Formal comments on the Draft Integrated Resource Plan (IRP) 2018

Abstract

As described in the Electricity Regulation Act No. 4 of 2006 and regulations in the Electricity Regulations for New Generation Capacity published in 2009; the Department of Energy (DoE), the system operator (Eskom) and National Energy Regulator of South Africa (Nersa) are responsible for the development, publication and updating of the national level long-term electricity sector plan known as the Integrated Resource Plan (IRP), which includes adoption of the planning assumptions, determination of the electricity load forecast, modelling and scenario planning based on planning assumptions, determination of a base plan derived from a least-cost generation investment requirement, risk adjustment of the base plan and approval/gazetting of the plan. Although not explicit, due to the broad implications of the IRP, it is typically consulted on via various engagement cycles (including public consultations). As part of the IRP update process, the DoE engages in a multi-stage stakeholder engagement process (including public engagements) to ensure all affected stakeholders are consulted including national and local government, business, organised labour and civil society. The most recent approved and gazetted version of the IRP is the IRP 2010-2030. An update to the IRP 2010-2030 was published in 2013 but this was never approved or gazetted. The input assumptions and base case of a further updated revision of the IRP (the "Draft IRP 2016") was published by the DoE for comment in October 2016. This revision included updated input assumptions including demand forecasts, existing plant performance, supply technology costs, decommissioning schedules and newly commissioned/under construction as well as preferred bidder power generation capacity. The time horizon for the Draft IRP 2016 was 2050. Some preliminary results were also shared in the form of a proposed Base Case and two other selected scenarios. As part of the Draft IRP 2016, the CSIR engaged in the public consultation and submitted comments primarily related to establishing a Least-cost Base Case, technology new-build limits (on solar PV and wind) and aligning costs to the latest Renewable Energy Independent Power Producer Programme (REIPPPP) Bid Window outcomes. As part of the Draft IRP 2018 update process, building on the Draft IRP 2016 and comments received, the DoE has requested for inputs from the public. Similar to the previous submission made by the CSIR, this submission is a contribution to better understanding and improving on the current Draft IRP 2018.