OUTA believes the Integrated Resource Plan issued for public comment is sloppy, inaccurate, out of date and disregards the importance of public comment. It should be recalled, reworked and reissued for public comment. 

The Draft Integrated Resource Plan 2023 (IRP 2023) issued for public comment in January 2024 by the Department of Mineral Resources and Energy (DMRE), is inadequate and makes a mockery of the public engagement process, says OUTA’s CEO Wayne Duvenage.  

He adds that the current Draft IRP 2023 contains a number of significant errors that even government acknowledged, as well as omissions and inadequacies. “That is why OUTA says it should be recalled, reworked and reissued for public comment, with adequate time provided for a meaningful consultation process, including a series of public hearings around South Africa.” 

The IRP 2023 is a key document for South Africa’s national long-term electricity planning and OUTA believes that the government has not taken this process and the need for regular updates and constant analysis seriously, explaining the current chaos with the country’s electricity supply. The current draft version is the long-awaited update to IRP 2019, and it took the DMRE about two years to produce. 

The initial closing date for comments (23 February 2024) was extended by a month, but this is still hopelessly inadequate, as were the DMRE’s briefings to the public, Duvenage explains. There were also no public hearings at which the public could engage with the plan. 

Despite the tight deadline, OUTA has made a submission on the IRP 2023 to DMRE. “We believe that the corrections to the IRP 2023 will need to be so substantive that it will require another round of public engagements, once the assumption data is more accurate and transparent,” says Duvenage.

In its submission, OUTA says the IRP2023 document should be reworked, using the input provided by credible critics and scenario planners, and then republished for a more meaningful public commentary and engagement process. The IRP should be a detailed plan which takes into account detailed information, including economic assumptions, the existing power generation fleet performance and decommissioning schedule, better-defined generation technology options and costs as well as various possible generation scenarios. The required electricity demand and the least cost to society should also be taken into account. 

OUTA’s submission notes that the initially gazetted plan had acknowledged errors and changes needed, thus requiring reworking. However, these corrections and updates are not reflected in the current version. “The serious errors, omissions and changes required in input assumptions, technology costs and available capacity have resulted in erroneous conclusions and observations in the Draft IRP 2023 that are not supported by the facts,” says OUTA’s submission. It becomes an almost futile exercise to comment on such a poorly compiled IRP 2023 document. 

Some of the errors and omissions noted in OUTA’s submission include:

• Inadequate and out-of-date technology costs;

• The use of fixed technology costs which do not take into account the likely cost reduction over the study period to 2050, especially given that international studies indicate that the cost of renewables and batteries are expected to decline;

• The amount of renewable capacity projected to be installed by the private sector and individuals appears to be underestimated;

• The plan includes the three Karpowership gas-to-power ships, although these are no longer on the table;

• There are unrealistic constraints on new renewables;

• A fixed gas fuel price was used although this is not realistic and the rand/dollar exchange rate is not taken into account;

• The impact of the hydrogen economy, green hydrogen and electric vehicles is inadequately addressed;

• Economic assumptions are missing or inadequate;

• Construction time and phasing for technology construction is largely missing;

• There is no information on delaying the decommissioning of power stations, or on the recommendations of the VGBE consortium report on Eskom;

• Electricity price trajectories are missing for various scenarios;

• The carbon emission constraints and minimum emission standards constraints are missing; and

• There is significant misalignment with existing legislation, regulations and policy. 

OUTA notes that Meridian Economics, a highly respected and professional scenario planning organisation, has published its review of the IRP 2023. "Their version furthermore underlines the fact that the IRP 2023 is not adequate or transparent and arrives at incorrect and economically damaging conclusions”. 

More information

A copy of OUTA’s submission is here.