Embedded Generation

Small scale on-grid solar photovoltaic embedded generation in

by Paul Tuson

The IRP 2010-30 update states that 9770 MW of solar photovoltaic (PV) capacity is planned to be installed in South Africa by 2030 and also estimates that embedded generation (EG) residential and commercial PV could reach 22,5 GW by 2030 based on living standards measure 7 (LSM 7) households and 5 kWp PV household installations

Even if this estimate is partially correct,  Approximately 45 000 PV systems in the and Eskom are being inundated with this points to a significant level of installed residential market applications from all types of customers small-scale solar PV embedded generation to allow them to install some kind of grid  Approximately 4000 PV systems in the connected embedded generation”. (SSPVEG) capacity in South Africa by 2030. The commercial market AMEU guideline on embedded generation Table 1 taken directly from a presentation states that the following PV market uptake  Approximately 670 PV systems in the by Tobias Bischoff-Niemz [4] shows only industrial market is projected for Johannesburg over the next some of the installed solar PV EGs to date 10 years: The guideline goes onto say that: “Municipalities in South Africa.

Project Location Province Installed capacity (kWp) When completed Kriel Mine Kriel Mpumulanga 240 Aug 13 Med Woodmead Gauteng 31 Jul 13 BMS Woodmead Gauteng 36 Jul 13 BT Woodmead Gauteng 36 Jul 13 WTP Witbank Mpumulanga 30 2013 Mitchells Plain Hospital Mitchells Plain 64 2013 Solar Irrigation Systems Montagu Western Cape 24 2013 GreenPeace Africa Johannesburg Gauteng 10 2013 Vodacom Century City, Western Cape 500 2012 Dube Trade Port Durban KwaZulu Natal 220 2011 Pick n Pay distribution centre Philippe, Cape Town Western Cape 300 2013 Vrede en Lust Farm Franschoek Western Cape 218 2013 Novo Packhouse Paarl Western Cape 200 Leeupan Solar PV Projects OR Tambo Precinct, Wattville Gauteng 200 2012 Pick n Pay Distribution Centre Longsmeadow, Johannesburg Gauteng 150 2011 Villera Winefarms Cape Town Western Cape 132 2011 Standard Bank PV Installation Kingsmead, Durban KwaZulu Natal 105 Unknown Pick n Pay Store Hurlingham, Johannesburg Gauteng 100 2010 BP Offices V&A Waterfront, Cape Town Western Cape 67 2011 Cavalli Wine & Stud Farm Stellenbosch Western Cape 51 2013 Oldenburg Stellenbosch Western Cape 45 2013 Coca Cola Water Bottling Plant Heidelberg Gauteng 30 Unknown Glaxo Smith Kline Cape Town Western Cape 30 Unknown Impahla Clothing Maitland Western Cape 30 Unknown Khayelitsha District Hospital Cape Town Western Cape 25 2011 Stellakaya Wine Farm Stellenbosch Western Cape 10 Unknown Leliefontein Wine Cellar and Groenfontein Stellenbosch Western Cape 88 2013 Admin Offices Eskom Megawatt Park Rooftop PV Sunninghill, Johannesburg Gauteng 358 2013 Eskom Megawatt Park Carport PV Sunninghill, Johannesburg Gauteng 398 Nov 2011 Eskom Kendal PV (ground mounted fixed) Eskom's Kendal coal fired power station Mpumalanga 620 Nov 2011 Eskom Lethabo PV (ground mounted 1-axis Eskom's Lethabo coal-fired power Free State 575 Nov 2011 tracking) station Eskom Megawatt Park CPV Sunninghill, Johannesburg Gauteng 26 Nov 2011 Cronimet Chrome Mining SA Thabazimbi Limpopo 1000 (PV) Nov 2012 Black River Park Cape Town Western Cape 700 2013 Bosco Factory PV Plant Edenale Gauteng 304 2013 Ceres Koelkamers Ceres Western Cape 505 2013 Rooibos Storage Facilities Clanwilliam Western Cape 511 2014 Table 1: Existing self-consumption solar PV EGs in South Africa 0.

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The AMEU document and the information from Table 1 show that interest in SSPVEG is growing and that installations are currently occurring in South Africa, with or without a national framework.

There is an obvious attraction to on-grid residential solar PV installations as the cost of solar PV systems decrease the cost of utility electricity increases Eskom’s reserve margin reduces and environmental and sustainability awareness among electricity users increases. EGs in the form of residential or commercial solar PV can also derive income when their generated electricity exceeds their load and they export their surplus electricity to the grid.

Besides the high SSPVEG projections and Fig. 1: Self-consumption solar PV EG. growing installations, there is a level of frustration in the renewable energy (RE) industry that not enough is being done to encourage SSPVEG in South Africa and that in fact there are real obstacles to the growth of the industry in South Africa. Some of these perceived obstacles are :

 Decrease in municipality revenue base. Up to 70% of municipal income is derived from electricity sales in some cases

 Reduced ability for municipalities to cross-subsidise other municipal services using electricity revenue

 Risk of LV and MV system overloading from high simultaneous solar PV EG generation into the local grid

 Safety of utility personnel

 Lack of pre-approved, generic standards Fig. 2: Net metering with bi-directional meter. for the solar PV EG/Utility interface

 Regulatory and legal obstacles

 Quality of supply (QOS) impact of PV equipment

This paper focuses predominantly on on-grid or parallel-connected SSPVEG (as opposed to off-grid and other RE technologies) at a residential and small commercial level. SSPVEG with battery or other storage is not addressed.

The current situation

Several standards, grid codes, guidelines and acts are being developed or exist in South Africa, intended to regulate the planning and implementation of RE generation and SSPVEG in South Africa, some of which are:

 Draft NRS097-2-1: 2013, Edition 2, Fig. 3: Possible FIT metering with bi-directional meters. Grid interconnection of embedded

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generation, Part 2: Small-scale embedded any entity wanting to “sell” electricity to generation another entity requires a generation license from NERSA. While generating licenses  NRS 097-2-3:2014 Edition 1. Grid Interconnection of embedded are not difficult to obtain if the explicit generation. Part 2 Small-scale allocation for that energy is detailed in embedded generation. Section 3: the NIRP it is possible that NERSA may not Simplified utility connection criteria for identify a specific allocation to rooftop low-voltage connected generators PV installations. This could be a potential Cable jointing, blockage for approval of such a license  Grid connection code requirements termination and for renewable power plants (RPPS) for EGs. However, the Municipal structures protection systems act 1998, Section 84 (1) page 32 states connected to the transmission system for wind and (TS) or the distribution system (DS) in South that “A district municipality has the following Africa version 2.6, November 2012 powers: [...] Bulk supply of electricity which solar applications includes for the purposes of such supply,  Distribution network code, Version 6, August 2011, RSA grid code secretariat, the transmission, distribution and, where South Africa applicable, the generation of electricity.” It could be argued that there are already  Distribution standard for the precedents to municipal generation e.g. interconnection of embedded the purchase of Kelvin power station power generation, DST 34-1765, March 2008, by City Power in Johannesburg and the Eskom standard renewable energy independent power  DST 34-1665 – Distribution standard producer (REIPP) program where electricity for the interconnection of embedded is purchased from IPPs and sold on to generation (DSiEG): Installations municipal customers. 100 kW – 1 MW From a technical point of view,  The SABS (2012), SANS 10142-1:2012, The wiring of premises, ed. 1.8, prevailing residential and commercial ISBN 978-0626-26767-4 meter technologies comprise the older electromechanical technology (rotating  Small-scale renewable energy standards disc), newer digital meters and pre-paid and specifications, published 1 June meters. Bidirectional metering systems are 2012, Eskom not currently installed in normal residential  Standard conditions for embedded and commercial points of supply (PoS) generation within municipal boundaries, but are being investigated in the draft national energy regulator of South NRS097-2-1 standard. Currently, most Africa, 22 September, 2011 SSPVEGs or Prosumers especially in the A1  Constitution of the Republic of South and A2 categories are not compensated Africa, No. 108 of 1996 for surplus or export power to their There is not enough space in this paper connected utility. In addition, existing to discuss the main technical, legal and SSPVEG installations are taking place in regulatory elements in all these documents, the absence of a coherent regulatory and but certainly they have a major impact on legal environment. the SSPVEG landscape in South Africa. The draft NRS097-2-1 standard proposes the SSPVEG mechanisms Branches: following small-scale EG categories (in line Cape Town | Gauteng | KNZ with the renewable power plant grid code): Self-consumption Head Office: Category A1: 0 – 13,8 kVA In the self-consumption mechanism, solar Tel: 021 700 4380 Category A2: 13,8 kVA – 100 kVA PV electricity is self-consumed during the day by residential or commercial consumer Category A3: 100 kVA – 1 MVA as shown in Fig. 1. www.tank.co.za

Most residential consumers are currently The SSPVEG installation is conservatively Authorized Distributors: installing small-scale solar PV EG systems sized to supply a portion of the load only and in the A1 category and most commercial not with the intention to export electricity consumers are currently installing SSPVEG to the grid. Where SSPVEG generation systems in the A2 and A3 categories even in does exceed the load, the Prosumer is not the absence of finalised SSPVEG regulations reimbursed and is content to supply the ESETA & SABS ACCREDITED and legislation being in place. grid with electricity without being financially From a legal/regulatory perspective, compensated.

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NRS097-2-3 recommends simplified As in the self-consumption and net-metering [4] T Bischof-Niemz, “How to stimulate the connection rules as follows: “an individual mechanisms described above, the kW rooftop PV market in RSA without putting munics’ profits at risk”. Johannesburg. 10th [EG connection] limit of 25% of NMD size of the SSPVEG installation can be December 2013. will typically support a penetration level limited to 25% of the prosumer NMD or [5] WG vote draft NRS 097-2-1:2013 Edition (percentage of customers that install incoming circuit breaker rating. Similarly 2. Grid Interconnection of embedded a generator) of 30% to 50%, which is to the net-metering mechanism, the generation. Part 2: Small-scale embedded generation. Section 1: Utility interface. considered a reasonable and acceptable prosumer applies to its connected utility compromise between restricting [6] NRS 097-2-3:2014 Edition 1. Grid for bi-directional meters via the necessary interconnection of embedded generation. individual generator sizes versus restricting application forms. Part 2 Small-scale embedded generation. penetration levels”. “The NMD in many cases Section 3: Simplified utility connection criteria is determined by the LV service connection for low-voltage connected generators. circuit-breaker rating”. This approach Financial considerations [7] Self consumption of PV electricity. Position paper. July 2013. European Photovoltaic simplifies the after diversity maximum Annual national electricity usage dropped Industry Association (EPIA). demand (ADMD) system overloading risks for the first time in 2013 and several [8] Municipalities urged to fast-track incentives and allows more freedom for SSPVEGs to metropolitan electricity departments have to control solar PV, Engineering News Article, connect to the grid without lengthy system reported drops in their electricity sales in the 20th Nov 2013. analysis and approval processes. last four years as a result of higher electricity [9] Rooftop solar PV, an awakening giant, Mike Rycroft, Energise, Jan/Feb 2012. In the above arrangement/s, the prosumer costs and EE measures undertaken by [10] City Power Johannesburg. Tariffs and notifies the municipality or connected utility consumers e.g. light emitting diode (LED) Charges 2013/2014. www.citypower.co.za. that solar PV for self-consumption purposes and compact fluorescent light (CFL) lighting, [11] VDE-AR-N 4105:2011-08. Power generation has been installed. Notification procedures solar water heating (SWH) and heatpumps. systems connected to the low-voltage could align with certificate of compliance Therefore, a reduction in municipal revenue distribution network. Technical minimum requirements for the connection to (Annexure 1) and application for inspection is a reality that is occurring and needs to be and parallel operation with low-voltage authority (Annexure 2) forms as included in accommodated and confronted with or distribution networks. SABS 0142. without the introduction of SSPVEG. [12] The doping effect of Italian feed-in tariffs on the PV market, Antonelli, M, Desideri, U. In all three of the SSPVEG mechanisms Energy Policy 67 (2014) 583 – 594. Net metering described above, the question of loss of [13] Grid connection code requirements for In the net metering arrangement, the revenue exists. For every kWh not purchased renewable power plants (RPPs) connected to the Transmission System (TS) or the prosumer both imports and exports electricity from the municipality, the municipality Distribution System (DS) in South Africa. from and to the utility grid and expects to be revenue base is reduced. [14] Distribution network code, Version 6, August compensated for net electricity exported to 2011, RSA grid code secretariat, South Africa. Editors note: A full discussion of loss of the grid as shown in Fig. 2. The utility meter [15] Distribution standard for the interconnection revenue due to SSPVEG and possible ways of embedded generation, DST 34-1765, is upgraded to a bi-directional meter, and to mitigate this is found in the article: “Small March 2008, Eskom Standard. the net result of the monthly or other periodic scale on-grid solar photovoltaic embedded [16] DST 34-1665 – Distribution Standard for the electricity import or export usage is charged generation in South Africa- methodologies Interconnection of Embedded Generation or compensated to the prosumer. (DSiEG): Installations 100 kW – 1 MW. to stimulate the market” by the same [17] Telephone discussion with Jaco Botha of As in the self-consumption mechanism author, published in the May 2014 edition Solareff (Pty) Ltd, 24th March, 2014. above, the KW size of the SSPVEG installation of Energize magazine. [18] The SABS (2012), SANS 0142-1:2012, The can be limited to 25% of the prosumer NMD wiring of premises, ed. 1.8, ISBN 978-0626- 26767-4. or incoming circuit breaker rating. In this Acknowledgements [19] Constitution of the Republic of South Africa, arrangement, the prosumer applies to its The author is grateful for comments and No. 108 of 1996. connected utility for a bi-directional meter advice from the following people: Jarrad [20] Small-scale renewable energy standards via the necessary application forms. and specifications, published 1 June 2012), Wright, Gerhard Botha, Maree Roos, Davin Eskom. Chown, Andrew Janisch, Chris Haw, Jaco Feed-in tariffs (FITs) [21] Standard conditions for embedded Botha and Frank Spencer. Jarrad Wright generation within municipal boundaries, National Energy Regulator of South Africa, The FIT mechanism attempts to promote also commented on an early draft of the 22 September, 2011. and incentivise the deployment of RE and paper. [22] Eskom tariffs and charges booklet places an obligation on specific entities 2012/2013, extracted on 30th March 2014, e.g. municipalities or utilities to purchase References www.eskom.co.za/tariffs. the electricity output from qualifying RE [1] Integrated resource plan for Electricity – [23] Electricity regulation act 4 of 2006, as amended by electricity amendment Act generators at pre-determined premium 2010-2030, Revision 2, Final report, 25th March 2011. 28 of 2007, http://www.nersa.org.za/Admin/ prices. In many countries, RE energy has Document/Editor/file/Electricity/Legislation/ [2] Integrated resource plan for electricity to be dispatched first if it is available. The Acts/ Electricity regulation 2006 (Act No 204 (IRP) – 2010-2030, Update report, 21st of 2006). consumption and generation of electricity November 2013. [24] Local government: Municipal Structures Act by the prosumer is recorded in full and billed [3] The Association of Municipal Electricity 117 of 1998, http://mfma.treasury.gov.za/ Utilities Southern Africa (AMEU), Guideline on and compensated. The prosumer therefore Legislation/lgmsta/ Pages/ default.aspx. the installation of embedded generation requires two meters as shown in one possible and the impact it may have on revenue Contact Paul Tuson, Tel 011 514-7200, meter arrangement in Fig. 3. of municipalities, October 2013. [email protected] ܀

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