Submission based on: Submission based on

Submission based on:

• Submission based on:

• Evidence and research
• The wishes of low income households

• Highlighting

• Support for the bill
• Suggestions for strengthening the bill
• Household Energy Safety challenges
• Linking energy security with energy poverty

• Call for a household energy “Marshall Plan”

Not-for profit organisation

• Not-for profit organisation

• Established in 1996

• Mandate

• to promote safety in the domestic usage of paraffin for the low income sector

• Mission

• to ensure the safe use of paraffin, as part of the energy mix for domestic users

As it addresses:

• As it addresses:

• availability of diverse energy resources;

• sustainability and affordability of energy with regards to economic growth and poverty alleviation;

• energy security in South Africa.

• An opportunity to address policy and implementation gaps in

• 1998 Energy White Paper

• Includes focus on safety

Household energy security and safety system to be implemented for low income sector

• Household energy security and safety system to be implemented for low income sector

• All energy carriers need equal attention for safety and efficiency and make optimal use of all energy carriers

• Bill is touching on it and can be improved in this area – in accordance with

• mandate of our Assoc.

It needs to give substance in terms of how the country plans to improve household energy safety (across all energy sources)

• It needs to give substance in terms of how the country plans to improve household energy safety (across all energy sources)

• Clarity on the role of government in promoting household energy safety

Importance of the principle of public participation and civil society involvement needs to be highlighted

• Importance of the principle of public participation and civil society involvement needs to be highlighted

• The State must lead public energy safety education and awareness campaigns

• Roles for the other National Departments such as Health and Education as well as for provincial and local government departments

• More clarity on the roles on provincial and local governments in South Africa’s

• energy governance and linkages with

• their strategies

The issue of standards enforcement needs to be attended to

• The issue of standards enforcement needs to be attended to

• address the lack of capacity to monitor standards compliance and enforce safety standards

• Necessary to collect information on energy safety

• propose that the Associations’ household energy-related surveillance project be used as an established resource

Ingestions of liquid energy carriers, mainly by children

• Ingestions of liquid energy carriers, mainly by children

• (e.g. paraffin)

• Burns from all energy carriers (e.g. paraffin, electricity, gas)

• Fires (informal houses and settlements)

• Causes

• Behavioral
• Systemic issues
• Appliances
• Lack of packaging, …
• Poverty issues – housing etc
• Lack of policy instruments and
• enforcement

Community-based research

• Community-based research

• Surveillance – Burn Units, clinics, households

• Series of Household Energy Summits

• Held in Durban, Rustenburg, Port Elizabeth and Johannesburg (National)
• Attended predominantly by paraffin users and victims of paraffin-related injuries

• Participants agreed on a declaration or set of proposals of what could be done

• This declaration forms the basis

• of our submission

Purpose of the Bill

• Purpose of the Bill

• This Bill intends “to ensure that diverse energy resources are available, in sustainable quantities and at affordable prices, to the South African economy in support of economic growth and assists in poverty alleviation…”

With regards to poverty alleviation, the participants of Paraffin Users Household Energy Summits noted with regret:

• With regards to poverty alleviation, the participants of Paraffin Users Household Energy Summits noted with regret:

• “the limited household energy options of many households due to economic hardship and poverty;

• the unsafe housing options available to poverty stricken people and that the housing provision does not cater for other energy carriers”

Improve the safety and availability of all energy carriers and their systems

• Improve the safety and availability of all energy carriers and their systems

• In context of energy crisis, paraffin is and will remain the energy source of choice for low income households, therefore:

Concern:

• Concern:

• paraffin price increases this year have had a disproportionate effect on the budgets of low income households

• The real price of paraffin has increased by 54% this year alone

2. Objects of this Act are to -

• 2. Objects of this Act are to -

• (a) Ensure uninterrupted supply of energy to the Republic;

• Participants of the Paraffin Users Household Energy Summit noted:

• “with regret that inconsistent and insufficient electricity supply is adding to household energy incidents”

(g) Promote evidence-driven energy and related sectors’ policy formulation

• (g) Promote evidence-driven energy and related sectors’ policy formulation

• Participants in Paraffin Users Household Energy Safety Summit urged governmental action:

• “Accelerate the establishment of paraffin policy within the broader context of other energy options for low-income households. The policy must clearly outline the stand of government on whether paraffin will be phased out or not;

• regulation of the paraffin industry, including wholesale and retail sectors which are a key portal for safety;

• the weaknesses and lack of regulation in the whole paraffin system (how paraffin is distributed, sold, stored,

• burnt or used”

(j) Facilitate improvement of the quality of life of the people of Republic;

• (j) Facilitate improvement of the quality of life of the people of Republic;

• Participants of Paraffin Users Household Energy Summit are alarmed by:

• “the many energy related incidents, injuries and deaths …;

• the many paraffin-related fires, burns, ingestions, asphyxiation, and respiratory complications due to indoor air pollution;

• the unacceptable burden borne by children, especially those under the age of five years old who are most at risk …;

• the unacceptable burden borne by women, especially in rural areas and informal settlements;

• the number of injuries by hot liquids or foods irrespective of the energy source used;

• the emotional effects and financial implications

• that low income households experience; and

• The lack of counselling services provided to survivors

• of paraffin related incidents and injuries”.

(h) provide for optimal supply, transformation, transportation, storage and demand of energy that is planned, organised and implemented in accordance with a balanced consideration of security of supply, economics, consumer protection and a sustainable development;

• (h) provide for optimal supply, transformation, transportation, storage and demand of energy that is planned, organised and implemented in accordance with a balanced consideration of security of supply, economics, consumer protection and a sustainable development;

• Participants in Paraffin Users Household Energy Summit noted with regret:

• “the weaknesses and lack of regulation in the whole paraffin system (how paraffin is distributed, sold, stored, burnt or used)”

• Participants in Paraffin Users Household Energy Summit urged government action:

• “register all sellers of paraffin and related

• appliances”

(j) Facilitate improvement of the quality of life of the people of Republic;

• (j) Facilitate improvement of the quality of life of the people of Republic;

• Participants of Paraffin Users Household Energy Summit urge governmental action:

• “Establish an energy injury/accident compensation fund similar to the road incident fund to provide financial support for paraffin-related incident victims and survivors”

• Participants of Paraffin Users Household Energy Summit strongly urge, pending regulation, that:

• “dedicated counselling support be provided for survivors”

Provision of data and access to data source

• Provision of data and access to data source

• The Assoc. as well as Paraffin Users support 3.(1) to 3. (3) and propose urgent governmental action:

• “Mobilize the Department of Health to take over and expand the Surveillance System that the Paraffin Safety Association is implementing …;
• To conduct research and collect user friendly data to monitor the impact of energy provision and the implementation of improved energy programmes;
• This research and data must remain current and accessible and be fed back to communities.”

• Importance of gathering info on energy safety

• The Assoc.
• collects and collates information from hospitals and clinics across the country
• is willing help and provide whatever surveillance information including energy-related injury data
• suggest that the National Health
• department plays critical role in this regard.

Safety, health and environment

• Safety, health and environment

• The Assoc. welcome clauses 4.(1) and 4.(2) as they speak to energy safety

• - where ‘may’ should be changed to ‘must’

Safety, health and environment

• Safety, health and environment

• 4. (1) The Minister MUST, in consultation with … establish … programmes, not contemplated in other legislation, to minimise the negative safety, health and environmental impacts of energy carriers.

• This clause is directly supported by Declaration:

• ensure the prevention and reduction of the negative health, economic and environmental damage through long-term risk reduction strategies;

• The Assoc. and Paraffin Users have concerns on current Bill:

• Importance of defining programmes
• Should include energy safety awareness and education programmes
• DoE - a leadership role educating the
• public by incorporating energy safety
• in schools curriculum for all grades

Safety, health and environment

• Safety, health and environment

• 4. (2) “The Minister MUST, … for the purposes of ensuring safe, healthy and environmentally sensible use of energy, prescribe standards and specifications, not elsewhere legislated or regulated, for –”

• There are great gaps in current legislation/practice
• Need for safe energy system, including
• Safe packaging for liquid energy carriers (to prevent ingestions)
• Safe and efficient appliances (cooking, heating and lighting)
• Enforcement will be critical
• Who, what, how, consequences
• need to be highlighted in the Bill

Energy access by households

• Energy access by households

• Household Energy Security is not happening in SA

• “appropriate forms of energy” - a definition is necessary

• A mechanism is needed to cushion the resource-poor consumers from the vicissitudes of price hikes whilst their access is limited

Additional clarifications are needed:

• Additional clarifications are needed:

• What is the rationale for establishing this structure?

• How different is it from South African National Energy Development Institute?

• Importance of safety information

• To produce meaningful outputs quickly:

• Agency should collaborate with this Assoc., UCT’s Energy Research Centre,

• Sustainable Energy Africa, etc.

Availability of Information:

• Availability of Information:

• The Declaration states:

• “This research and data must remain current and accessible and be fed back to communities”

• User-friendly language is needed

• Format accessible to communities

• Clauses 8. (1)(i), 5. 30(3)(d), 35.(1)(a) “may”

16. (1) and (2)

• 16. (1) and (2)

• What is the role of other departments (such as DPLG) in the development of the Integrated Energy Master plan?

• What will the role of civil society and public be in the drafting of the energy master plans?

• What role should paraffin be playing in this master plan?

Additional clarifications are needed:

• Additional clarifications are needed:

• There are potential risks of overlap or conflicts between NEMIA and SANEDI

• What will the differences be between this structure and SANERI?

• Clause 18(2): Propose that civil society and community representatives be included in Board of SANEDI

35(1) “The minister MUST, …, make regulations regarding:”

• 35(1) “The minister MUST, …, make regulations regarding:”

• Regulations “must”, not “may” be made where users’ safety is at risk

• The Bill does not provide regulation on paraffin and energy carriers’ price, where declarations states that

• “Price increases for paraffin must be regulated”

National Energy Bill is welcomed

• National Energy Bill is welcomed

• More emphasis on:

• National household energy policy
• Health and safety issues

• Promising that the Bill focuses on resources

• Willingness to collaborate expressed by the Paraffin Safety Association of Southern Africa