The South African Wind Energy Association’s (SAWEA’s) formal response to the draft Integrated Resource Plan 2023 (IRP 2023) questions both the modelling and assumptions used to determine the vastly diminished allocation for wind energy in the period to 2030 when compared with the prevailing plan.

It will also call for an overhaul of the document, including its post-2030 Horizon Two, given the lack of transparency in the current version regarding the modelling constraints employed, as well as the embedded policy adjustments and their associated costs.

The public comment period closes on March 23, having been extended by the Department of Mineral Resources and Energy (DMRE) from an initial date of February 23.

CEO Niveshen Govender notes that, when compared with the prevailing IRP 2019, the allocation for new wind generation has fallen dramatically from 14.4 GW by 2030 to only 3 GW.

“It's a huge reduction,” Govender told Engineering News in an interview as SAWEA was putting the final touches to its written comments to the DMRE.

“If you look at the energy mix of new generation capacity, wind has fallen from 37% to 19% and we are naturally concerned about how the modelling was done to arrive at such an outcome.”

Besides questioning the modelling, SAWEA is also highlighting the lack of alignment between the draft IRP 2023 and the costing used for wind, with the document unclear on how the Electric Power Research Institute and Lazard costing was applied and how these costs relate to prices achieved through various domestic procurement rounds.

Likewise, the IRP 2023’s “misalignment” with several other policy and industry plans that assume a far higher penetration of wind will be highlighted, including with the National Development Plan, Eskom’s Transmission Development Plan and the Energy Action Plan.

The absence of a “cost of scenarios” is also of concern, with Govender noting that this information was not contained either in the draft document itself, or in the supporting documentation released following its publication.

“We really need to understand what the costs are, including if there is a higher cost to get to energy security sooner.”

The draft IRP 2023 assumes ongoing loadshedding until at least 2027 and indicates that the shortfall will be overcome only once there is 7 220 MW of new gas-to-power capacity built and operating at a “high utilisation factor”.

The fact that the IRP 2023 does not cater for system adequacy has been heavily criticised by several stakeholders, given that IRP’s are primarily techno-economic models of what generation capacity should be maintained and built to match supply and demand.

Govender stresses that SAWEA’s members are not energy system specialists and will thus not comment in detail on the failure of the draft IRP 2023 to address loadshedding.

“What we can point out, though, is the fact that the 3.4 GW of wind currently in the system is helping to reduce two stages of loadshedding almost daily and that more could have been done had the wind allocation in the IRP 2019 been built as intended.”

Instead, none of the wind allocated for public procurement between 2020 and 2030 has been built to date and there are concerns that the 3.2 GW allocated to the current Bid Window Seven (BW7) could go the same way as BW6, when none of the wind projects advanced to the preferred-bidder stage.

“Although the curtailment addendum to the Grid Capacity Connection Assessment does unlock over 3 400 MW in the Western and Eastern Cape provinces, the scenario that arose during BW6 can only be avoided if it is coupled with Eskom’s Gated Generator Connection Process, which is not the case currently,” Govender highlighted.