1. 1 ERC Anya Boyd Energy Research Centre University of Cape Town 4th March 2011 ERC Response to the NCCRGP

2. 2 ERC General comments  Broadly speaking our comments converged on two concerns:  i) the lack of specific quantified targets for emissions reduction, both sectoral and sub-sectoral or any mechanism to identify such targets  ii) the lack of clarity on how the proposed policies and measures align with other national policy spheres  Comments focus on energy related issues.

3. 3 ERC Overview 1/ Targets, Timelines & Actions 2/ Electricity Supply 3/ Energy Efficiency 4/ Implementation 5/ Monitoring, Evaluation & Review 6/ Other

4. 4 ERC 1. Targets, Timelines & Actions  Copenhagen targets (5.4 & 9.2.1)  Inclusion important, however, lacks specifics on how to be met.  The final policy must specify from the outset that the issue of peak, plateau and decline is crucial in framing the mitigation response and must maintain the year 2030 as the start of the decline of the emissions as stipulated in the relevant 2008 SA Cabinet statement.  Timelines for reviewing and aligning legislation by 2012 and 2014 respectively (6.1.1& 6.1.2) leave only six years to reduce emissions by 34% below BAU by 2020  Efforts to review climate and related policies need to start earlier, with annual public reporting on progress

5. 5 ERC  How to allocate carbon space under the Peak Plateau & Decline scenario?

6. 6 ERC 1. Targets, Timelines & Actions (contd)  Lack of sectoral targets  Specific ambitious reduction targets should be specified across the board, and these should be established in a national process in the context of the national emissions reduction target  Lack of specified actions to achieve targets  Necessary to quantify resources required in terms of  Investment (ZAR millions)  Technology requirements  Capacity: Institutional and governance requirements for implementation ??

7. 7 ERC 2. Electricity Supply  Lack of integrated approach to electricity supply in relation to our national emissions reduction target  No more coal plants unless compatible with our emissions constraints  Nuclear (5.4.9)  Unclear where the 10GWe by 2035 target or the analysis which could have set such a target, originates from  Concerned by lack of public participation as mandated in the 1998 White Paper on Energy  Renewable Energy - targets vague (5.4.7 & 5.4.10)  GP refers to the 10,000GWh target by 2013 taken from the renewable energy white paper of 2003  “Scale up from” but does not clarify to what and by when

8. 8 ERC 3. Energy Efficiency  Most cost effective source of emissions reductions by the long-term mitigation scenario process (LTMS).  GP still supply rather than demand side orientated  It is not clear what progress has been made so far on the 2005 Energy Efficiency strategy  A wider, better resourced and governed approach to energy efficiency has the potential to deliver massive environmental, economic & social benefits

9. 9 ERC 4. Implementation  Inter-Ministerial Committee (IMC) on Climate Change  Potential to coordinate policy and implementation across government & also involves the Executive very centrally  National Planning Commission  More clarity on role in planning the transition to a low- carbon and climate-resilient economy and society  Energy policy capacity needs strengthening  GP refers to a national energy policy – who’s responsibility to implement?  More inclusive energy policy community  Civil society participation  Outreach work to community level but require govt resources

10. 1010 ERC 5. Monitoring, Evaluation & Review  The ERC supports a dedicated section on monitoring, evaluation and review as this critical to ensuring compliance.  It is crucial for government to set targets, and report against them regularly, both for mitigation & adaptation. Currently there is a lack of targets in the GP, precluding effective MRV  No clear mechanism for MRV on adaptation activities is proposed (9.1.)  Point 9.2.5 calls for annual reporting of actual greenhouse gas emissions. The ERC seeks clarity on the steps that will be taken in the event of non-compliance.

11. 1 ERC 6. Other  The ERC concurs with a balance of adaptation and mitigation interventions.  Lack of reference to the Informal Economy – under both mitigation or adaptation  Research Design & Demonstration (5.4.5)  Support this for both new and existing technologies  The classification of ‘hard’ and ‘soft’ technologies is poorly defined (8.3). The assumption that ‘hard’ technology is purely associated with mitigation technologies, and ‘soft’ technologies with adaptation technologies is incorrect  The ERC would advocate a stronger emphasis on a ‘just transition’ in relation to the energy-intensive sectors of the South African economy, whilst aligning with national and regional responsibilities

12. 1212 ERC Thank You