NERSA has published a request for comment on their web site regarding "net metering" and embedded generation (EG).
In South Africa, peak demand typically happens between 7am and 10am in the morning, and 6pm and 8pm in the evening.
The document assumes that EG cannot help with peak demand and ignores battery-based systems, fuel cells, biodigestors running on farms at peak times, sewerage-mining and so on.
This fundamental assumption causes the document to, again, ignore the huge potential of homeowners and rooftop owners to completely remove their peak demand and thus effectively supply the grid with electricity at peak time. Meaning South Africa's peaking power stations will not be needed, and the economy will expand.
Note that here is my full email to NERSA, based on this document:
I have read the latest discussion document dated 25th February 2015 as well as the draft discussion document dated 10th December 2014 and I have the following comments and observations:
1) The new document excludes the PV installation list from around the country. This is unfortunate as your readers will not have an idea of the scale of existing systems already being installed. Of-course this list ignores systems less than 1 MW, but nevertheless it is an interesting list.
2) The list of concerns has also been left out. One of the many reasons for the poor adoption of Embedded Generation in South Africa is because government misunderstands how important electricity generation is for the economy, and instead focuses on potential lost generation and compensation.
3) It is unfortunate that the System Profile Impact graphs have been ignored in the latest version. These graphs show how Renewable Energy will impact on the load profile of the grid. Having this information means that installers and users of EG can make proposals to move their loads to when the sun is shining.
4) Both documents assume that EG cannot help with peak demand and ignore battery based systems, fuel cells, biodigestors running on farms at peak times, sewerage-mining, etc. This fundamental assumption causes the document to again ignore the huge potential of homeowners and roof top owners to completely remove their peak demand and thus effectively supply the grid with up to 17 GW of electricity at peak time, meaning that South Africa's peaking power stations will not be needed, the economy will expand, etc.
Please acknowledge receipt of this email and add me to your communication database for the Public Hearings, etc.