Following wholly inadequate public consultations, stakeholders have submitted their written comments on the Department of Mineral Resources and Energy’s (DMRE’s) draft Integrated Resource Plan.

Dubbed IRP 2023 despite having only been released in early January 2024 following months of delay, the deadline for written comments was extended from February 23 to March 23. This, after the DMRE steadfastly refused to hold public hearings on the plan in a move that was shocking yet unsurprising.

Shocking, because the draft deviates so significantly from the prevailing IRP 2019 and contains outcomes that cannot be credibly defended when held up to the electricity realities unfolding locally and globally.

Unsurprising, because the DMRE has, in the image and likeness of its political principal, become notoriously defensive and contrarian over the past five years, to the point where it is often out of step with the reform agenda being pursued by the Cyril Ramaphosa administration.

Serious electricity system specialists were left with far more questions than answers when the draft IRP 2023 dropped with the bombshell that the modellers had decided to refrain from catering for system adequacy and had, instead, allocated for ongoing loadshedding until at least 2027.

They scratched their heads at the assumptions used, including technology costs that bore no relation to domestic procurement costs and were punitive against wind, solar photovoltaic (PV) and batteries, yet largely accommodative of imported gas, nuclear, so-called clean coal and concentrated solar power.

It also became immediately apparent that yearly build limits had been placed on the leading renewables technologies, which capped solar PV at 900 MW and wind at 1 720 MW in the plan’s Horizon 2, covering the period from 2030 to 2050. Yet, neither the document itself nor the associated supporting documents released to offer insight into to the assumptions employed explained or justified these in-built constraints.

In what was arguably the most detailed and technically thorough response to the draft IRP 2023, Meridian Economics described the build limits as “inexplicable”. It argued that these unrealistic constraints, together with overpriced renewables, had resulted in a gas-heavy plan that also took Eskom’s delayed coal decommissioning “as given”, notwithstanding the environmental and policy impacts.

Meridian argued that serious problems with the IRP 2023’s modelling and cost assumptions had resulted in “incorrect and economically damaging conclusions”.

This excoriating assessment was shared across various other written submissions, which were also generally sceptical about whether the plan could be redeemed through a department-led panel- beating exercised to integrate some of the objections and suggestions.

Several stakeholders have, thus, called for either a significant overhaul or for the plan to be withdrawn and reworked, with the help of independent electricity system planners.

Given the DMRE’s recent history, few will be surprised if these calls are likely to fall on deaf ears.

Unless the document is significantly revised, however, even fewer will be amazed when the document finds itself stuck in subsequent National Economic Development and Labour Council or Parliamentary processes as was the case with previous aborted update attempts.