Draft Integrated Resource Plan will fail to achieve any of the DMRE’s stated ambitions

Just Share has submitted comments on the Integrated Resource Plan, 2023 (“the draft IRP”), published by the Department of Mineral Resources and Energy (DMRE) on 8 January 2024. The draft IRP does not comply with a single one of the aims of an IRP. At the very least, it must be remodelled, with updated data and correct assumptions, and re-published for comment for a reasonable period.

An IRP specifies the types of energy sources and technologies from which electricity may be generated, and indicates the amount of electricity that is to be generated from each of such sources or technologies.

The consequences of electricity generation choices are far-reaching, and have important implications for the protection and/or limitation of various constitutional rights. In addition, an IRP has a critical bearing on whether South Africa is able to transition justly to a low-carbon, climate-resilient economy and whether the country can attract climate finance and other investment. It also affects the country’s ability to comply with the National Development Plan 2030 – which seeks to eliminate poverty and reduce inequality by 2030.

According to the Electricity Regulation Act, 2006 (ERA), an IRP is a “resource plan established by the national sphere of government to give effect to national policy”. The draft IRP defines an IRP as a “generation capacity expansion plan based on a least-cost electricity supply and demand balance in the long term and incorporates government policy”.

It defines the “main purpose” of an IRP as being “to ensure security of electricity supply necessary by balancing supply with demand, while considering the environment and total cost of supply”. The draft IRP states that it aims to meet “three distinct but not mutually exclusive aspirations, namely, security of supply, energy affordability and carbon emissions reduction”.

However, the draft IRP fails to meet any of those objectives individually, let alone in combination. This is primarily due to its heavy reliance on fossil fuels.

  • For starters, it does not “ensure security of supply”: according to the draft IRP’s “emerging plan” (for the period 2023 to 2030), there will be loadshedding at least until 2028.
  • The draft IRP relies on outdated and factually incorrect cost data and assumptions, and does not present a plan that will result in affordable electricity.
  • The draft IRP will exacerbate climate impacts and severely hinder the country’s ability to achieve its climate commitments.

The draft IRP inexplicably reduces the procurement of renewables as compared to the current IRP, and fails to accelerate significant investment in wind and solar PV and battery storage. The draft IRP also intends to ramp up gas procurement, unrealistically counts on improving the performance of Eskom’s ageing and inefficient coal fleet, and intends to delay the decommissioning of these polluting and non-compliant plants.  Quite apart from the severe climate and health impacts of this approach, it fails to recognise that rapid and extensive scaling up of renewable energy generation is the most cost-optimal energy pathway, and affords the best opportunity to provide affordable, reliable energy for all people in South Africa.

The draft IRP also fails to comply with applicable policy or legislation. For example, it does not achieve the aims of the ERA or the National Energy Act, 2008, in that it does not: “ensure uninterrupted supply of energy to the Republic”; “facilitate universal access to electricity”; or “facilitate energy access for improvement of the quality of life of the people of Republic”.

Another significant failing of the draft IRP is its treatment of legally-prescribed minimum emission standards (MES) for toxic air pollutants, under the National Environmental Management: Air Quality Act, 2004. The draft IRP treats MES compliance as an issue to be “balanced” against energy security considerations. Compliance with the law is not optional and air pollution from non-compliant facilities has enormous impacts on human health and wellbeing.

In relation to greenhouse gas (GHG) emissions, none of the draft IRP’s scenarios results in the achievement of net zero emissions in the electricity sector by 2050. This despite the Low Emission Development Strategy 2050’s economy-wide goal of net zero emissions by 2050.

The draft IRP also ignores that the country’s Nationally Determined Contribution – in terms of the Paris Agreement – is required to become increasingly ambitious, with an update due next year.

The draft IRP should also have been developed after – not before – the establishment of the electricity sector’s sectoral emission target (SET). SETs will be required in terms of the Climate Change Act and must include quantitative and qualitative GHG emission reduction goals for the first five years, the subsequent five to 10 years, and for a 10-to-15-year period thereafter. Despite the electricity sector being the easiest and cheapest to decarbonise, the draft IRP assumes that the power sector’s share of the country’s emissions will remain constant at about 44% – i.e. 160-180 Mt – until 2030. This is highly unlikely and further discredits the draft IRP’s proposed energy mix.

It is, in any event, premature for the draft IRP to have been published without an Integrated Energy Plan (IEP), of which it should be a subset. The National Energy Act provides for an IEP to serve as a guide for energy infrastructure investments. The IEP is required to take all viable energy supply options into account and guide the selection of the appropriate technology to meet energy demand. The IEP is hugely relevant to the decisions made about South Africa’s electricity future and it should have been published ahead of, and informed, the draft IRP.

As set out in Just Share’s comments, the draft IRP falls far short of the minimum requirements for a credible and lawful electricity plan; nor does it meet its self-described “distinct but not mutually exclusive aspirations”. It does not promote energy equity. It does not provide energy security. And it does not pay any meaningful regard to environmental sustainability.

IMAGE: Getty Images / Nigel Jared

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