Summary of the main points covered within our submission: Social & Economic Justice, Land Agriculture & Water, Youth, Education and Health & Wellbeing.
1. Social & Economic Justice
The IRP includes a criterion of ‘least cost to the consumer’, yet universal access to electricity has not been considered. Tariff structures which make the poor pay most, whilst large industries benefit from subsidised rates need to be reviewed.
The drive to provide cheap electricity to support economic growth is flawed in that it invariably leads to high consumption of energy and energy intensive lifestyles, which in turn leads to escalating greenhouse gas emissions. Energy efficiency should be a primary focus of the IRP.
We call on government to use the Human Development Index (HDI) rather than GDP as a guage of economic growth.
Areas where households are currently not connected to the grid and are unlikely to be in the foreseeable future could benefit quite quickly from a distributed electricity system (hybrid island solutions), which are more cost effective. These types of solutions are excluded from the IRP.
The excessive demand forecast underpinning the draft IRP will lead to a costly implementation of unnecessary large scale infrastructure at a time when we still need to address deep levels of poverty and inequality in South Africa. This in turn will create overcapacity and probably end up as stranded investments in years ahead - just as happened in the 1980s and early 1990s. We are in the position to avoid the repeat of such a future waste of limited resources NOW.
An (Renewable energy)
RE industry, which supports local manufacturing and engineering has a
bigger job creation potential, both on short, mid and long term, including exports within th region and to overseas markets.
The advisory technical committee to the IRP process is loaded with business interests and there is no civil society representation.
All advisory boards and technical committees of government need to represent the diversity of the population; e.g civil society, poor communities, labour, health and gender-focused organisations need to be represented and endowed with the same voice, weight and powers as others on these committees to allow a fair and balanced consideration of the many options available for planning.
Financial risk of nuclear and large-scale, centralised power stations:
The risk of significant cost escalation as clearly evidenced by numerous past and current global nuclear and coal power plants (e.g. Medupi) is not addressed in the draft IRP. South Africa can avoid these risky options by investing in incremental proven RE technologies and intensifying research & development for RE and by investing in good Energy efficiency campaigns that drive behaviour change.
2. Land, Agriculture, Water
Considering the climate change and temperature increase already evident and affecting water supply in Southern Africa,
the IRP criterion of lowest water consumption is greatly under-estimated.
Not only consumption, but water quality and pollution should be an input criteria for the IRP. The impact on water through all mining industries (acid mine drainage), for example should be considered.
RE technologies, do not require the same dedicated land-use zones as coal and nuclear. Solar and wind technologies can be widely distributed. Wind Turbines can be placed along-side roads or incorporated within grazing land, for example. Solar power plants can be placed on land that is too dry to cultivate, and solar water heating can be installed easily on all the available roof spaces in suburbs and industrial areas.
By adding on smaller scale RE electricity sources alongside existing grid infrastructure, the supply of electricity can be boosted without the need for the large, additional expense of transmission lines and the increased land-use that this involves.
3. Youth
The consideration of impacts of electricity choices made today on future generations is not represented within the draft IRP.
Future generations will have to solve and pay for the problem of safe long-term nuclear waste storage, a problem for which there is currently no solution world-wide.
The IRP should take potential future carbon-taxation into account in its cost estimates.
4. Education
The huge government investments in unnecessary power-stations could be better spent on education and health systems.
Imagine what might have been done with the billions wasted on the PBMR project.
5. Health & Well-being
RE does not have the impacts on health associated with coal and nuclear.
Bold Energy Efficiency Demand Side Management (EEDSM) and RE investment, without nuclear and additional coal is by far preferable from a health risk perspective.
Make your voice heard - make a submission to the IRP2010 process by Friday December 10th. Find the questionnaire template at www.doe-irp.co.za; Email it to
[email protected]
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