The Draft IRP2010 has now been developed by the Department of Energy (DOE);
the National Energy Regulator of South Africa (NERSA) and the System
Operator within Eskom Holdings, in accordance with the Electricity
Regulations on New Generation Capacity, August 2009, promulgated in terms of
the Electricity Regulation Act, 2006 (Act No. 4 of 2006).  Following the
publication and broad consultations on the IRP Input Parameters in June
2010, the DOE and its counterparts have spent the past four months
conducting the requisite modeling and scenario analysis towards developing
the Draft IRP2010.   The DOE hereby publishes this Draft IRP2010 for public
consultation and comment, for a thirty (30) day period commencing 8 October
2010 and ending on 10 November 2010.

The following documents can be found on the www.doe-irp.co.za website:

1.    Draft IRP2010;

2.    Executive Summary to the Draft IRP2010;

3.    Medium Term Risk Mitigation Plan (as part of the IRP development
process an Executive Medium Term Risk Management Plan was developed to
address the short to medium terms risks of the current electricity supply
shortage. This plan aims to quantify and clarify the nature and the extent
of the short-term supply risks and provide a quantum for immediate
interventions to avoid load shedding); and

4.    A prescribed questionnaire template, which you are kindly requested to
use to submit your comments.

You are requested to note the following process going forward:

i           Your comments submitted in the format of the prescribed
questionnaire should be emailed to the DOE, Ms Angelique Kilian at
irp2010@mweb.co.za, by close of business on 10 November 2010.

ii          Public Hearings on the Draft IRP 2010 will be held in the first
week of November 2010.  You will be advised of the precise date/dates in due
course.  Should you wish to make a presentation at the Public Hearing,
kindly indicate so to Ms Angelique Kilian at irp2010@mweb.co.za by 18
October 2010 with final submission of presentations on 29 October 2010.  (No
update to presentations will be allowed during Public Hearings.)

iii         All comments once received, will be logged and duly considered
and the Draft IRP2010 revised as necessary.

iv         Given that there is a dire need to make investment decisions
against the IRP2010 this year, the intention is that the revised Draft
IRP2010 will be tabled in Cabinet for approval prior to being published in
the Government Gazette by the Minister of Energy by the end of this year,
for implementation, in accordance with the Electricity Regulations on New
Generation Capacity.

Should you battle to download any of the documentation, please do not
hesitate to contact me.

The DOE wishes to thank you for your interest and participation in this
pivotal instrument to support our long term planning requirements for
electricity supply.

Thank you!

Kind regards,
Angelique Kilian
PROJECT MANAGER
Tel:  +27 12 444 4369
Cell:  +27 72 473 9519

All charges against the three activists from the APF and Earthlife who were assaulted, arrested and subsequently charged with public violence and resisting arrest at yesterday’s NERSA hearings, have been unconditionally dropped by the state prosecutor. The dropping of the charges came after the activists were kept locked up in police custody for over eight hours.

None of this comes as a surprise to either the APF or Earthlife since there was no ‘case’ against the activists in the first place. Indeed, the only case to answer is that emanating from the completely outrageous conduct of the SA Police Services, which has unfortunately become a hallmark of many police actions at events and protests involving community organisations. The APF and Earthlife – alongside other community organisations and social movements – will continue to vigorously oppose ESKOM’s application for multiple electricity tariff increases. We will not be silenced!

For further comment/information contact: Ferrial Adam of Earthlife on

0741813197

This morning, the NERSA public hearing into ESKOM’s application for tariff increases got underway at Gallagher Estate in Midrand. Both Earthlife and the APF were present, having made written submissions and requests for presentations in opposition to ESKOM’s application. Not long after proceedings began, a small group of Earthlife activists silently placed several posters on the walls inside the venue. Almost immediately, Gallagher Estate’s private security personnel arrived and tore down all the posters, whilst forcibly escorting those activists identified as the ‘perpetrators’, outside the venue. They then locked the doors and when a larger group of APF activists arrived, refused them (alongside the Earthlife activists already outside) entry.

Despite repeated attempts by these activists to point out the public nature of the hearing, and thus their right to attend, the private security personnel continued to lock them out. When the gathered activists then started toyi-toying, the SA Police Services were called. Three of the APF/Earthlife activists tried to reason with the police and to inform them of their democratic right to participate in the public hearing going on inside the building. The police then assaulted, arrested and hauled them off to the Midrand police station where they were charged with public violence and resisting arrest. The names of the three activists are Makoma Lekalakala, Mashao Chauke and Nomaliza Xhoma. At present they are being held at the Midrand police station while a lawyer engaged by Earthlife and the APF continues attempts to get the charges dropped.

For further comment/information contact: Ferrial Adam of Earthlife on

0741813197

21 January 2010

CANE is a coalition of organizations and individuals opposed to the use of nuclear power in South Africa.

CANE opposes Eskom’s proposed electricity tariff increases based on the information and policy given in the Integrated Resource Plan (IRP) 2009 Preliminary Report. The National Energy Act (2008) requires the Minister of Energy “to provide “any data and information reasonably required for the purposes of conducting analysis required for energy planning from any person”. A small extract from the IRP was gazetted on 31 December 2009 and covers the period 2009-2013. It is clear from the Preliminary Report that almost all of the analysis and planning was done by Eskom. This is explicitly stated: “in the absence of a…state-driven governance process for the development of the IRP, the IRP was developed predominantly by Eskom…”[1]. This raises a conflict of interest. Eskom should contribute to the IRP but should not be driving it. The Department of Energy has undertaken to initiate a process of reviewing IRP 1 to allow for consultation with stakeholders, due to commence in January 2010[2], so we trust that we and other organizations and individuals will be consulted in the drafting of a more balanced, policy-driven IRP 2.

IRP 1 is based on the assumption that “[electricity] demand growth is expected to…average 3.2% a year over the 20-year planning horizon.”[3] 3.2% compounded annually implies a doubling of capacity over the 20-year period. The assumption that demand grows relentlessly and that the response is to provide ever more capacity is like putting the demand cart before the policy horse and this is going to be economically and environmentally unsustainable whether it is funded by price increases, borrowing or taxes. The limits to growth set by resource depletion and environmental destruction are already upon us. Cheap fossil fuel, which has powered industrial growth from the start of the industrial revolution up to now, is coming to an end, if it has not done so already. The idea of supplying ever increasing quantities of electricity is completely at odds with what is required now, a policy of energy efficiency and the elimination of all forms of wasteful use of energy. If Eskom has to charge much more for electricity in order to pay for new generation capacity then an equally ambitious energy efficiency strategy needs to be in place as well. This is not the natural function of of Eskom, a power supply monopoly. It is the function of government. Energy efficiency, energy productivity and a strategy to achieve this needs to be at the heart of IRP 2.

Energy productivity is a win-win option. Improvements in energy productivity are far more cost-effective than expansion of power generation. It is entirely possible for energy productivity to substitute for new generation capacity over the period 2010 to 2030 at 20% of the cost of new generation plant.[4] Energy productivity which uses existing energy for more output has no negative impact on the environment, climate change or water supply. On the contrary it has a positive impact and frees up financial resources for other uses. Energy productivity could create many more sustainable jobs than building and operating new centralised generation plant. The IRP commits to 1 million solar water heating installations over the 20 year period. this might save the capacity of one coal-fired power station. This is a start, but much more can be done: like replacing inefficient motors and machines with much more efficient ones, environmentally upgrading buildings, and changing to combined heat and power at large factories and intensive energy users. What is required is a practical strategy and the political will to carry it out.

Eskom plans to meet the projected increased demand over the period by building new coal-fired power stations and the returning to service of out of use power stations. It is intended to save only 3225MW of capacity by 2020 through demand side management[5] out of a total projected peak demand range of 60 000 MW – 66 000 MW. This gives a very low target of 5% for demand side management. The low target is a result of Eskom’s weak incentive and constrained ability, as a supply monopoly, to stamp out wastage and implement energy productivity strategies. The total generation capacity required by 2020 is then calculated from this weak demand-side target.

IRP1 states that “the independent power producer[s] are expected to provide additional capacity in the medium term” and also that “the IRP is developed on the basis that the country builds capacity to meet expected growth at minimum cost (inclusive of externality impacts).”[6] If these statements were translated into action then there would be a much greater amount of generation capacity supplied by Independent Power Producers using renewable energy and micro-generation.

UCT’s Energy Research Centre has shown in a recent study[7] that we can reach a 15% renewable target by 2020 and “combined with an energy efficiency programme, average electricity costs will be lower than the baseline for most of the 2015-2020 period.”  Yet the presently committed capacity of renewable energy from independent power producers under the REFIT (Renewable Energy Feed-In Tariff) scheme is only 725MW (400MW from wind and 325MW from “other”).[8] This present commitment is just 1% of total capacity projected for 2020 and only 4% of new build over the period. There are proven wind resources in South Africa[9] to provide constant wind energy when spread across various locations.  There is a proposal in the IRP to introduce Concentrated Solar Power (CSP), but only starting in 2021. This is too late and we need to kick-start CSP now. South Africa has the best solar resources in the world, so this is an opportunity not to be missed: South Africa could become a world leader in this technology. The  Energy Research Centre study has shown  the cost of electricity from concentrated solar power coming down year by year due to ‘technology learning’ until it becomes the cheapest form of electricity from about 2025. This is also good for jobs. Our motor car production lines could easily be converted to solar and wind turbine technology. The IRP does not even go into the socio-economic impact of the IRP and the opportunity costs of the various decisions. The economic impact is “still outstanding”.[10]

Up to 2020 the bulk of new generation capacity according to the IRP is to be coal. From 2020 to  2027 Eskom plans to build a ‘fleet’ of nuclear power stations of 11 500 MW in total. The best most recent cost estimate for nuclear plant construction is a nominal (2008) overnight capital cost of R33 million/MW[11] and a real cost of capital of 14.5%[12] reflecting nuclear’s high risk. But the cost of new nuclear build is not standing still, rather it has been rising by about 12% a year in real terms over the period 2003-2010.[13] At this rate, real costs over and above inflation double every 6 years, so if this continues the overnight cost of each MW of the nuclear ‘fleet’ after 2020 is likely to reach well over R66 million giving a total of R380 billion in 2008 Rands and then calculate 14.5% cost of capital compounded on top of that. I can’t do the sum but the real figure must be heading towards the R1 trillion level in today’s Rands. Such a level of debt would sink Eskom into a debt black hole. Is this the real reason for the huge price increases asked for? From the tables of capacities and costs (Appendix C) it is impossible to determine what costs are attributed to nuclear power out of the cumulative totals, as case by case costs are not given. The ‘moderate’ level of confidence for cost for nuclear of +1 given in the Risk Rating[14] is pure whistling in the wind. Even the Director for Strategy and Research at the World Nuclear Association cannot work out or predict the cost of a nuclear power plant.[15]

What we do know for sure is that costs of nuclear plant are escalating while the costs of renewable energy technologies are coming down and the costs of energy efficiency and energy productivity are negative because they release funds towards other projects.

CANE rejects nuclear power as a source of energy in South Africa now or in the future. Apart from the cost, the other negating factors include the proven health risk[16],the unsolved long-term high level waste problem, the pollution of ground water through uranium mining and the very poor fit with the type of skills available and the small number of jobs relative what could be achieved from renewable energy technology and energy efficiency and energy productivity strategies. The other intractable problem with nuclear power is the risk of nuclear proliferation, and the undesirable type of security state that would have to be reconstructed to try to safeguard the entire nuclear fuel cycle from beginning to end (and for high level radioactive waste there is no “end”). For all these reasons, nuclear power is not the answer to coal and carbon emissions. Funds diverted to nuclear power means less funds available to quicker and cheaper options, which is the huge opportunity cost when one excessively large project is chosen over multiple smaller ones.

While it is accepted that electricity prices must rise to allow for improved capital infrastructure and for energy productivity strategies, we do not accept any increase based on the present Integrated Resource Plan. There should be a much greater commitment to energy efficiency and energy productivity and a commitment to at least 15% renewable energy by 2020. As this can be supplied by the IPP’s, the capital invested would be at no up-front cost to Eskom. Rather, Eskom should commit their funds to upgrading their distribution infrastructure, expanding up to the solar fields of the N Cape and employing smart grid technology in order to manage the various energy supplies. Another 15% of capacity should be saved by energy productivity. Renewable energy, energy productivity and simply eliminating waste are the real answers to carbon emissions. Eskom cannot be allowed to write its own terms of reference and base its price hikes on that. The IRP needs to be re-drafted, to include policy for energy efficiency and for jobs and skills, to actively encourage independent power producers, and to eliminate the nuclear power financial black hole.

Written by:

Rod Gurzynski. For the Coalition Against Nuclear Energy

BA (Economics) B. Arch (UCT)

rod@boma.co.za

Tel: 021 789 2023.

[2] Integrated Resource Plan for Electricity. Government Gazette 31 Dec 2009. Pg 10.

[3] Integrated Resource Plan for Electricity. Preliminary Report Sept 2009. Pg iv.

[4] McKinsey Global Institute. The Case for Investing in Energy Productivity. Feb 2008. Pg 12. http://www.mckinsey.com/mgi/reports/pdfs/Investing_Energy_Productivity/Investing_Energy_Productivity.pdf

[5] Integrated Resource Plan for Electricity. Preliminary Report Sept 2009. Table 14 – Expected DSM outcomes. Pg 45.

[6] Integrated Resource Plan for Electricity. Preliminary Report. Sept 2009. Pg 4.

[7] Costing a 2020 Target of 15% Renewable Electricity for South Africa. Marquard et al. Final Draft. Energy Research Centre UCT. Oct 2008

[8] Integrated Resource Plan for Electricity. Preliminary Report Sept 2009. Committed new capacity. Table 3 Pg 9.

[9] Costing a 2020 Target of 15% Renewable Electricity for South Africa. Marquard et al. Final Draft. Energy Research Centre UCT. Oct 2008.

[10] Integrated Resource Plan for Electricity. Preliminary Report. Sept 2009. pg 29.

[11] Business Risks and Cost of Nuclear Power. Craig Severance. Jan 2009. Appendix A: Most Likely case. The most likely overnight cost is $4 070/kW before escalations and excluding cost of capital. $4 070 x exchange rate  $1-R7.29 = R29 670 x CPIX adjuster 167.3/150.3 = R33 026/kW.

[12] Business Risks and Cost of Nuclear Power. Craig Severance. Jan 2009. Appendix A: Most Likely case.

[13] Centre for Energy and Environmental Policy Research. Update on the cost of nuclear power. May 2009.  Pg17. http://web.mit.edu/ceepr/www/publications/workingpapers/2009-004.pdf

[14] Integrated Resource Plan for Electricity. Preliminary Report. Sept 2009. Pg 58.

[15] Escalating costs of new build: what does it mean? Nuclear Engineering International. Aug 2008.

http://www.neimagazine.com/story.asp?storyCode=2050690

[16] International Journal of Environmental Research and Public Health. 2009. Article: Very low dose fetal exposure to Chernobyl contamination resulted in increases in infant leukemia in Europe and raises questions about current radiation risk models.  Christopher Busby.

http://www.mdpi.com/1660-4601/6/12/3105/pdf