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minister kubayi
Finance and Policy  
11 January 2017

DoE grants public comment extension for IEP

On Monday, the South African department of energy (DoE) announced that the closing date for written comments regarding the draft integrated energy plan (IEP) report and the Integrated Resource Plan (IRP) Update, has been extended.

On the 25th November 2016, the DoE published in the Government Gazette the Draft Integrated Energy Plan (IEP) report and the Integrated Resource Plan (IRP) Update Assumptions, Base Case Results and Observations for public comments.

The closing date for written comments was communicated as 15th February 2017.

Following requests from a number of stakeholders, the Department has now extended the public comments period to run until the 31st March 2017.

IEP: concerns around public comment

In November, the South African Renewable Energy Council (SAREC), an umbrella body representing the interests of the solar and wind industries, came out in cautious support of the 2016 update of the IEP and IRP, which for the first time since 2010, allows all stakeholders to participate in an informed debate on the choices and timings of the technology choices that will enable the delivery of affordable and sustainable energy to South Africa.

“In terms of the Department of Energy’s activity plan, such debate should culminate in the promulgation of a final IRP shortly after March 2017,” said Brenda Martin, Chair of the South African Renewable Energy Council.

Focus of IRP debate

Some questions that SAREC would like to be processed through the public participation include:

  • Whether rational planning and resulting investment choices have been made on the basis of ‘least cost’.
  • Whether all opportunities to achieve both energy and developmental objectives are being utilized. The enviable record of deployment and delivery of socioeconomic benefits means that larger allocations of technologies aligned with the achievement of South Africa’s development agenda should be considered.
  • Why the wind and solar PV prices used in the IRP base case scenario are at variance to real prices being awarded to preferred bidders in Round 4 of the REIPPP.
  • The absence of CSP technology in the IRP base case scenario without any clear explanation.

Industry views

At the time of the report's release, the South African Photovoltaic Industry Association (SAPVIA) said that it welcomes the 2016 update of the long-awaited Integrated Resource Plan (IRP).

The Association praised the allocation of 17,600MW for solar photovoltaic (PV) in the 2016 IRP update, stating that it is a step in the right direction. However, it is still less than what the sector has to offer given the abundant resources.

According to SAPVIA: “The updated IRP will give all South Africans the opportunity to interrogate the choices and cost assumptions used by the IRP planners to reach their conclusions regarding technology choices.

“Independent modelling, based on up-to-date figures from South Africa’s REIPPPP bidding rounds confirm that renewables are the best policy choice in order to meet South Africa’s energy needs at the least cost, while still maintaining our carbon obligations.”

They added: “Evidence shows that the least cost path for South Africa to achieve a sustainable, low carbon, high job creating energy mix is one that contains a large renewable energy component, supplemented with gas fire power. This renewables and gas scenario has been repeatedly seen in our BRICS partners and elsewhere globally.

“In the current fiscally constrained environment, SAPVIA believes that the additional cost of deviation from this ‘least cost scenario’ should be made public to allow policy makers to make informed value-for-money decisions.”

According to SAPVIA, the ‘build constraint’ placed on renewables should be removed in the IRP models and scenarios in order to reflect the real potential that solar technology can play. The association will examine the rationale for the current artificial cost-ineffective constraints being placed in the IRP models as it prepares its submission for the consultative process.

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