1. EIUG Energy Intensive Users Group Comments on the Energy Bill

2. Presentation Overview
Introduction to EIUG
General Comments to the National Energy Bill
Specific Comments:
Energy Planning
Renewable Energy
Energy Efficiency
Energy Research
Security of Supply
EIUG

3. Introduction to EIUG EIUG The EIUG is an association of large energy
intensive consumers
Membership of the group consists of 35 of the
countries largest energy users
Combined consumption is in excess of 40% of the
total electricity consumption in South Africa
Energy is a primary input to all these organisations
who are dependent on quality & affordable electricity
for their survival and growth
EIUG

4. General Comments
The EIUG pledges the support of the considerable experience
of its members to the aims of the Bill however:
The Bill makes no provision for stakeholder input into
energy policy or planning formulation which is
fundamental to the growth of the EIUG member
companies, many of whom represent South African
opportunity relative to other International
opportunities
The EIUG believes a more inclusive stakeholder policy will
improve South African growth prospects particularly
during these energy constrained times
EIUG

5. General Comments
It is the experience of the EIUG membership that Energy
permeates all activities in the modern world and cannot
be seen in isolation hence:
Repeats the request for stakeholder input into
energy policy & planning formulation to
improve South African growth prospects with
constrained energy resources
EIUG

6. General Comments
The EIUG is of the opinion that NERSA should have
the role of collection and collation of Energy data and
the determination of any application in the public interest
The establishment of National Energy Modelling and
Information Agency will compromise the independence
of NERSA, lead to duplication of data gathering effort and
confusion of outcomes
The EIUG welcomes the concept of integrated planning
but repeats the request for suitable legislation
to be enacted to ensure stakeholder involvement in this
regard
EIUG

7. General Comments
To ensure “electricity security” which is an objective of the Bill
The EIUG believes that in terms of the current Electricity
Supply Industry model Eskom is the electricity supplier
and is responsible to:
Ensure that it has made provision to meet the
electricity demand of the country in both the long
and short term
EIUG

8. Specific Comments EIUG Definitions
The definition of energy data is too broad and consequently provides the Minister with powers beyond the required jurisdiction which might lead to unintended consequences
The definition of energy efficiency is unclear
Environmentally sensible is open to subjective
application [cl 4.3]
Safety, Health and Environment
Ministry of transport should be included [cl 4.2]
EIUG

9. Specific Comments EIUG National Energy & Modelling Agency
This function should be performed by NERSA
National Energy Development Institute
This institute should be funded from the fiscus as it
has other non energy benefits
EIUG

10. Specific Comments EIUG
Measures to promote the use of renewable energy [cl 27 (1)a]
The Minister should be required to consult with all affected sectors
The nature of South African Industry is different to most other parts of the world. each individual application is unique and subject to specific challenges and wide consultation is necessary for maximum positive impact
EIUG

11. Specific Comments EIUG
Measures to promote energy efficiency [cl 29 (2)]
That the Minister is empowered to prescribe individual minimum levels of energy efficiency for particular sections in conjunction with the SABS is suited to consumer products; but requires considerable interaction with large industrial stakeholders to prevent disruption to the economy
It is recommended that this clause be modified to ensure adequate consultation so as to positively affect the economy
EIUG

12. Thank You
EIUG