IRP 2023 is sloppy, inaccurate and out of date – tear it up, says Outa

The draft Integrated Resource Plan 2023 (IRP 2023) the Department of Mineral Resources and Energy released for public comment in January is sloppy, inaccurate and out of date. The IRP is supposed to be a key document for South Africa’s national long-term electricity planning, but it is so inadequate that it makes a mockery of the public engagement process.

“Tear it up, start again and do it properly,” says Wayne Duvenage, CEO of Outa. “It is Outa’s submission that the current draft Integrated Resource Plan 2023 (IRP 2023) contains a number of significant acknowledged errors, omissions and inadequacies and therefore should be recalled, reworked and reissued for public comment, with adequate time for a meaningful consultation process, including a series of public hearings around South Africa.”

Outa believes that government has not taken this process and the need for regular updates and constant analysis seriously, which is why the country is faced with the current electricity supply shambles.

The public only had time until 23 February to comment, but the department then extended the public comment deadline to 23 March 2024.

However, Duvenage says, this is still hopelessly inadequate, as were the department’s briefings to the public, along with the lack of public hearings where the public could ask questions and make submissions about the plan.

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Outa’s submission despite tight deadline

Despite the tight deadline, Outa made a submission to the department on IRP 2023 and believes that the corrections to the IRP 2023 will have to be so substantive that it will require another round of public engagements once the assumption data is more accurate and transparent.

“We initially called on the department to extend the comment period by two months to give the public a reasonable opportunity to consider this very technical plan. However, in Outa’s submission we say that we now believe that this IRP 2023 document should be reworked, using the input provided from credible critics and scenario planners before it is republished for a more meaningful public commentary and engagement process,” Duvenage says.

He emphasises that the IRP should be a detailed plan which considers:

• detailed information, including economic assumptions
• the existing power generation fleet performance and decommissioning schedule
• better defined generation technology options and costs
• various possible generation scenarios
• the required electricity demand and;
• the least cost to society.

Outa notes in its submission that the plan that was initially gazetted contained acknowledged errors, requiring changes and therefore, needed reworking. However, Duvenage says, these corrections and updates are not reflected in the current version.

“The serious errors, omissions and changes required in input assumptions, technology costs and available capacity resulted in erroneous conclusions and observations in the Draft IRP 2023 that are not supported by the facts,” Outa says in its submission.

Duvenage says it becomes an almost futile exercise to comment on such a poorly compiled IRP 2023 document.

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Serious errors and omissions in IRP 2023

Some of the errors and omissions Outa noted in its submission include:

• Inadequate and out-of-date technology costs
• The use of fixed technology costs which do not consider the likely cost reduction over the study period to 2050, especially given that international studies indicate that the cost of renewables and batteries are expected to decline
• The amount of renewable capacity projected to be installed by the private sector and individuals appears to be underestimated
• The plan includes the three Karpowership gas-to-power ships, although these are no longer on the table
• There are unrealistic constraints on new renewables
• A fixed gas fuel price was used although this is not realistic and the rand/dollar exchange rate is not considered
• The impact of the hydrogen economy, green hydrogen and electric vehicles is inadequately addressed
• Economic assumptions are missing or inadequate
• Construction time and phasing for technology construction is largely missing
• There is no information on delaying the decommissioning of power stations, or on the recommendations of the VGBE consortium report on Eskom
• Electricity price trajectories are missing for various scenarios
• The carbon emission constraints and minimum emission standards constraints are missing and
• There is significant misalignment with existing legislation, regulations and policy.

Duvenage also points out that Meridian Economics, a highly respected and professional scenario planning organisation, in its review of the IRP 2023 further highlights reasons why the IRP 2023 is not adequate or transparent and arrives at incorrect and economically damaging conclusions.