This article originally appeared in the Daily Maverick Opinion Section.
It is difficult to understand why the main limitations to private power generation have not been removed, despite repeated pledges from government to that effect. There is a real danger that while grappling with the immediate crisis, policymakers will shelve the issue indefinitely.
Demand for electricity has plunged with the onset of South Africa’s COVID-19 lockdown, removing the threat of load shedding for its three-week duration. It could be several months before the economy is up and running normally again, but it would be a big mistake to forget the power constraints which plagued SA in the weeks before the pandemic struck.
When Moody’s downgraded SA on 27 March, it pointed out that unreliable electricity supply and its impact on the economy was one of the main reasons for the decision. The ratings agency also pointed out that a strategy to stabilise electricity production in the country has failed to materialise and that as a result, economic growth would remain low for years. Returning to a constrained electricity supply without an adequate government response is the last thing embattled businesses need after COVID-19.
Against this background, it is difficult to understand why the main limitations to private power generation have not been removed, despite repeated pledges from government to that effect. There is a real danger that while grappling with the immediate crisis, policymakers will shelve the issue indefinitely. In addition, the National Energy Regulator (NERSA) has inexplicably halted all new licensing applications for the duration of the lockdown period.
For connected projects larger than 1MW — which applies to most of the pent-up demand for corporate generation of electricity — a license is still required from NERSA even if the installation is for a customer’s own use, or established through a bilateral agreement involving only a customer and an independent power producer.
These onerous license application processes were intended for large, utility style power stations, hundreds of MWs in size, and each requires a public participation process with hearings. They have requirements which make the development of smaller project impractical. The official time for NERSA to issue these licenses is 120 days but in practice it takes far longer — with some cases so far taking as long as two years.
NERSA is theoretically able to process license applications, but in practice is inadequately resourced to handle the quantity of smaller applications that are now being made. This regulatory blockage is holding up the roll out of hundreds of MWs of electricity generation, which would be the fastest way to alleviate the power constraints which lead to load shedding.
This point has been repeatedly made by independent bodies like the Minerals Council of SA, Business Unity SA, the South African Photovoltaic Industry Association, and the Council for Scientific and Industrial Research. It has been recognised by Minerals and Energy Minister Gwede Mantashe, who indicated at the mining Indaba in March 2020 that self-generation of any size would not require licensing.
Companies in the private sector were hopeful that their pleas for the 1MW cap on licensing for their own electricity generation would be lifted to 10MW, which would include most of the projects they want to implement. And yet, when the eagerly awaited Schedule 2 of the Electricity Regulation Act was published on 26 March, the 1MW threshold for grid-connected facilities exempt from licensing was maintained.
The shape of the national load profile – when and how much electricity is used – is important to Government because it affects which mix of electricity is most cost effective. Its preferable to have a load profile that allows for the maximum usage of the cheapest resources available to the country. From this angle, the control over who builds what generation is understandable, but even with this argument considered, the amount of solar power in South Africa still represents under 5% of installed capacity, and less than 2% of the consumed energy.
A 10MW solar generator represents 0.006% of annual electricity demand and 150 of such projects would need to be installed to reach 1% of the total demand. Lifting the license exemption threshold to 10MW will initially have negligible effect on the demand profile but a huge effect on lifting red tape in the way of more energy coming onstream and supporting small to medium size businesses. It is always possible for the state to monitor the uptake and lower the threshold for licences at a later stage if necessary.
As the chairperson of a solar PV company, the SOLA Group, I have seen many clients desperate to install larger solar plants than the 1 MVA limit to alleviate their electricity constraints and lower their costs. These projects are practically ready to be rolled out – and could be built within 8-12 months – if the licensing hurdle is removed.
From my extensive experience in the solar PV industry in South Africa I estimate that, without such restrictions, solar PV companies could build 500 MWs within the next 12 – 18 months. The wasted opportunity due to these arbitrary licence requirements is obvious and destructive.
For the sake of saving businesses and creating jobs post COVID-19, I urge government to:
- Lift the threshold on requirement for a generation license from 1MW to 10MW until the embedded generation allocation in SA’s new Integrated Resource Plan has been reached.
- Require that these projects are registered with NERSA upon their commercial operation date through submission of an independent certificate of compliance against which the allocation to embedded generation can be measured, and keep the database of installed MWs public and updated.
- Ensure that NERSA is provided with, or creates, clear guidelines as to the technical standards that must be met to obtain a generation license for generation projects above 10MW in size.
- Provide NERSA with the resources, both through budget and staff, to evaluate the applications in a meaningful, prompt and scientific way.
- Return to processing and receiving licence applications during the lockdown.
The business case for installing embedded power generation remains for the private sector, and the economy will once again start moving when the impact of the pandemic subsides. It would be tragic if its potential to recover is thwarted by continued electricity shortages.