a) Both, an official acting under delegated authority, and the Minister in general, exercise their powers in terms of sections 2, 24, 24E, 24K, 24N, 24O, respectively, of the National Environmental Management Act, 1998 and the Environmental Impact Assessment Regulations, when considering applications for environmental authorisations. There are no specific provisions that deal with climate change impact assessments per se, nor are guidelines currently available in respect of acceptable range, standards, or parameters against which the impacts of climate change can be measured.
In the absence of specific provisions that deal with climate change impact assessments, the Department also considered the Integrated Resource Plan for Electricity (‘IRP’) 2010-2030. The promulgated IRP 2010-2030 (2011) factors in an increase in generating capacity to meet future demand, incorporating provision for new coal-based generation, but with an emphasis on low-carbon energy sources, including nuclear power and renewables, to ensure that South Africa’s dependence on coal-based electricity generation is reduced. In line with this, the Independent Power Producers Procurement Program (IPPPP) has the mandate to procure energy from Independent Power Producers (IPP) aligned to the capacity allocated to different electricity generation sources in the IRP, including 2 500 MW from coal.
b) The cabinet approved Integrated Resource Plan (IRP) identified the preferred power generation mix required to meet expected electricity demand up to 2030. This includes a mix of power generation technologies to be pursued, including coal. The IRP was informed by, amongst other things, South Africa’s development priorities, cost of supply and demand balance required to meet the country’s electricity requirements.
c) South Africa’s Nationally Determined Contribution (NDC) is contextualised within its national circumstances and priorities, which considers both development needs and climate change imperatives. The NDC further specifies that, “in the short-term (up to 2025), South Africa faces significant rigidity in its economy, and any policy-driven transition to a low carbon and climate resilient society must take into account and emphasise its overriding priority to address poverty, unemployment and inequality”. The NDC should therefore be understood in the context of these national circumstances and priorities. Emissions from the two coal IPPs are within the “Peak, Plateau and Decline” range - taking the timetable for the retirement of the current plants into account. Thus, the approval of these two coal IPPs does not lead to South Africa contravening its commitment to the Paris Agreement.
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