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sacan.africa / Blog  / 2023  / Joint Civil Society Organisations in South Africa Statement on the Just Energy Transition Investment Plan

Joint Civil Society Organisations in South Africa Statement on the Just Energy Transition Investment Plan

As a collective of civil society organisations (CSOs) actively engaged in South Africa’s energy transition and the various sectors that intersect, we acknowledge and appreciate the Presidential Climate Commission’s (PCC) commitment to consulting multiple stakeholders, including CSOs, in the development of policies and strategies that will guide the country’s transition to a just and sustainable economy. We also welcome the opportunity to engage and comment on the document. However, we express our deep concern over the process of developing South Africa’s Just Energy Transition Partnership Investment Plan (JETP-IP) as well as its contents. Finally, we would also like to thank all of those from civil society which made an input into this statement. 

While the Just Energy Transition Plan (JETP) is intended to be multi-sectoral and includes various stakeholders, we have observed some significant shortcomings with the current process, including inadequate meaningful public participation, lack of transparency, and exclusion of important stakeholders. The Just Transition in South Africa must be guided by the principles of, inter alia, restorative justice, addressing the historical and ongoing impacts of past injustices and inequalities. This requires a transformative approach that prioritizes the needs of affected communities, addresses systemic barriers, and ensures that the transition is fair and inclusive. By doing so, South Africa can achieve a truly just and sustainable energy transition that benefits all its citizens.

We call for a more inclusive, transparent, and participatory approach to the JETP-IP. This should include effective engagement with broader stakeholders, such as youth from low-income and rural areas, women, and the health, faith, and education sectors, and meaningful consultation with communities and CSOs. By meaningful consultation, we refer to consultations that go beyond simply providing information or soliciting feedback: by providing opportunities for stakeholders to participate in planning, drafting, implementation, and monitoring activities, as well as ensuring that there is transparency and accountability. We also suggest the process be made more accessible – through the provision of resources such as data for online engagement and transport support for in-person engagement – and user-friendly documents and other relevant information provided well before consultations. While consultations have been held, more opportunities for stakeholders to provide input or revisions to the JETP-IP are needed. We urge the government to prioritise community engagement and consultation as it is a constitutional right. 

One of the major issues with financing for the Just Energy Transition Plan (JET-P) in South Africa is that it is mainly in the form of loans, with only a few grants available. While loans can be an effective way to fund large-scale infrastructure projects, they also come with a significant financial burden for the country. Loans need to be repaid with interest, which can place an undue burden on South Africa’s fiscus and reduce funds for future generations as debts will need to be prioritized.

Investment plans are often designed to meet the aims and objectives of the investors rather than the needs and requirements of those receiving the money. This can lead to a situation where the funding is not used in the most effective way possible. The JET-P must be developed in a way that prioritizes the needs of the people and communities affected by the energy transition. This means ensuring that funding is available for those who need it most and that investment plans are developed in a way that meets the needs of the communities.

To address these issues, the South African government must ensure that the financing for the JET-P is available in a way that does not place an undue burden on the country’s finances. This could include exploring alternative sources of funding, such as international grants or private investment. Additionally, the government must work with affected communities to identify their needs and develop targeted policies and programs that address these needs in a sustainable way.

Furthermore, it is essential that the investment plans for the JET-P are developed in a way that prioritizes the needs of the people and communities affected by the energy transition. This requires collaboration and consultation with affected communities to ensure that the funding is used in the most effective way possible to achieve the goals of the JET-P. By doing so, the government can ensure that the transition is just and sustainable, and that the burdens of financing the transition are not placed on future generations.

Additionally, there needs to be more direct communication of information regarding the JETP-IP given to stakeholders such as CSOs, including the extent to which relevant stakeholders can modify it and the financial mechanisms through which funds will be distributed, and how they will participate later in the process to ensure engagement in the JETP and assist in providing transparency during implementation. Furthermore, the technical nature of the plan poses challenges for stakeholders not involved in the energy and other relevant sectors to understand and meaningfully engage with the process. In other words, to what extent will any input made at this stage influence the JET-IP?

As a collective, we are particularly concerned about the inclusion and prioritisation of hydrogen in the JETP, given its high carbon footprint and potential water risk for a water-scarce country such as South Africa. We are also concerned about the potential openings for including Small Modular nuclear reactors, despite the evidence that it is not a viable option and is a high-cost, high risk means of energy production. We strongly recommend prioritising the use of sustainably developed renewable energy, locally manufactured and community-owned, for local purposes to address energy gaps and provide internal resources rather than for export. 

We also call for a gender-responsive and socially inclusive approach to the JETP. Gender perspectives have been largely absent from the current process, and the JETP-IP must address glaring gender gaps to ensure that the energy transition benefits all.  We must acknowledge that the current energy sector is one that excludes women at various levels, and that women are disproportionately impacted by climate change; as such, it is crucial that through a Just Energy Transition, we not only acknowledge but tackle and address the gender gaps we currently face. Additionally, the JETP must take into account the needs and priorities of youth and communities, particularly those in areas with high carbon emissions. 

The health sector is an important component to restorative justice, which the Just Transition Framework (JTF) has understood to mean redress that heals people and the land. The fossil fuel industry has caused the illness and premature deaths of past, present and future generations. It is critical that the health sector is consulted not only for the just transition as a whole, but also for the just energy transition – as a frontline sector responsible for healing the nation, but also as a notable contributor to South Africa’s carbon footprint. 

Energy use lies at the basis of our food systems and public services, therefore transforming the way we use and think about energy requires deep transformations in every sector and consideration of human needs involved in energy democracy. This requires implementing Integrated Energy Planning, starting with an understanding of all of society’s energy service needs (a detailed understanding of ‘demand’ – including suppressed demand), as envisaged in section 6 of the National Energy Act (2008).

Pressing questions have to be answered: 

  1. Who will implement the JETP-IP, and where will this responsibility fall within the government structure?
  2. Which specific individuals and working groups will be involved in the implementation, monitoring, and evaluation of the JETP-IP, and how will they be selected?
  3. Will the JETP-IP serve as a framework that informs other policies and initiatives related to the transition to a low-carbon economy, or will it operate as a standalone plan?
  4. Will the comments and recommendations from these submissions and the consultations held in any way meaningful impact the JETP-IP as it currently stands?  
  5. We recommend consultations with:
    • SECTION27 – contact Sasha Stevenson (stevenson@section27.org.za)
    • groundWork – contact Azeeza Rangunwala (azeeza@groundwork.org.za)
    • Public Health Association of South Africa – contact James Irlam (james.irlam@uct.ac.za)
    • WRHI, Wits University – contact Matthew Chersich (matthew.chersich@wits.ac.za)
    • South African Medical Research Council – contact Caradee Wright (caradee.wright@mrc.ac.za)

This is the time to establish that access to sustainable, safe, adequate, and reliable energy should be recognised as a self-standing right. Recognition would give impetus to a rights-aligned energy transition that must simultaneously end energy poverty, meet energy needs in a manner that addresses gender inequalities, and curb greenhouse gas emissions. Such integrated planning should also provide for the development of more participatory and locally accountable energy systems. 

We propose that the following should be included in recommendations to Cabinet:

NERSA should implement its mandate, under the Electricity Regulation Act, to set up forums “as may be necessary to advise the Regulator on matters affecting customers or end users in general, or a category of customers or end users in particular” – with a particular focus on addressing energy poverty and recognising that the free provision of electricity is arguably the most cost-efficient social investment available in SA.

Calling for the adoption of a benchmark for the provision of basic energy services, based on the recognition that there is a minimum level of electricity use that is necessary to facilitate socio-economic benefits and enable active citizenship; in particular commending the merits of establishing a Minimum Threshold Level of Consumption (MTLC) as a benchmark for efforts to address energy poverty, at 350kWh/month/HH (per household) – as recommended by the PARI report Hungry for Electricity (2022): “Electricity only becomes a truly transformative national asset when everyone is able to access the MTLC” (Minimum Threshold Level of Consumption – p.100 Hungry for Electricity). Specific recommendations should go beyond: “…improving free basic electricity”, to explicitly call for scaling up both the amount and the reach of the current system for Free Basic Electricity (FBE), with an immediate/initial increase to 200 kWh/month per household.

Calling for major improvements in transparency and accountability throughout the electricity system, including enabling all users to be informed participants within the system. As the JTF states: “A just transition puts people at the centre of decision-making…” and this must be applied to a holistic consideration of our electricity system, with appreciation that electricity users including households are part of the system.

To conclude, the Just Energy Transition Plan (JETP) should consider the different experiences and needs of women, men, and non-binary individuals in South Africa. Women are often disproportionately affected by the negative impacts of energy systems, including energy poverty, health issues, and environmental degradation. Therefore, the JETP must prioritise gender-sensitive approaches that promote women’s participation, representation, and leadership in decision-making processes related to the energy transition.

The JETP should also address the health impacts of energy production and consumption in South Africa. Poor air quality, caused by the burning of fossil fuels, has severe health consequences, particularly for vulnerable populations such as children, the elderly, and people with pre-existing health conditions. The JETP must prioritise the health and well-being of communities affected by energy systems by reducing air pollution, promoting clean energy alternatives, and providing access to healthcare services.

The government should prioritize investments that align with the needs and requirements of communities affected by the transition, rather than focusing solely on the goals of the investors. It is essential to acknowledge that the transition to a low-carbon economy may adversely affect specific sectors and communities, particularly those dependent on fossil fuels. The JETP must include measures to support these communities and ensure the transition is fair and just, providing alternative job opportunities and retraining programs for workers in affected industries.

Finally, the JETP must be developed through an inclusive and participatory process that recognises and addresses power imbalances and systemic inequalities. The voices and perspectives of historically marginalised groups, including women,youth, indigenous communities, and people living in poverty, must be heard and considered in the development and implementation of the JETP. Only then, can South Africa achieve a truly just and sustainable energy transition in South Africa.

Endorsed by: 

Gendercc SA – Women for Climate Justice

Green Environmental Heart Movement 

SECTION27

Project 90 by 2030 

African Climate Alliance 

Climate Action Network South Africa (SACAN)

African Climate Reality Project

Extinction Rebellion (XR) Nelson Mandela Bay (NMB) 

Southern African Faith Communities Environment Institute (SAFCEI)

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