-waste data. It also outlines the CCT's planned investments in four new material recovery facilities (MRFs) and its strategic shift toward a circular waste economy.

The document outlines the structure of South Africa's public water sector, which spent R 41.5 billion on infrastructure procurement in the 2019/2020 financial year. It details the roles of entities like the Department of Human Settlements, Water and Sanitation (DHSWS) and Water Services Authorities (WSAs), and explains the predominantly used design-bid-build procurement model. The guide provides a comprehensive breakdown of bidding requirements, including B-BBEE compliance and the necessity of registering on the Central Supplier Database. It also highlights the importance of strategic partnerships to overcome bidding barriers and lists available platforms for trialling innovative water technologies.

The report finds that urban adaptation finance is significantly underfunded, representing only 3-5% of total global adaptation flows, with an estimated annual investment of up to USD 3.7 billion against a projected need of USD 11-20 billion for urban infrastructure protection. Analysis of the Global Landscape of Climate Finance, World Bank PPI, and CDP Cities data reveals a heavy concentration of funding in the water and wastewater sectors and a geographic bias toward East Asia and the Pacific, particularly China. Key barriers to scaling finance include limited DFI mandates for sub-national investment, poor municipal creditworthiness, and a lack of standardized outcome metrics for private investors. The report recommends developing practitioner case study databases, improving urban boundary tracking, and expanding DFI mandates to work directly with cities.

The document outlines the regulatory requirements for embedded generation in South Africa, specifically focusing on the transition to a 100 MW license-exempt threshold. It details the two-phase process involving connection approval from a licensed distributor (municipality or Eskom) followed by registration with the National Energy Regulator of South Africa (NERSA).

The document outlines the strategic importance of groundwater in South Africa, detailing the legal requirements under the National Water Act and providing technical recommendations for borehole monitoring to prevent depletion and contamination.

The report identifies significant economic potential in South Africa's waste sector, particularly through the transition toward a circular economy. It highlights the City of Cape Town as a primary hub for waste beneficiation due to its high landfill gate fees and substantial investments in material recovery facilities. Key growth drivers include the 2020 National Waste Management Strategy, new Extended Producer Responsibility (EPR) regulations, and provincial landfill restrictions on organic waste. While the plastics and e-waste sectors show strong potential for virgin material replacement and national processing, challenges such as inadequate source separation, data gaps, and the volatility of virgin plastic prices persist.

The South African energy services market is expanding, driven by rising electricity costs, energy insecurity, and falling technology prices. The market is divided into small-scale embedded generation (SSEG), energy storage, and energy efficiency, with a total available market estimated at R131 billion by 2035. While rooftop solar PV is the dominant SSEG technology, energy storage is emerging as a critical tool for resilience against load shedding. Energy efficiency faced contractions during COVID-19 lockdowns but retains significant untapped potential. The report identifies emerging opportunities such as Solar Power Purchase Agreements (PPAs), behind-the-meter battery storage, and smart metering, while highlighting the role of the Western Cape as a regional hub for green economy investment.

The South African EV ecosystem is currently nascent and dominated by private sector activity, with limited local commercial production of battery cells and a reliance on imported components. While the country possesses significant reserves of battery minerals like manganese, it lacks extensive beneficiation capacity. The automotive sector, a major GDP contributor, is pivoting toward EVs to maintain competitiveness in export markets that are phasing out internal combustion engine (ICE) vehicles. Key barriers to adoption include high upfront costs, inadequate charging infrastructure, and a chronic shortage of technical skills. The report recommends that the City of Cape Town intervene through targeted incentives, procurement of EV fleets, and the development of charging infrastructure and skills training to stimulate a viable local value chain.

The report analyzes the South African urban water market, highlighting a critical funding gap of approximately R33 billion per annum for water and sanitation infrastructure. It identifies three primary investment opportunities: reducing non-revenue water (NRW), implementing non-sewered sanitation systems (NSSS), and wastewater sludge beneficiation. While the Western Cape has planned sufficient supply projects to ensure a surplus, the national context remains water-stressed, with a projected 10% gap between supply and demand by 2030. Key barriers to investment include municipal financial insolvency, lack of technical capacity, and a lack of locally demonstrated technologies.