SA’s energy planning must be grounded in national sovereignty and developmental realism, but the draft Integrated Resource Plan 2023 (IRP 2023) reflects neither.
As the world’s most powerful economies strategically adjust their energy systems to secure growth and geopolitical strength, SA is adopting a decarbonisation trajectory that is misaligned with its endowments, infrastructure limitations and socioeconomic fragility.
Globally, China and the US continue to pursue energy policy grounded in self-interest, industrial pragmatism and resource sovereignty. International Energy Agency (IEA) data shows China is responsible for more than 30% of global carbon emissions and is expanding its coal-fired capacity by more than 300GW — decisions defended by China’s National Energy Administration as critical to economic growth and energy security.
The US, despite ambitious climate rhetoric, is expanding fossil fuel infrastructure. The US Energy Information Administration (EIA) projects that the country will be the world’s largest liquefied natural gas (LNG) exporter by 2026. Both nations are unapologetic about leveraging their domestic energy endowments to strengthen industrial advantage.
SA, by contrast, is a developing economy struggling with endemic poverty, unemployment, grid instability and institutional erosion. Yet it is committing to developed world energy targets and policy frameworks that ignore its own context.
Our developmental mandate cannot be subordinated to externally driven climate metrics. The just energy transition must begin at home, grounded in economic realism and energy justice, not in ideological imitation of Brussels, Beijing or Washington.
It is in this context that the draft IRP 2023 must be understood and critiqued. While the document presents 10 modelled pathways across two horizons, it evades political commitment to any. It hides behind scenario-based modelling without adopting a clear, enforceable pathway for implementation. It is not aligned with section 34 ministerial determinations under the Electricity Regulation Act (2006), rendering it institutionally hollow.
The language of the IRP is conditional, filled with hedges such as “possibilities” and “opportunities”, rather than assertive policy direction. This technocratic ambiguity is unacceptable amid stage 6-8 load-shedding, collapsing infrastructure and public despair.
Most fatally, the IRP 2023 ignores the enforcement of minimum emission standards (MES) under the National Environmental Management: Air Quality Act. According to the Government Gazette published in January 2024, Eskom’s exemptions are set to expire. Failure to comply will legally require the shutdown of noncompliant coal plants.
Legal cliff
Conservative estimates project this would remove at least 16,000MW of baseload capacity, with the worst-case scenario being up to 30,000MW, more than 60% of Eskom’s coal fleet. None of the IRP’s scenarios model this legal cliff. There is no contingency strategy. This is an unforgivable omission in a country already teetering on the edge of grid collapse. If MES enforcement is not phased in with realism, and matched by accelerated capacity replacement, the result will be nationwide blackouts, industrial ruin, water system failure and the undermining of constitutional rights. The IRP’s silence is not merely a technical failure — it is a national risk.
Equally glaring is the IRP’s reliance on outdated electricity demand assumptions. The ESRG/Sanedi model used by the department of energy fails to account for electricity needs arising from SA’s green industrialisation agenda: green hydrogen, electric mobility, battery processing and digital infrastructure such as data centres. The assumption that these new sectors will be “off-grid” is not supported by either global trends or domestic feasibility studies. SA’s Hydrogen Valley plans, including major ammonia export nodes in Coega and Saldanha, will require large-scale grid access. Failure to integrate this demand into planning will create significant underinvestment in transmission infrastructure, misallocate resources and stall industrial growth.
Magical thinking, not planning
On the supply side, the IRP continues to use outdated 2020/21 Electric Power Research Institute cost data. Yet the global landscape has shifted dramatically. Solar PV and battery storage prices have declined by more than 50% since then, making them the most cost-effective and scalable options for new generation. Conversely, clean coal and nuclear options remain financially unviable when full costs (including water usage, emissions compliance and project delays) are accounted for. Worse still, the IRP assumes Eskom’s energy availability factor (EAF) will recover to 70%, despite it consistently falling below 55% over the past five years. This is magical thinking, not planning. The risk is that the IRP inflates future baseload availability that will not materialise, deepening investor hesitation and system unreliability.
The draft IRP 2023 is not a plan, it is a collection of guesses, blind spots and deferrals. It fails to reckon with MES enforcement. It underestimates demand.
Critically, the IRP 2023 is not aligned with the four primary policy frameworks governing SA’s energy system. First, the Electricity Regulation Act (2006) requires that IRPs guide binding ministerial determinations, but this link is broken. Second, the National Energy Act (2008) demands holistic integration across sectors, yet the IRP remains generation-centric. Third, the 1998 white paper on energy policy prioritises access, equity and participation, yet the IRP offers no solutions for township or rural energy poverty. Fourth, the National Development Plan (NDP) 2030 calls for co-ordinated infrastructure-led growth, yet the IRP lacks credible financing, sequencing or implementation frameworks. In short, the draft IRP is not only incomplete, but also noncompliant with SA’s existing legal and policy architecture.
Investor confidence has also been undermined. Unlike Morocco, Chile, Vietnam or even Nigeria, countries that have implemented policy-aligned feed-in tariffs, renewable energy zones and transparent auction frameworks, SA’s draft IRP 2023 fails to provide clarity on procurement volumes, bid windows, bankable timelines or investor guarantees.
Vietnam has rolled out 16GW of solar PV in less than three years. Chile attracted more than $20bn in clean energy investment through legally binding regulatory frameworks. Morocco’s Noor Complex succeeded due to strategic sequencing and public-private finance. SA, once hailed for its Renewable Energy Independent Power Producer Procurement Programme success, is now regressing. IRP 2023 does not tell investors where to deploy capital, when to expect returns or how regulatory risk will be mitigated. No sovereign investor will back a road map that itself has no route.
Crisis of credibility
This crisis of credibility can be addressed, but only through bold reform. SA must urgently consolidate a hybrid pathway, drawing from IRP pathways 1, 3 and 5. This should include the phased and conditional shutdown of noncompliant coal plants; the expedited rollout of 5,000MW-8,000MW of flexible gas capacity; commissioning of at least 2,000MW of small modular nuclear reactors (SMRs); and the deployment of 15,000-plus MW of wind, solar PV and concentrating solar power (CSP) with storage. Forecasts must incorporate hydrogen, electric vehicles and beneficiation electricity needs. Grid planning must be accelerated in renewable energy zones, ports, special economic zones and industrial hubs.
A transmission and localisation master plan must be developed, outlining capex needs, spatial sequencing, transformer and turbine manufacturing targets and local content incentives. This must be embedded in the National Infrastructure Plan, the department of trade, industry & competition’s industrial policy, and fiscal programming.
Grid command centre
A grid command centre under Operation Vulindlela should be tasked with unblocking project pipelines, fast-tracking environmental impact assessments, standardising land approvals and ensuring interdepartmental co-operation.
But no reform is complete without addressing energy inequality. The most progressive proposal the IRP must institutionalise is a township microgrid programme, powered by solar PV plus battery storage, targeting 2-million households by 2030. This can be delivered via Eskom Distribution, metros and licensed social independent power producers. A flat energy rental for low-income households (R100-R150/month) and a solidarity infrastructure fee for upper-income, off-grid households, would embed redistribution into the energy system. With SA’s Gini coefficient at 0.63, this is not only affordable, it is morally necessary.
Job creation through local installation, maintenance and manufacturing would amplify the socioeconomic dividend of this intervention.
The draft IRP 2023 is not a plan, it is a collection of guesses, blind spots and deferrals. It fails to reckon with MES enforcement. It underestimates demand. It distorts technology costs. It assumes supply that does not exist. It ignores the distribution sector. It undermines investment. It violates constitutional guarantees. And it offers no hope to the millions still living in energy poverty. It cannot be passed in its current form.
The IRP must now become a binding social contract, legally enforceable, economically rational and socially inclusive. Energy planning is not about megawatts alone, it is about sovereignty, dignity, jobs and constitutional justice. If we get the IRP wrong, we lose not only investment, but the future.
• Bici is a master of management in energy leadership candidate at Wits Business School.











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