SAREC
Noupoort Wind Farm. credit: SAREC
Public comment submissions on the IRP2016 will be closing on Friday 31 March.

In South Africa, public participation for SA’s Integrated Resources Plan 2016 update report (IRP2016) has been encouraged, and according to vested stakeholders, it is an ideal opportunity for citizens to sway the long-term investment choices that will serve the country up to 2050.

Chair of the South African Renewable Energy Council (SAREC), Brenda Martin, said:  “We don’t often have an opportunity to influence government policy, so this is a significant moment, not just for the energy industry, but for all South Africans.”

SAREC welcomes participation

The energy council noted that the IRP2016 is outdated by three years, which is heavily overdue for an environment that is changing at a rapid rate.

Having invited public input, the Department of Energy (DoE) has a moral obligation to consider all recommendations received.

“The general public have become well informed as to the long-term implications of various power supply options and are thus well-placed to influence the energy investment choice pathways up to mid-century,” added Martin.

SAREC’s submission indicates that the IRP process should be a purely techno-economic exercise providing rational input into the policy debate.  Read more…

“The 2016 update process itself has detracted from the valuable capacity of the IRP modelling tool to identify the cost-optimal build and technology mix for the South African economy; this mix could result in electricity price competitiveness and tariff affordability,” stated Martin.

SAREC believes that renewable energy can play a significant role in the re-industrialisation of the country, transitioning away from the carbon-based minerals energy complex towards a more sustainable future. Read more…

A scheduled, consistent renewable energy programme, which includes all available renewable energy technologies combined with a gas-build programme provides an opportunity to drive and sustain a power system which re-skills mineworkers to undertake 21st century jobs and economic opportunities.

Value of public participation

According to the energy council, achieving a sustainable future requires a shared commitment from government, citizens and the industry – a commitment that extends beyond policy and planning, into practice. South Africa’s renewable energy industry is ready to take up the challenge.

Specific SAREC inputs to the IRP2016:

  1. The least cost, unconstrained scenario of the IRP should always be the default Base Case scenario. This does not mean that it should be the final policy adjusted version, but it is the one against which all artificial or policy-imposed constraints can be robustly measured.
  2. Modelled scenarios deviating from the least-cost, unconstrained scenario should be published by the DoE, in order to facilitate an informed debate.
  3. Any limitations imposed by the DoE on the annual build of renewables should be accompanied by rational explanations. Wind and solar PV were the only technologies with annual build constraints in the IRP Update Base Case.
  4. DoE have failed to set out a credible argument for the use of annual build limits for wind and solar PV.
  5. Rational methodologies should be applied to the various generation technologies used in the IRP pricing assumptions. The current process effectively imposes a policy-adjusted scenario on electricity stakeholders and customers, with no allowance for transparent engagement on long term tariff effects. This could be regarded as an attempt to stifle debate and could result in undermined public confidence in the veracity of the IRP process.
  6. We note that Concentrating Solar Power (CSP) was completely excluded and there is no allocation for CSP in the Draft IRP2016 generation mix up to 2050. This seems to have been based on modelling assumptions that are outdated, do not reflect the current market reality, and do not acknowledge the dispatch ability and operational flexibility of CSP power stations.
  7. The IRP process should adhere to predictable timelines and should draw on the best possible independent modelling resources. For instance, the continued lack of explanation for adoption of the IRP2013 Update report is unacceptable; independent research institutions should be included in the modelling process.
  8. Finally, SAREC recommends that the IRP model should deal with the following factors:
  9. Externalities such as decommissioning costs;
  10. A review of the setting of price assumptions for various technologies in the IRP.
  11. The risk of cost overruns and time delays, particularly on mega projects.
  12. The potential for public investment savings on embedded generation vs investment in mega projects.

 

 

 

Featured image: SAREC

Comments are closed.