Extend deadline for submission of IRP comment

Since publication of the draft Integrated Resources Plan (IRP) 2023 on January 4, there has been debate on its relevance in SA’s fast-changing energy landscape. Should the government still be planning as if the state, through Eskom, continues as a major player in electricity supply 20 or 30 years from now?

That is by no means the only critique levelled at the plan which has been called unambitious at best and a complete failure at worst for not adequately addressing the energy crisis. While the industry tries to make sense of the plan, the consensus is that the deadline to submit comments on the plan must be extended.

The department of mineral resources & energy (DMRE) has been engaging with the media, industry and the broader public through virtual information sessions, but they are a poor substitute for formal public hearings, which will not take place according to the present IRP 2023 consultation timeline.

At the first of two DMRE-hosted public information sessions last week, many questions were left unanswered. The department said it will respond to questions in writing and publish answers on its website, but this has not happened yet. The department was asked to extend the February 23 deadline, directorgeneral Jacob Mbele told “technology agnostic” SA National Energy Association (Sanea) members this week. At its IRP 2023 discussion, Sanea also asked Mbele to extend the deadline.

The DMRE has indicated it will consider these requests, but with the deadline only a month away it has to decide soon.

Meanwhile, in the interest of transparency, the department also needs to publish more detailed information on assumptions it used and how it arrived at scenarios presented in the plan.

It is not clear, for example, why modelling done for the period 2030 to 2050 includes a large share of concentrated solar power (CSP) generation in its renewables-led scenario, rather than assuming all solar power will come from solar photovoltaic cells (PV), the cheaper alternative. The SA solar PV association (SAPVIA), which participated in the session hosted by Sanea, says including up to 34,000MW of capacity from CSP may be the reason the IRP modelling showed that a renewable-energy only pathway cost more than other pathways such as building nuclear power stations or new coal-fired power stations.

Perhaps the greatest flaw of the IRP 2023, as pointed out by some Sanea members, is that it assumes business as usual for the energy sector for the next three decades. The plan cannot ignore that the state will probably play a smaller role in electricity generation. The IRP should recognise this and also that more planning is needed for Eskom to provide ancillary services better, such as grid access and electricity trading platforms.

The IRP cannot, and should not, decide the policy and regulatory changes needed to prepare for a liberalised energy market and a supply mix that increasingly feature more renewables.

Any plan committing SA to expensive technologies for decades when there are better alternatives available will be disastrous for the country.