EIUG

1. EIUG Energy Intensive Users Group Comments on the Energy Bill B52 - 2008

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 • 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 • 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 • 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 • 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 • 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