An objection has been made over the short notice given to stakeholders for Tuesday’s “targeted consultation” by the government with stakeholders on the crucial and long overdue Integrated Resource Plan (IRP) 2024.
The notice was only received on Friday.
The IRP is a policy document that sets out when new generation capacity must be added to the country’s electricity system, how much and what the technology mix must be. The aim is to ensure electricity security in future at the lowest cost with the least effect on the environment.
Energy & electricity minister Kgosientsho Ramokgopa announced at a media briefing on November 19 that the department would embark on a series of “targeted consultations” on a revamped document with those who submitted substantial comments on the draft IRP 2023. These would start with an in-person workshop in Pretoria on Tuesday and several online engagements thereafter.
He said earlier consultations on the draft IRP2023 resulted in 4,338 submissions, 136 of which were considered “substantial”.
The minister indicated that all the inputs would be consolidated by the end of November, which would pave the way for him to take the document to cabinet and if approved have it gazetted in the first quarter of next year.
Chris Yelland — in his capacity as adviser to the Organisation Undoing Tax Abuse (Outa), EE Business Intelligence MD and commentator on energy matters — objected to the short notice for the consultations saying this was causing problems for the industry.
He warned that undue process might lead to a legal challenge that would further delay the finalisation of the IRP2024.
Yelland also objected to the lack of information needed to properly prepare for the engagement “such as details of any revised assumptions and the output of revised modelling.”
He expressed Outa’s opinion that there had been “completely inadequate notice, without a programme or any documentation enabling key stakeholders that have been invited to attend the targeted stakeholder engagements to prepare and to participate meaningfully.”
Two days of the notice period were over a weekend.
He noted that there was an important Africa Renewables Investment Summit taking place next week, which clashed with the consultations.
Yelland warned that the process was “seriously compromising the integrity and credibility of the targeted stakeholder engagement process”.
“It is Outa’s view that without a credible and meaningful stakeholder engagement process, with adequate notice and information to enable meaningful participation and input, there may be legal challenges arising that could further delay the finalisation of the IRP,” Yelland said.
The country is still operating under the IRP2019. The revised draft IRP2023 was published early in January but has not yet been finalised. This contributes to policy uncertainty that is detrimental to investment in the fast-developing local electricity market.
The draft IRP2023 was widely criticised for among other things its failure to ensure energy security because it provided for load-shedding until 2027.
It was light on new renewable energy generation and included 7, 220MW of additional gas generation to be added by Eskom and independent power producers (IPPs) up to 2030. A total of 6,300MW of embedded generation was included, as well as about 4,000MW of battery storage from Eskom and IPPs.
The document dealt with two time horizons: the period up to 2030 and thereafter, up to 2050.
Busisiwe Mavuso, CEO of Business Leadership SA (BLSA), said earlier this year the document was out of touch with what was happening in the energy market. She said it needed to be revised “immediately”.
Meridian Economics pointed to serious problems with the modelling and cost assumptions. According to Meridian, wrong assumptions and flawed modelling in the IRP2023 led to “incorrect and economically damaging conclusions”.
The IRP2023 was developed under the political leadership of Gwede Mantashe, then-minister of mineral resources & energy. The energy function has since been reallocated to Ramokgopa who earlier indicated that his department had taken the criticism to heart and was busy with a fundamental review of the IRP.









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