4. Energy Policy

4.1. IRP

  • The EIUG submitted its comment to the Department of Energy (DoE) on 31 March 2017.
  • Key comments in the EIUG submission include:
    • DoE draft IRP2016 uses overly optimistic energy demand scenarios. There is, therefore, a case to be made to delay high-risk decisions on construction of large, centralised, baseload, power generation plants.
    • There is no rational basis for the annual caps placed on renewable technologies in the Draft IRP2016.
    • The country needs reliable electricity supply at the lowest possible cost, delivered by a build plan using technologies that offer diversity and flexibility to match the vagaries of demand.

The EIUG submitted its comment to the Department of Energy (DoE) on 31 March 2017. The comment has been uploaded onto the public website as well as onto the portal, along with other key stakeholder submissions. The EIUG comment was also extensively referenced by mainstream media reporting on the IRP, and included in the list and summaries of highly critical responses compiled by Chris Yelland at EE Publishers. This article includes a good summary of the EIUG submission as follows:

The submission by the EIUG says proven cost and time overruns, stringent safety requirements, a lack of a national capacity to manage large-build projects and the inflexibility of large nuclear power projects need to be properly considered in the planning of any future nuclear build programme.

Given a growing surplus in generation capacity, with additional energy coming online from omitted Eskom and IPP projects, as well as slow economic growth and severely reduced industrial demand for electricity, South Africa should rather focus on stimulating economic growth, and delay high-risk decisions on construction of large, centralised, base-load, power generation plants.

The EIUG believes that should the trends of weak economic growth, rising electricity prices, weak international commodity markets, reducing energy intensity and declining electricity demand continue, it is unlikely that the national electricity energy demand in South Africa, which is still below 2007 levels, will grow anywhere near the rate forecasted in the Draft IRP2016.

The EIUG has significantly lower electricity demand growth outlook compared to what it considers the overly optimistic forecast used in the IRP 2016. The EIUG believes the price elasticity of industrial demand needs to be understood, and an energy mix providing least cost and lowest risk is required.


The EIUG is preparing a set of infographics outlining the key messages from the comment on the IRP. The final graphic will be shared with all members, stakeholders and the public.