Environmental and climate groups reject government gas plan

Acollective of environmental and climate justice groups has made submissions to the National Energy Regulator of South Africa (Nersa), rejecting the Department of Mineral Resources and Energy’s (DMRE’s) gas procurement plans.

Rejecting the proposal are groundWork, the South Durban Community Environmental Alliance (SDCEA), Natural Justice, and the Centre for Environmental Rights (CER). They say the proposed plan is vague and unnecessary, and threatens the constitutional rights of South Africans. The objections are supported by Earthlife Africa, The Green Connection, 350Africa.org, Oceans Not Oil, and Project 90 by 2030.

The plan is in addition to the proposed 3,000MW laid out in the Integrated Resource Plan (IRP2019). The IRP sets out a plan to procure 1,000MW in 2023 and 2,000MW in 2027.

Organisations became aware of the plan after Nersa announced public participation on 26 August 2022 for three determinations under section 34 of the Electricity Regulation Act 2006, which DMRE minister Gwede Mantashe had proposed.

The three determinations proposed by Mantashe include renewable energy to the amount of 14,791MW for storage, solar and wind from 2024 to 2030; 1,000MW of biomass for 2023 and 2024; and the 3,000MW of gas/diesel for 2024 to 2027. The last is the determination organisations are disputing.

In a statement, the coalition argued that the proposal for gas procurement lacks adequate public consultation and key information, and is not informed by electricity needs and leastcost planning or crucial impact assessments. They also said the plan conflicts with the law and Constitution owing to unjustifiable harm posed by new gas development, lack of alignment with the Electricity Regulation Act of 2006, and specifications to Eskom’s gas-fired power station in Richards Bay.

As the country experiences high levels of rolling blackouts once again, the plan President Cyril Ramaphosa announced in July has yet to take effect. Among the announcements was Mantashe issuing determinations for additional capacity as laid out in the IRP, as well as a request for gas power as soon as possible.

The IRP states that local recoverable shale and coastal gas are being pursued and need to be accelerated, adding that the gas “could form a central part of our strategy for regional economic integration within [the Southern African Development Community]”.

However, the document adds: “Concerns and risks were also raised about the capacity provided for and practicality of gas to power in the recommended plan and the risks it poses since South Africa does not currently have adequate gas infrastructure.”

The Richards Bay Gas to Power Plant is the proposed solution to the lack of gas infrastructure. The project is also being challenged in court as groundWork and SDCEA seek to have the environmental authorisation of the plant reviewed, citing a lack of adequate public participation.

“It hasn’t been said in that many words, but the determination by … [Mantashe] and the concurrence by Nersa is almost tailor-made for the Eskom power plant [Richards Bay], in terms of location, procurer…,” said Gabrielle Knott, an attorney at CER.

“This determination wilfully ignores all evidence that gas in the future electricity mix does not form part of a least-cost electricity plan for [SA]. Any gas capacity will simply add to rising electricity costs and further exacerbate inequality and the economic downturn in [SA],” said Knott.