IRP23 under fire: why South Africans are losing faith in energy policy
The draft IRP23 was once again in the spotlight last week as the government engaged in a consultative process with stakeholders who submitted their comments on the document.
However, the focus has shifted from relying on the IRP as a tool to govern and transform South Africa's power, energy and electricity sector. Instead, attention has turned to key inputs submitted during the process, many of which question the relevance of the draft IRP23 in its current form. The document appears heavily skewed towards renewable energy, raising concerns about its potential cost implications. Yet, the process of adopting the IRP seems to persist in its stillborn state.
We are all waiting with bated breath for the final outcome of the IRP23 document. What will the Electricity Minister decide after all the consultations? Dr Kgosientso Ramokgopa faces an enormous challenge: determining the direction South Africa will take for its energy future. So far, 4 363 submissions have been made in response to the draft IRP23. By comparison, the government received 6 890 submissions during the 2018 consultation process for the draft IRP18, which was eventually adopted in 2019 and became known as IRP19.
This time, however, the number of submissions has significantly decreased. Why are there fewer contributions now compared to 2019? The answer is clear: South Africans have grown weary of investing their time and resources in processes they believe will never see implementation. The IRP energy policy has become a national joke. Since 2010, numerous IRPs have been developed, yet none have been successfully executed.
The government’s approach of gazetting and opening these policies to public comment has become a mere procedural exercise to rubber-stamp the process. Tangible outcomes remain elusive. Over the years, we’ve seen IRP10, IRP15, IRP17, IRP19, and now the draft IRP23, none of which have been implemented effectively. Every five years, the Department of Energy promulgates and gazettes these plans, without any successful implementation.
Let’s consider the costs of undertaking this massive process of gazetting and inviting public submissions. It’s no small undertaking. Consultancy firms are hired to oversee and integrate this entire process, ensuring that all the moving parts align. Significant manpower is involved to ensure the document reflects the South African energy landscape accurately.
Take IRP19 as an example: the recurring theme was an energy mix that accommodated all available energy sources. The focus was on achieving a balanced energy mix that incorporated coal, gas, hydro, nuclear, wind, solar, biofuels, biomass, battery storage and thermal power. The aim was to balance the grid while addressing transmission and frequency challenges.
For instance, in cases where higher levels of renewable energy were introduced, gas peakers served as a stabilizing force. These peakers balanced the low frequency and intermittency of renewables to match the consistent baseload power required for grid stability.
The rationale for integrating renewables was that the maximum contribution of renewables to the grid could not exceed 30% of the total 100% grid capacity. This limitation is due to the current high-voltage transmission grid infrastructure, which cannot handle more than 30% renewable energy without risking stability issues. Introducing more renewables beyond this threshold would lead to grid instability and, over time, a gradual collapse into widespread blackouts.
This underlying challenge was a major factor behind Eskom's load-shedding crisis. The then-CEO, during the years of load-shedding, pushed heavily for the Independent Power Producers (IPPs) programme. The focus was on procuring electricity from Renewable Energy Independent Power Producers (REIPPs), while much of Eskom’s coal-fired power generation fleet was left idle. The strategic shift towards a greener energy focus came at the expense of maintaining and optimizing Eskom’s coal plants.
The result was a catastrophic decline in operational efficiency. Eskom’s Unplanned Capacity Loss Factor (UCLF) - representing unplanned outages or plant breakdowns- soared to over 18 gigawatts of capacity out of operation. At the same time, Eskom’s board was largely inactive, failing to address the crisis. The singular focus on renewables, while the core coal-powered generation fleet was neglected, left Eskom in a dire state, grinding operations to a near halt.
The function and purpose of the IRP are to prevent such disasters from occurring. It is a policy document that should guide both Eskom and the private sector on where to focus their investment efforts in building new generation capacity. The IRP spells out in detail which areas the state should target with its policy instruments and capital investment for power projects, and how to prioritise spending within the energy generation sector.
It comes as no shock to realise that the state makes these huge plans, but falls short in implementing them - something South Africa is well known for.
The difficulties in implementing the IRP stem from vested interests within the private sector, particularly multinational corporations and foreign governments that have heavily invested in undermining South Africa’s policy space. These entities consistently fund side initiatives to stop, block, and frustrate any projects aimed at implementing the IRP policy.
Take, for example, the allocation for new High Efficiency Low Emissions (HELE) coal plants in the IRP. Why has the state never prioritised funding Eskom to convert its coal plants into HELE plants? There are numerous NGOs that receive substantial funding to block any projects related to coal and nuclear energy.
Consider the issue of nuclear power. Right now, several court cases are attempting to block the government’s progress on nuclear energy. Similarly, the gas sector faces a similar situation. When the state procured Independent Power Producer (IPP) projects for gas, these projects were blocked by the private sector through various pressure groups, funded NGOs, and political parties. Despite the gas IPP tenders being awarded, not a single megawatt has been added to the grid.
It is not a coincidence that only baseload IRP power generation projects -such as coal, gas, and nuclear - have failed to be implemented?
To date, all the IPPs that have been implemented are renewable energy projects—wind, solar, and, more recently, battery storage. Since the IPP office was opened in 2011, the state has procured over seven bid windows. However, no new coal, gas, or nuclear IRP projects have been added to the grid.
The last attempt to introduce 2 500 MW of nuclear power was met with huge resistance from green lobby movements, eventually leading to a court case that favoured the green movement. The courts have often been biased arbiters in this energy debate, ruling almost exclusively in favour of renewable energy IPPs. While the state has allowed for several IPP bid windows to procure gas and coal to add to the grid, all of these projects have been blocked by green movement lobby groups and advocacy organisations. You don’t need to be an engineer or scientist to recognise the deliberate sabotage of South Africa’s energy policy space.
The ruling party, our President, and his cabinet ministers should hang their heads in shame for failing to follow through and implement the policies they have enacted into legislation.
I won’t be holding my breath on IRP23 outcomes as why should this time be any different?
Crown Prince Adil Nchabeleng is president of Transform RSA and an independent energy expert.
* The views in this column are independent of “Business Report” and Independent Media.
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