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facility ," irrespective of size or capacity , which meets the criteria in paragraph 3 , is exempt from the licensing requirement .
In addition to the above , we note that the removal of the 100MW restriction also applies where a generation facility supplies electricity to one or more customers by wheeling , as was the case , with the previous exemption .
The Schedule 2 Notice also contains the following proposed changes that are worth noting :
• Connection Agreements will contain the conditions applicable to an end-user customer ; references to " energy storage " in paragraph 2.1 and 2.2 will be amended to refer explicitly to " battery storage ".
• We note that paragraph 3 still refers to " energy storage ", and not just " battery storage ". This potentially makes provision for pumped hydro storage , which in our view should be envisaged . However , clarity on the intention here should be provided ; and
• The following provision will be added to Schedule 2 ( paragraph 3.6 ): " Save for the licensing requirements , a registered generator shall comply with all applicable legislative and regulatory requirements necessary for the sustained operation of the national interconnected power system ." This provision seems to be intended to make it clear that exemption from licensing does not remove the need to comply with the applicable grid codes and any other applicable regulatory requirements .
The greatly anticipated removal of the 100 MW licensing threshold for embedded generation projects is a positive change that will further incentivise private investment in electricity generation and reduce the lead times to commence construction of projects . This , along with other proposed regulatory and legislative changes , should have a positive impact on South Africa ' s electricity supply crisis .
The changes proposed in the Schedule 2 Notice also pave the way for greater private sector participation in a future competitive power market – as foreshadowed in the draft ERA Amendment Bill published earlier this year .
Despite the positive proposed amendments , there are some remaining issues in the current Schedule 2 that are not addressed by the Schedule 2 Notice :
• Under paragraph 3.2 , it is unclear whether the reference to " where there is conveyancing of electricity through the transmission or distribution power system " is intended to exclude the operation of distribution lines that are not connected to the grid at all . In this instance , the electricity exported to the purchaser ' s system would not be conveyed through a transmission or distribution power system . We propose that this be clarified by the DMRE ; and
• a " reseller " under Paragraph 3.5 is defined as a person who purchases electricity from a trading entity to sell it to a customer , but “ trading entity ” is not defined . It is not clear which sellers of electricity would qualify as trading entities . We propose that this be changed to refer to a " trading licensee ". RACA
Image credit : Gerd Altmann | Pixabay
CHANGING PERCEPTIONS
There was a wealthy man who was continuously bothered by severe eye pain . He consulted with many physicians but no one could relieve his discomfort . He went through countless treatment procedures , but his pain persisted - and in fact worsened .
He looked at every available solution for his pain and after some time approached a man considered wise in the community who was renowned for treating odd illnesses . The wise man carefully observed the wealthy man ’ s eyes and offered a very peculiar solution …
The wise man told the wealthy man to concentrate only on the colour green for a few weeks and avoid all other colors . The wealthy man , now being desperate to rid himself of the pain , agreed and told the wise man he would go to any extent necessary .
The wealthy man then appointed a group of painters , purchased many barrels of green paint and instructed that every object his eye was likely to glance upon be painted green .
After a few weeks , the wise man came to visit the wealthy man to follow up on his suggestion . As the wise man made his way through the wealthy man ’ s house he observed the scene . Everything was painted green . As he came closer to the wealthy man ’ s bedroom he too was coated with a whole bucket of green paint . The wise man , puzzled by this behaviour , was immediately addressed by the wealthy man saying that he was simply following the advice .
Hearing this , the wise man laughed and said , “ If you had only applied some thought to my suggestion and purchased a pair of green-lensed glasses , worth nearly nothing , you could have saved a significant portion of money and efforts . You surely must know that you cannot paint the whole town green to solve your problems !”
The moral of the story is that no matter how ‘ desperate ’ you are - when you simply change your view of a situation , the whole process and outcome change accordingly - and that can mean preserving not only wealth but time , effort and resources that could be doing something of actual value . RACA
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