Comments to NERSA on the Ministerial Determination to procure 2 500MW of new nuclear generation capacity

The Helen Suzman Foundation has submitted its comments to the National Energy Regulator of South Africa (“NERSA”) in respect of a determination by the Minister of Mineral Resources and Energy to commence the process to procure new nuclear energy with a generating capacity of 2 500MW (“the ministerial determination”).

In its detailed submission, the HSF makes the following points:

  • a least cost option for additional power generation needs to be established in a credible manner, which has not been done;
  • arbitrary limits to the annual construction of renewable energy options cannot be applied to forecasts, as such conduct provides not only clear evidence of an irrational approach, but also leads to the inevitable perception of a process that has been intentionally manipulated for undisclosed purposes; and
  • any financial assessment of new nuclear power plants must also include the cost implications of the extensive lead times required for the build of such plants (assumed to be in excess of 10 years), the decommissioning costs and the cost of storage of spent nuclear fuel.

The HSF points out that if these issues are not dealt with in a credible and thorough manner, the possibility of legal challenges against any final approval of the ministerial determination arises, on the grounds that such a decision is unreasonable and/or irrational.  For the HSF, it is not a question of adopting a pro- or anti-nuclear stance on this particular issue, but rather of ensuring that a logical and rational process is followed, leading to a justifiable, rational and reasonable conclusion.

For a copy of the HSF’s submission to NERSA, click here.

Anton van Dalsen
082 888 0500