Small Scale Embedded Generation – Update to the regulations

SALGA, AMEU and Eskom, with the support of GIZ, have been collaborating to provide NERSA with a formal submission of comments on the 'Standard Conditions for Small Scale Embedded Generation' issued by NERSA. Technical workshops relating to safety aspects of embedded generation are also underway.

Author: Aurelie Ferry, SALGA

Small scale embedded generation (SSEG) is seen by many in South Africa as a sustainable way to provide, at a low voltage level, much needed additional capacity to the electricity system. In order to realise this, the regulatory framework needs to be in place, along with safety standards which ensure optimal operation of the systems and, above all, safe working environments for technicians. The German International Cooperation (GIZ) organisation, under its South African-German Energy Programme (SAGEN), in cooperation with Association of Municipal Electricity Distributors (AMEU), South African Local Government Association (SALGA) and Eskom, has made SSEG a focus of its cooperation programme. Two work streams have been running in parallel, one on the regulatory framework and conditions, and the other on the technical aspects of SSEG.

1) Standard conditions for Small Scale Embedded Generation

In January 2012, the attention of AMEU members was drawn to the existence of a NERSA document entitled Standard Conditions for Small Scale (less than 100kW) Embedded Generation within Municipal Boundaries. The document was undated but referred to a decision of the Energy Regulator dated 22nd September 2011, despite the fact that it had not been subject to the required public consultation process before being made a mandatory requirement.

In terms of the decision, municipalities were required to register and maintain a database of all small scale (less than 100kW) embedded generation within their areas and report to the Energy Regulator on an annual basis on a number of statistics related to this generation. It also states that “....these conditions are guidelines currently but the intention is to include them in the Licence conditions of the municipalities when they are renewed.”

Since that time, a number of meetings have been convened by various bodies to discuss the implications of the document. Over the last year, experts from the GIZ’s SAGEN programme have conducted workshops to finalise a formal submission to NERSA on the matter. Arising from this process, comments from the SALGA/AMEU/Eskom reference group on NERSA's Standard Conditions for Small Scale Embedded Generators were considered by the SALGA Municipal Trading Services Working Group at a meeting on 12th June 2014. The Working Group supported the proposed framework. Final approval was obtained from the SALGA National Executive Committee to engage with NERSA on the subject on 3rd July 2014. The comments were presented to NERSA by a SALGA delegation on 16th July 2014. NERSA officials welcomed the initiative and undertook to advise SALGA, in due course, of the way it intends to address the issues raised in the position paper.

2) Technical workshops and support

A SALGA-GIZ workshop on "Technical Aspects of Small Scale Embedded Generation" was held on 26th June 2014 at the Tshwane Council Chamber.

This well attended workshop presented views on the impact of SSEG on distribution, network planning and operation as well as experiences with rooftop PV systems in Germany. A significant aspect of the workshop was the safety aspects related to the Low Voltage Operating and Maintenance with embedded generation. These aspects will be addressed in the upcoming SANS10142-3. Details of the update and development of new parts of NRS 097-2 were presented. This specification covers:

The workshop resolved that several issues will be investigated further, including the development of a technical guideline based on NRS specifications, lessons learnt and international best case practices. A further workshop which will take place during November 2014, focusing on safety issues.

GIZ has again offered to provide ad hoc advice to municipalities regarding technical aspects of SSEG on an individual basis. Any municipality wishing to take advantage of this offer is invited to contact Ms Sofja Giljova, South African - German Energy Programme (SAGEN), at or 012 423 6330.

A copy of the SALGA/AMEU/Eskom reference group comments is available here

Copies of the minutes of the workshop and the presentations delivered are available on the AMEU website.