Draft IRP 2018: (in)effectiveness of public participation raises questions

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DRAFT INTEGRATED RESOURCE PLAN 2018
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The South African Department of Energy is revising the Integrated Resource Plan (IRP), the blueprint of what the country’s energy mix will look like for the next 30 years. This long-overdue update (the last version of this “living plan” dates back to 2010!) is critical for social, economic and environmental reasons. This plan will determine how South Africa intends to meet its energy demand – and importantly, tackle energy poverty – while effecting the much-needed rapid transition to a low-carbon energy system.

In planning the country’s energy path, the IRP ought to ensure energy affordability to its citizens, many of whom still do not have access to what many of us take for granted. Affordable electricity is a critical lever for socio-economic progress, and new electricity generation capacity must be planned and provided at least cost.

At the same time, it also should meet existing ministerial determinations and contractual commitments for any existing new-build, as well as government’s policy objectives, which include universal access to electricity, economic growth and jobs, environmental compliance and sustainability, and increasing the diversity of both primary energy sources and generators within the electricity supply industry in order to manage risk.

In September 2018, parallel to the public consultation on the updated draft IRP organised by the Department, Parliament’s Portfolio Committee on Energy invited the public to make submissions on the same, as part of the Legislature’s mandate to discuss and review government policy, and listen to the views of the public.

As per the separation of powers enshrined in the South African ConstitutionParliament is mandated to oversee the Department of Energy’s work and hold it accountable. By opening the draft IRP 2018 for public submissions, the Portfolio Committee on Energy aimed to ensure that it would be scrutinised objectively, with due consideration of all relevant goals, facts, and parameters.

Ultimately, the purpose of public participation in this oversight process was to ensure that the updated IRP ultimately serves the best interests of the people and of our environment. As such, submissions are an important way to influence decision-making by the Government.

ACRP was one of many civil society organisations that submitted comments which you can download here:
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In addition to written comments, the Portfolio Committee held a series of five public hearings and a roundtable discussion in Parliament in October 2018. Members of the public had the opportunity to make oral presentations of their views and recommendations regarding our energy generation choices as a country.

Several organisations involved in Action 24, including SDCEA, the Land Rights Organisation South Africa (LANDROSA) and Concerned Citizens of Lephalale/ Earthlife South Africa, took part in these public hearings to raise the voice of communities that experience many negative impacts as a direct result of the fossil fuel energy industry, from exploration and mining to the power stations.

While this oversight exercise is very welcome and should be the rule rather than the exception, it raises a few questions. Was the engagement meaningful? How will these public inputs feed into the IRP update by the Department of Energy? Why did it take close to a month for the Portfolio Committee to adopt the final report on the IRP 2018 public hearings, when this should be a straightforward case of recording and analysing the submissions received?

In a letter to the Chair of the Portfolio of Energy, the civil society collective Energy Governance South Africa highlighted some key concerns about this public engagement:

  • Very few members of the Portfolio Committee attended the public hearings. In fact, the number of Members of Parliament (MPs) present at the roundtable went from three to one at the end of the discussion.
  • During the first two days of the hearings, the Question and Answer sessions did not take place, and the MPs did not openly interrogate what the public in attendance (civil society, industry representatives, and lobbying groups) presented to them – despite some of the presentations clearly showing conflicting information. Some presentations contained questionable and unreferenced figures, which the MPs did not query. One example: among several questionable nuclear figures was the claim Koeberg supports 64 000 jobs annually, whereas the Eskom website puts this number at 1 200.  This does not constitute meaningful engagement, and the process ended up being a one-way flow of information without interaction or interrogation.
  • While environmental and climate concerns were recurrent themes throughout the submissions, the MPs had no questions on climate change and alignment between the draft IRP update and the need for a swift and complete shift to low-carbon energy – not to mention consistency between South Africa’s energy and environmental policy. In fact, successive draft reports on the hearings made no mention of climate change or the urgency of the situation in light of the recent Intergovernmental Panel on Climate Change (IPCC) special report on Global Warming of 1.5 °C, and of South Africa’s even more alarming Third National Communication under the UNFCCC. Quite the opposite – revised draft reports versions confirmed a favourable bias for coal and nuclear, particularly in view of their (claimed) employment potential. Submissions that suggested curtailing the construction of Kusile coal-fired power station, fast tracking the decommissioning of some coal power plants, or that raised concerns around the Chinese-backed coal fired power plant for Limpopo’s Energy and Metallurgical Special Economic Zone (EMSEZ) were struck from the record.
  • While the Portfolio Committee heard over 30 presentations during this process, the voices from communities were largely under-represented. They are the most affected by electricity prices, along with the environmental and health impacts of electricity generation, but currently have the least access to involvement in the IRP public participation process. ACRP and many other organisations have called on the Portfolio Committee to avail financial support to allow less well-resourced communities to take part in the public hearings held in Cape Town. The Portfolio Committee failed to grant this request, and the few community members present at the hearings were only able to attend through the support of other civil society organisations. Some of them did not even get the opportunity to speak at the public hearings on 23 and 24 October 2018, as the programme did not allow enough time for them.

This initiative to engage the public was welcome and in fact necessary. However, it feels like the Portfolio Committee missed the opportunity to involve the public effectively. The IRP update must be conducted with full transparency and proper regard to the Constitution and what is in the public interest.  In this regard, the effects of the energy mix on human health, the environment, climate change, and the economy are critical while also providing accessible and affordable electricity to our citizens.
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