Serious questions continue to be raised about both the content of the Integrated Resource Plan (IRP) for electricity currently being discussed at the National Economic Development and Labour Council (Nedlac) as a precursor to its approval by Cabinet, and the drafting and consultation processes that have been employed.
Electricity and Energy Minister Dr Kgosientsho Ramokgopa has indicated that he is keen for the updated IRP to be approved soon, given that the prevailing IRP2019 is outdated. However, his initial deadline of the end of March was not met.
The document before Nedlac is referred to variously as IRP2024 and/or IRP2025 and was drafted hurriedly late last year, with scant consultation.
This redrafting followed heavy criticism of the version, then dubbed the draft IRP2023, released in January 2024 by Ramokgopa's predecessor, Gwede Mantashe, which stakeholders rejected partly because its base case included loadshedding until at least 2027.
More than 4 300 public comments were received, and most of the substantial submissions highlighted serious problems with both the modelling and cost assumptions used, which had resulted in incorrect and potentially economically damaging conclusions.
Acutely aware of these criticisms, Ramokgopa, who was appointed Electricity and Energy Minister in the Government of National Unity Cabinet, commissioned the South African National Energy Development Institute to remodel the IRP.
The results were announced in November with a promise that the new draft would be released prior to Cabinet approval.
However, the document was released only for Nedlac consideration and not for broad consultation, despite the material changes included relative to the version released by Mantashe.
MEANINGFUL CONSULTATION?
Speaking during a webinar hosted by EE Business Intelligence, Meridian Economics MD Dr Grove Steyn said that the version currently before Nedlac not only contained technical flaws but also did not include sufficient information to enable meaningful consultation.
"Despite welcome improvements in the technology cost assumptions [compared with the draft IRP2023], overall, the input assumptions remain opaque and poorly documented," Steyn said.
"It is astonishing that the current IRP document does not show data on the technology capacity, energy mix, costs or emissions for the modelled scenarios or the 'Proposed Balanced Plan'.
"Technically this means that it does not qualify as an IRP in terms of the legal definition," he added, highlighting the requirement for policy-making to satisfy the Constitutional principle of legality, which includes a minimal rationality requirement.
Presidential Climate Commission (PCC) executive manager Lebogang Mulaisi also questioned the process, describing the Nedlac discussions under way as the "last opportunity" to influence the policy, despite ongoing concern as to whether the public consultation phase preceding it was truly meaningful.
She questioned, for instance, whether having hosted a workshop with stakeholders and experts with a day's notice could be considered as having been a meaningful consultation.
In addition, Mulaisi reported that the PCC had been struggling "to track how the consultation resulted in an amendments to the updated version".
LOGICAL FLAWS
Steyn also argued that the Proposed Balanced Plan in the document before Nedlac had not been logically derived from the underlying analysis, which only introduced nuclear when the gas build was disallowed. However, the Proposed Balance Plan included both gas and nuclear.
The outcome, thus, "forced" in technologies that were uneconomical and which would rely on public procurement, where the risk of these costs being "socialised" was high.
"South Africa's recent empirical experience with these types of projects provides stark warnings about their enormous risk for cost overruns and opportunities for rent-seeking and even corruption," Steyn said, referring specifically to Eskom's Medupi, Kusile and Ingula me...