A collective of environmental and climate justice groups 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, Natural Justice, and the Centre for Environmental Rights. The collective says the proposed plan is vague, 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, while taking into account the environment, port issues and transmission. The plan adds that the additional energy “represents low gas utilisation, which will not likely justify the development of new gas infrastructure and power plants…”

Organisations became aware of the plan after Nersa announced public participation on 26 August for three determinations under section 34 of the Electricity Regulation Act 2006, which DMRE Minister Gwede Mantashe had proposed. Section 34 determinations set the guidelines and regulations for the procurement process of energy.

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

Public consultation

In a statement, the coalition argued that the proposal for gas procurement lacks adequate public consultation, lacks key information and is not informed by electricity needs and least-cost planning or crucial impact assessments.

The coalition said the plan was vague and in conflict with the law and Constitution because of unjustifiable harm posed by new gas development, lack of alignment with the Electricity Regulation Act of 2006, and lack of specifications for Eskom’s authorised (and disputed) gas-fired power station in Richards Bay.

“Energy modelling shows that renewables are the quickest and cheapest way to get much-needed capacity on to the grid. By committing to harmful and expensive gas, government is displacing this much-needed renewable capacity and the most practical solution to SA’s load shedding woes,” said Avena Jacklin, the senior climate and energy justice campaigner for groundWork.

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Curbing global greenhouse gas emissions to keep the temperature increase below 1.5°C, in line with the Paris Agreement, requires a sharp decline of one-third in fossil fuel reliance between 2020 and 2030, the latest Intergovernmental Panel on Climate Change models show. This puts the development of any new gas infrastructure at risk of becoming stranded assets; footing a bill that will long outlive its purpose.

As South Africa experiences high levels of rolling blackouts once again, the energy 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.

Read more in Daily Maverick: “Here it is: Ramaphosa’s ‘energy action plan’ to end SA’s rolling blackouts” 

The IRP states that local recoverable shale and coastal gas are being pursued and this needs to be accelerated as they have great potential. Gas, the IRP states, “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, in a landmark case, as groundWork and the South Durban Community Environmental Alliance seek to have the environmental authorisation of the plant reviewed, citing a lack of adequate public participation.

Read more in Daily Maverick: “Richards Bay floating gas power plant faces turbulent legal water”

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

She added that there were many questions around the determination, such as where the gas will come from, as well as the shortening of the public participation process on the matter, with the current bouts of rolling blackouts being used to back the fast-tracking of the process. Knott added that should Nersa not address the concerns raised by the organisations, court action would be considered.

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