REVIEW OF THE IRP 2023

COMMENTS FOR SUBMISSION

TO

THE DIRECTOR GENERAL OF THE DEPARTMENT OF MINERAL RESOURCES & ENERGY

22nd MARCH 2024

Introduction

The Kromme Enviro-Trust is an environmentalist NGO in the St Francis Bay area, near Humansdorp in the Eastern Cape. This district is something of a power-production centre, with five existing wind farms, three wind farms under construction, and an identified site for a possible nuclear power station at Thyspunt.

The DMRE published the Integrated Resource Plan 2023 on 4th January 2024 with (extended) time for comments until 23rd March 2024. Our response to the IRP 2023 is that it defies South Africa’s agreed nationally determined contribution (NDC) commitments in terms of the Paris Agreement, makes little or no attempt to plot a way forward that reduces the country’s greenhouse gas emissions, and sacrifices the long-term health of its population on the altar of resource exploitation.

Any plan that references ‘clean coal’, ‘delayed decommissioning of coal-fired power plants’, ‘acceleration of gas resource assessment’ is focused not on achievement of the Paris 1.5° goal but on maximising the use of fossil fuels. This country is already the fourteenth largest emitter of greenhouse gases in the world. Is it our ambition to move up this table to a top ten or top five position? This plan seems designed to make that a reality.

The IRP 2023 focuses on coal, gas and renewables, with a passing nod to nuclear, hydro, storage and green hydrogen. The interventions it proposes (p.32) are:

  • Improve the electricity availability factor
  • Accelerate gas-to-power initiatives
  • Delay shutting down coal plants
  • Develop the grid
  • Expedite Koeberg’s life extension
  • Re-look the minimum emissions standards required by NEMA air quality regulations

All of the above, with the exception of the Koeberg life extension, will lead to an increase in emissions. This is in direct contradiction of SA’s Paris Agreement commitments and stands to be rejected.

  1. Coal.

The plan opens with a declaration of intent to continue using coal for power generation, justifying this by “the abundance of coal resources in the country” (p.10). It cites the necessity for investing in “cleaner coal technologies” and refers to a carbon capture utilisation and storage study being conducted in Leandra. This is greenwashing of the first order and is completely oppositional to the global accord to move away from fossil fuels, contrary to the document’s introductory claim that SA’s approach to energy security is “in line with international trends and developments” (p.10)

The so-called ‘cleaner coal technologies’ are identified as fluidised bed combustion and pulverised fuel technologies with carbon capture and storage. An expert retained by the Centre for Environmental Research, Dr Ranajit Sahu, considered both technologies and reported that:

  • Pulverised coal units, even at maximum efficiency, require unaffordable costs for capturing their emitted carbon dioxide
  • Fluidised bed technology emits from two to ten times more nitrous oxide (a greenhouse gas 300 times worse than carbon dioxide) than pulverised coal technologies

He concluded that “there is no such thing as ‘clean coal’, regardless of whether technologies are used to minimize air emissions.”[1]

Delaying the shut-down of coal-fired power plants for ten years is unconscionable and reveals a readiness to sacrifice the health of workers and neighbouring residents in the interest of political expediency. The impact on carbon emissions of delaying plant shut-downs is entirely unacceptable throughout the period covered by the plan.

 

  1. Gas

The plan enthusiastically promotes the use of gas in SA’s power production, specifically in peaking power plants (closed cycle gas turbines, closed cycle gas engines and internal combustion engines). It clearly does not envisage an end to the need for the emergency power supplied by those sources: load-shedding is predicted to continue until at least 2027, an admission of the complete failure of the national power utility to operate a normal power supply.

The IRP envisages replacing gas imports, at least in part, with gas from the Brulpadda field off Mossel Bay, or from fields discovered in the Free State and Mpumalanga, and from shale beds (presumably via fracking?) (p.11) It unashamedly states that gas exploration is being pursued and “must be accelerated” (p.11).

It seems clear that there is a political agenda underlying the IRP 2023, biasing it towards the use of coal and gas.  There is a cavalier disregard of the need to exit from fossil fuels and to construct a green economy that would be able to compete in a global economy that penalises carbon emitters and will ramp up those penalties as time goes on. The IRP has seized on the classification of gas as a ‘transition fuel’ and interpreted it as gas being classified as green: it has also seized on the potential of so-called ‘clean coal’. Neither of these re-framings is true or valid.

Not only does the pursuit of domestic gas production envisaged in the IRP defy South Africa’s Paris commitments, it defies economic logic. If the Paris Agreement goal of net zero by 2050 is met, i.e. phasing out fossil fuels worldwide, world gas demand declines significantly after 2050, according to International Energy Agency predictions. Steve Nicholls of the Presidential Climate Commission[2] cautions that investing in gas infrastructure would require recovering the capital investment before 2050 because in that year it will be necessary to phase gas out of the economy or to switch the infrastructure to hydrogen (significantly more expensive) or to invest in a means of carbon capture and storage (also significantly more expensive). In all likelihood investments in gas infrastructure will be stranded within a 25-year time frame.

Nicholls sees gas as strictly short term, or Horizon One as the IRP defines it, while South Africa works to achieve the ‘greener industrialisation’ that will allow it to be competitive internationally and to achieve economic growth.

  1.  Renewables

Rather than opting to set SA on a trajectory towards a renewables-dominated power mix, the IRP refers to renewables as “an opportunity to diversify the electricity mix” (p.12). There is no vision for a green powered future, just an acknowledgement that renewables are part of the mix. The plan does acknowledge that renewables are an important feature of the global move to decarbonisation (p.12) but chooses to ignore that move and follow its own carbon-biased strategy.

The 2023 plan in fact reduces renewable procurement, from the 15.2GW envisioned by the IRP 2019 to only 8GW. The yearly build of solar PV is limited to 900MW and wind is limited to 1720MW, and this across an extended time frame, which defies logic.

  1. Green Hydrogen.

In the northern hemisphere about 25% of the gas market has been replaced by hydrogen, and the goal is to fully convert old gas plants to hydrogen (Tord Jonsson, Wärtsilä Energy[3]). Large investments are being made in hydrogen research and development. But in the IRP 2023 hydrogen receives only a passing mention.

In the interest of meeting our climate change commitments, we would have expected green hydrogen to have been the subject of serious scrutiny at the very least. If Namibia can embark on the construction of a large-scale green hydrogen industry with its Hyphen project, there is no reason why South Africa should be incapable of doing likewise. Concentrating on natural gas and ‘clean’ coal, as the IRP 2023 does, clearly betrays the political agenda underlying the proposals.

 

Conclusion

The IRP 2023 is seriously flawed in its approach to its stated purpose of ensuring the security of the electricity supply while considering the environment and ensuring compliance with South Africa’s emission reduction plan (p.10). It claims to be in line with international trends and developments but this is far from the truth. It is not even in line with other South African government policies on climate, air quality or green industrialisation.  As environmentalists the Kromme Enviro-Trust rejects this plan and its attempt to prolong the country’s dependence on fossil fuels. Just because we have a resource in abundance is no justification for using it: we have human resources in abundance but that would not justify engaging in human slavery.

 

Kromme Enviro-Trust (St Francis)

Contact: [email protected]

 

IRP 2023

https://www.dmr.gov.za/Portals/0/Resources/Documents%20for%20Public%20Comments/IRP%202023%20[INTEGRATED%20RESOURCE%20PLAN]/Publication%20for%20comments%20Integrated%20Resource%20Plan%202023.pdf?ver=2024-01-05-134833-383

Government Gazette 4 January 2024, Vol 703, No 48874

The new IRP looks at two time horizons – the first takes us to 2030 and the second to 2050.

Horizon One, to 2030, puts forward five scenarios:

  1. Firm initiatives: already committed (under construction, with confirmed grid capacity)
  2. Reference case
  3. Firm initiatives plus other applications (includes REIPPPP 7)
  4. Firm Initiatives plus gas coming in from 2027 (DMRE gas, Eskom Richards Bay gas, RMIPPP dispatchable gas)
  5. Firm Initiatives plus recovery (Eskom electricity availability factor EAF improves)

Their evaluation:

  • Scenarios 1, 2 and 3 leave high levels of unserved demand and continued high usage of peaking power stations
  • Scenario 4, which includes gas to power initiatives, shows constraints remaining up to 2026 but significant reductions in unserved demand and use of peaking plants from 2027.
  • Scenario 5 combines the already committed initiatives with Eskom improving its EAF and this would restore supply immediately with low requirement for peaking plants.

The preferred plan for Horizon One is still predominantly coal based but adds a large new contribution from gas (24% of added capacity), ‘distributed generation’ (22%), wind (15%) and solar (12%). It (optimistically) requires an improvement in Eskom’s EAF, acceleration of the deployment of gas to power, delaying the shut-down of coal-fired power stations, development of the grid, accelerating the action to extend Koeberg’s life, and – seemingly – negotiating acceptance of non-compliance with the air quality standards.

BIG ISSUES HERE

Horizon Two, from 2031 to 2050, puts forward six alternatives:

  1. Reference case: least cost energy mix (large build of solar 18 000+MW, wind 41 887MW and gas 23 829MW)
  2. Renewables only, with storage (wind 97 093MW, solar PV 18 000MW, CSP 34 500MW, storage 19 761MW)
  3. Renewables plus nuclear (reduced wind at 84 289MW, solar PV as per alternative 2, no CSP, storage as per alternative 2, plus nuclear 14 500MW[4])
  4. Delayed shutdown of coal-fired power stations by 10 years: plus new build of gas 26 507MW, wind 35 412MW, solar PV 18 000MW.
  5. Clean coal: new coal build 5 500MW, gas 26 025MW, wind 60 814MW, solar PV 18 000MW

Their evaluation:

  • Alternative 1, least cost, provides an adequate energy mix and an initial signification reduction in carbon emissions, followed by an increase from 2042 as gas utilisation increases
  • Alternatives 2 (renewables only) and 3 (renewables + nuclear) exclude gas after 2033 and have the least carbon emissions but the highest levels of unserved demand.
  • Alternative 4, delaying shutdown by 10 years, maintains security of supply but does not reduce carbon emissions
  • Alternative 4, using so-called “clean coal”, does not maintain security of supply but has low emissions.

The plan acknowledges the urgency of immediate action to provide for the required capacity envisaged for just over a decade from now. The overall evaluation is that a combination of nuclear, renewables, clean coal and gas is required to provide security of supply along with carbon reduction. Renewables only or renewables plus nuclear reduce carbon emissions but are costly to implement and do not provide security of supply.

The nuclear options considered are Pressurised Water Reactors[5] (PWR) and Small Modular Reactors (SMR). 

 

[1] Potential Impacts of Proposed New Coal Generation, Ranajit Sahu.(2021) https://cer.org.za/reports/potential-impacts-of-proposed-new-coal-generation

[2] The Role of Gas in South Africa’s Energy Transition, March 2024

[3] The Role of Gas in South Africa’s Energy Transition, March 2024

[4] Koeberg capacity 1860MW, Thyspunt planned capacity of 3 000 to 4 000 MWe and an eventual total site capacity of up to 10 000 MWe.

[5] As per Koeberg