Both plans were published for comment on 25 November 2016 – several years overdue – with public presentations at workshops planned to commence as early as 7 December 2016 – on little more than a week’s notice. It appears that only eight workshops in only eight cities are planned before consultation at the National Economic Development and Labour Council, a statement says.
“This despite the fact that the department has failed to make available not only all promised annexures to the two plans, but crucial documents such as the Ministerial Advisory Council of Energy IRP Working Group’s report on the IRP. Those documents that have been made available are not only extremely voluminous (amounting to many thousands of pages) but highly technical and complex.”
The grouping – comprising the Life After Coal/Impilo Ngaphandle Kwamalahle Campaign (Centre for Environmental Rights, Earthlife Africa Johannesburg, and groundWork), together with the South Durban Community Environmental Alliance, the Vaal Environmental Justice Alliance, the Highveld Environmental Justice Network, the South African Waste Pickers Association, Bopanang Bangalano, the Climate Action Group, Nthole Morwalo, and the Women Energy and Climate Change Forum – inadequate time for the public to prepare before the workshops commence – say there is simply enough time not only to peruse the documents, but to obtain expert assistance in analysing them.
The organisations will also not be able to consult with communities and other groups who are impacted by energy decisions made in terms of the IRP Update and IEP. In addition, the workshops should be much more widespread, with many more of these planned; particularly in the areas that will be most impacted by the energy decisions made in terms of the IRP Update and IEP – such as coal-impacted communities in the Mpumalanga Highveld.
The minister’s public participation plan is for written comments on both documents to be submitted by 15 February 2017, with no provision for additional written submissions to be made before the plans are finalised. The organisations pointed out that this is not lawful, reasonable or procedurally fair, nor does it accord with the constitutional requirements for public administration to respond to people’s needs, to encourage the public to participate in policy-making, and to foster transparency by providing the public with timely, accessible and accurate information.
As pointed out by the Life After Coal Campaign and Greenpeace Africa on 31 October 2016, energy decisions made in terms of these plans have significant impacts for all South Africans, and for constitutional environmental rights. “As a result, there is no room for secrecy or box-ticking: there must be full and meaningful stakeholder engagement in all stages of the process towards finalising an updated IRP.”
The organisations have called upon the minister to make the missing annexures and certain additional documents available and requested an extension of time for public comment on the IEP and the IRP Update by 31 March 2017. Thereafter, at least a further 60 days are required for comment on the different scenarios developed considering different assumptions (for example on economic development and energy demand); and at least a further 30 days for comment once the policy-adjusted IRP (which takes various government policies into account) has been determined.They asked for a response from the minister by 30 November.