SEA commends the Department of Energy on courageously taking the planning of the electricity sector in a
new direction. SEA is primarily active in the establishment and maintenance of networks supporting the sustainable and
equitable use of energy through local government in South Africa and the region. Our criticisms and comments are therefore made positively and constructively. The following
comment is entirely that of SEA based on its experience in the sector.
A summary of the main points of our comments are as follows;
Small-scale embedded generation (SSEG) has been called a ‘disruptive’ technology. SEA believes that the IRP could benefit from a more rigorous assessment of small-scale embedded generation (SSEG) roll-out, including < 1 MW systems which currently dominate installed capacity (Table 1, Appendix A).
While the policy adjusted 200 MW annual allocation to embedded generation of capacity between 1MW and 10MW in the ministerial determinations is, in our opinion, of the right order of magnitude for the time being until the next IRP, this capacity range has been a minority of the historical installed capacity as suggested by Table 1, Appendix A. The problem is that if the regulator grants the full 200MW of licenses annually it’s likely that far more capacity is being installed just below the 1MW license threshold limit. This capacity, not accounted for in the plan, will impact significantly on demand for grid electricity.
In this respect we believe local government and in particular, metropolitan electricity utilities, are the best placed to feed data on disruptive technologies to the IRP process, particularly now that most larger distribution utilities have established small-scale embedded generation (SSEG) registration systems.
The IRP notes the risk that demand forecasts may be lower due to higher prices. The cost benefit of rooftop solar systems is however relatively simple to calculate and public tools are available for this. We recommend that in order to achieve internal consistency between the price path and demand forecast, there should be a series of iterations of the price path to assess how much energy efficiency and distributed generation could affect demand given these prices. An internally consistent IEP can complement this by determining an energy service based demand from sectors that can incorporate energy efficiency and distributed generation rather than the final energy demand that is currently being used.
As such it is a matter of urgency to determine the potential capacity for SSEG in different sectors that could be taken up if costs drop and grid prices rise. Table 2 in Appendix A below suggests that retail alone will have a rooftop potential of 650 – 800 MW by 2020. Commercial installations as shown in the example in Appendix B are already highly attractive investments at current prices.
Demand side data has been cited as a limitation. We strongly recommended proactively addressing the data situation as follows:
Establish Good working relationships with ESCOs.
Work with ESCOS and training/certification institutions to develop a standardised electronic data model for energy audits and automatic (anonymised) integration into database.
This should look ahead to smart meter data consolidation by back end systems.
Make data plans and open data a condition of government funding and grant funding.
Adopt confidentiality and data privacy policies that are clear, transparent and appropriate to the nature of the data and that are not excessive and do not favour arbitrary firm secrecy.
