The World Wide Fund for Nature of South Africa (WWF-SA) has raised questions about the integrity of the National Energy Regulator of South Africa's (Nersa's) hearings into Eskom's request for tariff increases of 35% a year between 2010 and 2013, as well as the intentions behind the Department of Energy's (DoE's) eleventh-hour publication of the so-called integrated resource plan (IRP).

The three-page IRP, described by some as a "tick-the-box-style" exercise, was published in the Government Gazette on December 31, 2009, outlining the source and timing of new electricity generation to be installed in the country over the next five years.

"Such a decision potentially removes the prospect for meaningful consideration of stakeholder input and interests into Eskom's controversial tariff increase applications," WWF-SA, which would make oral representations to Nersa next week, asserted in a statement.

"If this is a cynical attempt to appear to comply with the requirement of the National Energy Act of 2008 requiring that the Minister must publish an integrated energy plan every year, the department would have done better to admit a failure to deliver," stated WWF-SA climate change programme manager Richard Worthington.

The organisation noted that the Act also required the IRP, along with its underlying assumptions, to be publicly consulted on and to incorporate projections of energy demand and supply for a period of 20 years.

The current Nersa public hearings follow Eskom's revision of its initial application for a 45% increase, to a yearly 35% increase, which was based primarily on the announced deferment of building the coal-fired Kusile power station to 2014, as well as other renewable energy projects.

In the IRP, the Minister of Energy stated that new generation capacity "must be met though the projects listed in the IRP", however, the IRP states that Kusile will generate power from 2013.

The notice, published in terms of the Electricity Regulation Act, contains new build plans as put forward in a "previously leaked IRP", ignoring the delays upon which the current tariff application is based.

"This gazetting of a so-called ‘Integrated Resource Plan' makes a mockery of government policy and legislated requirements regarding integrated energy planning, in terms of both content and process," said Worthington.

"This plan for electricity supply through 2013 also claims to give effect to policy objectives for renewable energy usage, of "approximately 4% of the energy mix" and for demand-side management, though it adds nothing to the vague announcements for reinvigorated implementation made at last year's Solar Water Heating (SWH) Conference," Worthington added.

WWF-SA highlighted that Eskom has now stated it will deliver on the promised one-million SWH units, through the same subsidy programme that has failed to perform effectively since its inception. Demand side management was said to be the one area where the gazetted IRP1 differed substantially from the initial IRP proposal from Eskom, which was leaked to the media earlier in 2009.

WWF Trade and Investment Advisor Peet du Plooy said that the ‘plan', which effectively rubberstamped the leaked IRP draft, consisted of little more than an extract from one of the tables in that initial document, with modification to the energy savings expected under Eskom's Demand-Side Management programme the only new addition.

"The plan contains a number of grave discrepancies," WWF-SA said, noting that it ignored Eskom's announcement of a cost-saving delay in the building of Kusile.

It also assumed that Eskom's solar and wind projects, which have been similarly deferred, would both be commissioned in 2010.

"Even allowing for Eskom fast-tracking projects it had abandoned indefinitely, the total renewable energy capacity to be brought on-line according to the plan is 725 MW. This compares to 1 320 MW or the "equivalent [of] replacing two (2 x 660 MW) units of Eskom's combined coal-fired power stations" required by the Renewable Energy White Paper of 2003," highlighted WWF-SA.

The nongovernmental organisation also said that the IRP showed demand-side savings greater than those contained in the more complete, though secret leaked plan from September 23, 2009, rising steadily from savings of 400 MW in 2009 to more than 3 000 MW of additional savings in 2013 alone.

"The solar water heater plan will doubtless improve energy savings, but these savings are likely to amount to a combined total of 1 000 MW," it added.

The plan also showed the reserve margin as increasing from 18% to 22%, while Eskom said its reserve margin was about 8% and needed to rise to at least 15%, which is the international norm.