National Union of Metalworkers of South Africa

1. National Union of Metalworkers of South Africa Submission on Energy Efficiency to the PC on Energy 06 September 2012

2. Introduction • SA ranks 13th in the world as a carbon emitter • Developments since COP17 highlighting the need for SA to be more energy efficient • Resonance of this in the National Climate Change Response White Paper 2011, the Green Economy Accord 2011 and several policy documents released by auxiliary departments that seek to reduce the country’s emissions by 34% by 2020 and 42% by 2025 • Energy Efficiency Strategy of 2005 takes its mandate from the 1998 White Paper on Energy Policy and apart from its vision to make energy affordable to all without damaging the environment, the strategy has set ‘a national target for energy efficiency improvement of 12% by 2015’(Energy Efficiency Strategy RSA, 2005: ii).

3. Introduction (continued) • 2008 First Review: Minister indicated that government had entered into a Energy Efficiency Accord with some ‘40 large industrial and commercial consumers’ • DoE: revised strategy for public comment by the end of 2011

4. NUMSA on the Energy Efficiency Accord Our concern: The exclusion of both labour and civil society formations from participation in the Energy Efficiency Accord and the dominance of big business in what has explicitly been described as a voluntary rather than mandatory initiative, confirms a number of our fears about the nature and intention of the Accord: • The voluntary nature of the Accord does not place any obligation on business to implement energy efficiency measures and so long as industries are made to comply with the minimum regulatory standards as far as emission levels are concerned the chances of further investments in energy efficiency projects will remain as they are – voluntary! • The Accord does little to discourage abusiness as usualapproach and leaves energy efficiency almost entirely in the hands of the private sector

5. The National Business Initiative (NBI) and Business Unity South Africa (BUSA) have complete control over the Accord: To convene the business of the Accord and its link with Government, an Energy Efficiency Technical Committee (EETC) was formed with NBI playing the management and secretariat roles ... the EETC is chaired by one of the signatory companies and the deputy chair is provided by the Department of Minerals and Energy (DME) [Source: NBI/DME, 2008: p3 NBI/DME 2008, Assessment Study of the Energy Efficiency Accord, viewed 31 August 2012, http://www.nbi.org.za/SiteCollectionDocuments/ee_accord_assessment_report.pdf ]

6. In its assessment of the Accord, the NBI and BUSA have made several recommendations calling on government to ensure that: • The voluntary efforts on energy efficiency by business will be considered in the planned Power Conservation Programme (PCP) • Power rationing to be shared fairly by all sectors in the economy and not just by business • Business wants more high level engagement from government departments • Business wants government to provide an integrated package of incentives and financial mechanisms to sustain their involvement and interest in energy efficiency programmes • There is more government support for Research and Development – Support from the South African National Energy and Development Institute (SANEDI) • There is adequate skills training in Energy Management and technical operations and for the Energy SETA to play a more proactive role in establishing the requisite training standards

7. Seemingly, the Accord becomes a one sided affair, with Business setting the agenda and Government showering its blessings with a promissory note acknowledging that all is well and on track.

8. Absence of Trade Union and Civil Society from Participating in Policy Development • In August 2011 the Department of Energy (DoE) briefed the PC on Energy on some of its work on energy efficiency and energy savings. DoE highlighted progress on the following projects: • The Solar Water Heating Programme • Fiscal Energy Efficiency and Demand Side Management (EEDSM) Programme • Industrial Energy Efficiency Project [Start: 1/4/ 2011 - Finish: 31/3/2014] • Energy Efficiency Target Monitoring Project [Start: 1/04/ 2011 - Finish: 31/3/2014] • Energy Efficiency and Demand Side Management: • Appliance Standard and Labelling Programme • Appliance Energy Efficiency Standards • Energy Efficiency Communication and Campaign Strategy

9. In all these endeavours the word trade union, labour and civil society is hardly mentioned. The only reference that comes close to any involvement from civil society is the proposal by DoE to refer the Energy Efficiency Communication Strategy to NEDLAC social partners for consideration: This Strategy is to give weight to the National Campaign including defining roles and responsibilities for all stakeholders as it is a fact that government can not do it alone. [DoE, Briefing on Energy Efficiency and Energy Savings to the Parlimentary Portfolio Committee on Energy, 10 August 2011]

10. NUMSA Workshop 17 October 2011 DoE presentation to NUMSA Employee Involvement Process [Source: DoE, Industrial Energy Efficiency Project, 17 October 2011, Numsa Workshop]

11. Response from NumsaShopsteward, Assmang Chrome, 31 October 2011 Question: Does our company have an efficiency committee? Is there a structure or energy committee? Response: Yes! we do have an energy efficiency section led by the Energy Manager, where all the engineers and superintendents assist him on control measures on energy consumption. The above structure is responsible for both energy consumption and costs

12. Response from NumsaShopsteward, ArcelorMittal, 31 October 2011 Energy committee: ArcelorMittal have the energy committee at corporate [level] with Mr. Francois van der Bank as the energy manager. AMSA (Vanderbijlpark ) has started with formulating their energy committee.

15. Further consultations with shopstewards belonging to industries that fall within the scope of the Intensive Energy User Group (IEUG) and those involved in some of the SWH manufacturing industries confirm that management sees Energy Efficiency as its own prerogative. During COP17, Numsa conducted several interviews with shopstewards attending the C17 Civil Society Space gathering at the University of KwaZulu-Natal. Many of them attended the World of Work Pavilion organized by the International Trade Union Confederation (ITUC) and confirmed that there was little interaction between them and management on issues such as energy efficiency.

18. SWH Rebate Programme Installations

22. In the short term NUMSA RDG’s will focus on the following:

23. Conclusion As indicated in many of our previous submissions to the PC on Energy NUMSA is more than willing to share its ideas on matters of energy and has repeatedly called for involvement of all stakeholders in matters of energy production and consumption. Unless there is a commitment from all to participate and until such time that government and the private sector become less selective on issues that they want the unions and civil society to participate in, the chances of becoming energy efficient and creating a new and healthier environment will remain an illusion.