Attorneys from the Centre for Environmental Rights (CER) will today (16 October) tell Parliament that an Integrated Resource Plan for Electricity (IRP) that provides for expensive new coal-fired power, at a time when South Africa needs to be urgently transitioning away from harmful coal, would be in conflict with the Constitution.
This means that an IRP that irrationally includes expensive new coal could be held up by court challenges for years to come, they will argue.
On 16, 17, 23, and 24 October 2018 the Portfolio Committee on Energy will be hosting public hearings on the draft IRP 2018. In addition to the CER, activists from Life After Coal partners groundWork and Earthlife Africa will be making submissions, as well as activists from various affected communities, and many other civil society organisations.
Although the draft IRP released for comment on 27 August 2018 is a substantial improvement on both the IRP 2010 and the 2016 draft, it still proposes the inclusion of 1000MW of new coal capacity to come from the proposed independent power producer (IPP) coal-fired power stations, Thabametsi and Khanyisa.
This is despite the draft IRP’s acknowledgement that a least-cost IRP would not include any new coal capacity, and despite Minister of Energy Jeff Radebe’s admission that forcing these two coal plants into the IRP will cost South Africa an additional R23-billion.
ER argues that these power stations are not needed, as South Africa has excess electricity capacity, while cheaper and cleaner alternatives to coal-fired power are available.
The organisation points out that Thabametsi and Khanyisa would be two of the most greenhouse gas (GHG) emission-intensive plants in the world.
The CER’s oral submissions on Tuesday will be based on the written submissions made to the Portfolio Committee on the draft IRP on 5 October 2018. In addition to the objections to the inclusion of 1000MW of coal in the IRP, the following further objections to the draft IRP were made:
* The draft IRP places an arbitrary and unreasonable annual constraint on renewable energy capacity up until 2030.
* The draft IRP does not give adequate (or in most cases any) consideration to the external costs and impacts of various electricity sources for water, health, ecosystems, and climate. Importantly, coal power generation requires enormous volumes of water and pollutes our scarce water resources. Yet, despite South Africa’s ongoing water crisis, the draft IRP fails to model water use and associated costs of different supply options. Including these costs would justify a rapid shift from coal to water-efficient renewable energy.
* The draft IRP fails to adequately convey the urgency and need to rapidly transition from fossil fuels and the need to effectively eliminate GHG emissions from the electricity sector as soon as possible; particularly in light of the findings of the recently-published Intergovernmental Panel on Climate Change’s Special Report.
* The draft IRP simply assumes a 50-year lifespan for all Eskom stations, rather than the period for which each station remains economic, is necessary for energy security, and can comply with the law. In addition, remaining units of the very-delayed and over-budget Medupi and Kusile power stations should be abandoned.
* The draft IRP makes extensive provision for new gas capacity of 8100MW, without providing any clarity on, inter alia, the sources of gas (which is presumably planned to come from fracking and/or offshore gas production), its associated impacts, or the types of gas power plants proposed. Notably, it fails to assess the need for gas against competing alternatives such as battery storage, which are continuously becoming cheaper, and demand-side options to address peak demand. A proper assessment of these alternatives would substantially reduce the need for gas capacity. Gas is a fossil fuel with considerable impacts for climate change, particularly when methane (a potent GHG) leaks from extraction, transport, and storage are accounted for alongside emissions from gas power plants. South Africa should not be locking into further unnecessary GHG-emitting infrastructure like gas.
* The draft IRP does not adequately consider important aspects which significantly affect assumptions around South Africa’s electricity needs and planning. Notably, it unreasonably over-states economic growth and electricity demand (despite acknowledging that the IRP 2010 incorrectly overestimated demand) and fails to properly assess peak demand. Further, it does not consider the uptake of energy efficiency, demand-side management, and distributed energy, which are radically altering demand. As such, the draft IRP fails to properly assess the trends and rapid changes in relation to electricity systems happening across the globe.
* The Department of Energy has failed to conduct adequate consultations and participation with affected communities in relation to the draft IRP and to provide stakeholders with the modelling data crucial for effective and meaningful consideration of and participation on the draft IRP 2018. The CER has had to formally request this data through the Promotion of Access to Information Act, 2000 (PAIA), and it has still not been forthcoming.