At last we have an updated IRP, but what is it really achievable?



When the IRP 2018 was published for comment in August 2018 a number of people (including me) breathed a collective sigh of relief that the hotly debated, dreaded and much anticipated large allocation of capacity to cripplingly expensive, and potentially politically tainted nuclear energy wasn’t there. 

Sue Rohrs

Don’t get me wrong, there’s a time and a place for nuclear, but that time isn’t now.  Not for South Africa with its beleaguered economy and recent rapid electricity tariff hikes.  We just can’t afford it.  Also, if you are a card-carrying no-nuker, remember that the time period in this IRP has been shortened (by 20 years).  The IRP 2016 base case document was predicated on a time line up till 2050, with the first nuclear plant being commissioned in 2037.  The IRP 2018 update spans a planning horizon until 2030.  So, if nuclear’s not on the cards, it could well be a situation of “not yet”.  We’ll have to wait and see what further updates hold in store.

At first glance, or couple of glances, apart from the relatively small allocation of capacity to renewable energy (which is my major bone of contention with the plan), it seemed as though there really wasn’t that much to comment on in the document, or anything to take issue with apart from some niggly lawyerly thoughts I had like “where is the 0 to 1 MW category that’s supposed to be in the IRP because it’s referred to in the exemption schedule to the Electricity Regulation Act?” or “how is this allocation of 200 MW to embedded generation going to work in practice and is it enough?” and “what about all the capacity contained in the applications for consent to deviation which are sitting with the Department of Energy which haven’t been processed for years?  Shouldn’t there be an upfront allocation of this capacity to embedded generation?”.

Upon further review, though, and having tried to connect the dots and piece together the bits of the document I thought should inform each other I got a bit more clarity on what the IRP did, and didn’t, have in it.

The fact that demand wasn’t going to match what was anticipated in the IRP 2010 wasn’t the least bit surprising given the state of the economy, the decline in the manufacturing industry and rapidly escalating electricity prices (amongst other things).  Nor was it a surprise that Eskom’s EAF was down to about 72%.

What was surprising was that even though it had been acknowledged that Eskom’s availability factor had been in the 70th percentile for a few years, an EAF of 80%, being the figure Eskom had agreed with its shareholder, was used for the purposes of projecting Eskom’s supply.  I wondered (and still do) what would happen if this aspirational figure was not achieved.  How does that then affect the numbers, and where is it proposed that the shortfall in electricity generation (I assume that is the result) will be made up from?  The IRP doesn’t provide any answers.

I had a similar sense when I considered the allocation of 1 GW to coal IPPs and 2,5 GW to Inga produced hydropower.  To me, and this was apart from a number of other concerns I had about the inclusion of these allocations (including their price), the biggest questions was “what if”?  What if there are delays in getting the electricity?  What if the projects don’t come off at all?  What if the environmental lawsuits against the coal IPPs are successful? What if the grid coming all the way down Africa isn’t robust enough to support the wheeling of Inga power?

What would any of this do to the time lines in the IRP and, in an extreme scenario, what type of electricity would be allocated instead of the coal and hydro?  This type of variability isn’t dealt with in the plan, and perhaps should have been.  Hopefully the allocation would be to renewable energy, but this certainly isn’t a given.

To me there seem to be a whole host of significant variables, any one of which could quite materially affect the balance of the document.  The intention is to regularly review and update the plan, but the IRP 2010 was stated to be a “living document”, to be updated every two years.  That didn’t happen, and seven years later it’s still the official plan, albeit a very outdated official plan.

To me, what is critically important is how the IRP will be implemented and managed.  If it’s really going to work properly it must be an evolving document and a full-time task team must be established to consider the variables and the changing times and technologies and to propose updates on a regular basis. If not, it’s unfortunate, but the plan won’t be anywhere near as effective as it might have been.

Contact Sue Rohrs, Rohrslaw, Tel 082 876-7453, sue.rohrs@rohrslaw.co.za

 

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