As the government appears to be steamrolling down a path of nuclear energy procurement yet again, the lack of effective public participation signals worryingly weak democratic processes.
When the finance minister reveals the Budget on Wednesday, we predict we will not hear what Treasury and the Finance Ministry are doing about more costly and unnecessary nuclear energy plans. The President’s State of the Nation Address (Sona) too was conspicuous in its omission of nuclear energy as a part of South Africa’s future energy mix. Instead, he focused on renewables and finding ways to address our current energy crisis.
Yet, we know from recent developments that the government has been pushing ahead with its nuclear plans, despite nuclear being one of the most expensive electricity generation options, and despite the fact that no more nuclear is needed.
The government’s lack of transparency, coupled with its inability to demonstrate how we can afford or why we need more nuclear energy, means citizens will again bear the brunt through higher energy bills and continued above-inflation increases in Eskom tariffs.
While the President’s Sona and Wednesday’s Budget speech should emphasise the importance of a reliable energy system – by making a firm commitment to improved decision making, transparency and accountability mechanisms – there is still too much secrecy around South Africa’s energy planning.
In terms of the Integrated Resource Plan (IRP), which lays out our energy choices, this risky and outdated technology is not even identified as a necessary part of the solution to the energy crisis. Renewable energy is significantly quicker to install, and more cost effective. The minister’s new push for nuclear energy comes in the form of a Section 34 Determination for 2,500MW new nuclear power, for which the National Energy Regulator of South Africa (Nersa) is hosting a hearing on 23 and 24 February. A Section 34 Determination is a policy instrument that should be used to enable energy procurement in line with IRP 2019. However, this one is not in line with the IRP.
Following the Southern African Faith Communities’ Environment Institute’s (SAFCEI) request according to the Promotion of Access to Information Act 2 of 2000 (PAIA), we remain particularly concerned about the government’s inability to provide approved feasibility studies, business cases or research study reports on the proposed use of new nuclear power and its potential impact on the environment and local communities. And, with recent reports of cracks in the containment structures at Koeberg Nuclear Power Station, can we believe the National Nuclear Regulator (NNR) when it claims these are not serious, when these reports have not been provided?
Our concerns are not just about the lack of transparency and information. How decisions are made about our energy systems is an ethical and moral issue that should concern us all. As a multifaith environmental justice organisation, we believe the government needs to be accountable to citizens who elected them, and engage in meaningful consultation with the public on these important decisions.
We have been given little information about the plans for nuclear power and how it could affect South Africans. Even after numerous PAIA requests for feasibility studies and other information, we have received no substantive information. This means the general public does not have the information it needs to make informed decisions about these plans. Yet, as per the Constitution, we have a right to access information that should be in the public domain.
Nersa issued a consultation paper calling for the public to comment on whether or not the regulator should agree with the determination made by the mineral resources and energy minister, in terms of Section 34(1) of the Electricity Regulation Act 2006, to procure 2,500MW of new nuclear power in South Africa. The deadlines for written and oral submissions were 5 and 19 February, respectively, a rushed process for such a major cost implication and far-reaching decision.
Well-respected energy expert Chris Yelland writes that nuclear energy is indeed “a very high-risk and high-regret option”. I couldn’t agree more when he asserts that “this is not the time to be making extremely expensive 100-year commitments”. Coupled with the lack of a valid business case, there are a number of practical reasons for rejecting this technology.
If, according to Eskom’s reply to our PAIA, it has not completed any approved studies on the feasibility of small modular reactors (SMRs) or conventional nuclear technology in recent years, why is the government once more asking for approval from Nersa for further nuclear power options? And, while we are encouraged that President Cyril Ramaphosa spoke about the need to work to fulfil our climate-action commitments under the Paris Agreement, nuclear energy will not meet those commitments.
This is all so reminiscent of the rushed and secret 9,600MW nuclear new build of 2015 – a deal that was declared unlawful and unconstitutional in the Western Cape High Court in 2017 (the judgment and other documents can be found here). The government is still not laying out its nuclear energy plans for public scrutiny, but once again seems to be steamrolling down a path of nuclear energy procurement.
The lack of effective public participation, such as that which characterised the illegal nuke deal, is a hallmark of weak democratic processes.
Especially in this time of Covid-19, South Africa does not have the funds to ignore its past energy planning mistakes, which could cost a conservative estimate of R330-billion. It is therefore imperative that the government upholds democratic processes and listens to what the people want. DM/MC
Francesca de Gasparis is SAFCEI’s Executive Director.