South African Renewable Energy Feed-in Tariff

Implementing feed-in tariffs in a country is a political process, which involves many interest groups like electricity generating industry, financing institutions, renewable energy industry and non-governmental organisations. When a basic form of feed-in tariff is chosen according to policy objectives, many details (included technologies, amount of payment for different technologies, pre-qualification of projects for payment agreements etc.) have to be determined and tested. If the selected settings do not result in a development of renewable energy project, the tariff system has to be revised.

As and example for the development and application of a new feed-in tariff system, this article describes the tariff concept in South Africa.

South African Renewable Energy Feed-in Tariff

At the end of 2007, the National Energy Regulator of South Africa (NERSA) commissioned the development of a Renewable Energy Feed-in Tariff (REFIT) for South Africa, under its authority to regulate electricity tariffs in the country. The feed-in tariff requires the Renewable Energy Purchasing Agency (REPA), in this case Single Buyer Office (SBO) of the national electricity utility Eskom, to purchase renewable energy from qualifying generators at pre-determined prices. These predetermined prices act as an incentive to renewable energy developers and private investors by reducing financial risk and providing market certainty.

The REFIT was finally launched in March 2009 and is aimed at supporting the government’s 10,000 GWh 2013 renewable energy target and promoting competitiveness for renewable energy with conventional energies in the medium and long-term. The key objectives of the REFIT are to:

• Create an enabling environment for renewable electricity power generation in South Africa;
• Establish a guaranteed price for electricity generated from renewables for a fixed period of time that provides a stable income stream and an adequate return on investment;
• Create a dynamic mechanism that reflects market, economic and political developments;
• Provide access to the grid and an obligation to purchase power generated;
• Establish an equal playing field with conventional electricity generation; and
• Create a critical mass of renewable energy investment and support the establishment of a self sustaining market.

The REFIT only includes power generation from renewable energy generators connected to the transmission and distribution systems and thus excludes off-grid power generation. There is however interest in exploring a REFIT for the establishment of isolated mini-grids in the future to help address national issues related to access to electricity.

All renewable energy power generators under the REFIT will require a generation licence issued by NERSA and a Power Purchase Agreement (PPA) with the REPA. There are proposals that in the long-term, the REPA and possibly the SBO are to be housed external to Eskom to ensure greater independence.

In addition, in order to support the growing green electricity market, NERSA has also permitted independent power producers (IPPs) to sell power directly to entities willing to buy renewable energy outside the REFIT, provided that a generation licence has been granted.

Technologies included by tariff concept

Phase 1 of the REFIT was launched in March 2009, with four priority technologies, namely, landfill gas, small hydro, wind and concentrating solar power (CSP). These, were selected on the basis of the 2004 Department of Minerals and Energy (DME) financial and economic study which focused on the optimal mix of technologies required to fulfil the country’s renewable energy targets. Biomass pulp and paper and sugar bagasse were excluded from Phase 1, because of the inclusion of these technologies in the Pilot National Cogeneration Programme (PNCP) implemented by Eskom within the same period when the REFIT was being developed. However this programme was not successful in terms of getting projects off the ground.

Phase 2 was published in October 2009, following public consultation, and includes the following additional technologies:

• biomass solid waste, however pulp and paper, bagasse and projects based on mill waste from industrial processes remain classified as cogeneration and presently excluded from the REFIT;
• biogas through anaerobic digestion;
• building integrated and ground-mounted large-scale solar PV systems with a capacity greater than 1 MW;
• CSP with a capacity greater than 10 MW, mounted on a two-axis tracker on the ground; and
• CSP without storage and central tower technology (CTT) with six hours of storage a day.

Wave energy, tidal energy and geothermal renewable technologies are also excluded as they are presently viewed as non-commercial, but could be considered in the future.

Concentrating PV is also not included at this stage, owing to the high economic cost, and fossil fuel will be allowed for the CSP technology, but will be limited to a maximum of 15 percent of the total primary energy input.

Small scale grid connected PV systems are also not included under Phase 2, however NERSA has stated that small-scale producers are likely to be included in Phase 3 of the REFIT, due in the second quarter of 2010.

In addition to proposing the addition of new technologies to the REFIT, NERSA also published, for public review and comment, a draft PPA to assist in reducing the risk to developers and speed up the process of getting projects on line. The PPA was modified based on a PPA used under Eskom’s Medium-Term Power Purchase Programme (MTPPP) in 2008. The public comments received on the PPA will be reflected in the final revision of the PPA scheduled for the end of November 2009. The other commercial agreements such as direct agreement, fuel supply agreement and transmission connection agreement will be considered for inclusion in the PPA. NERSA has also indicated that the standardised Direct Agreement, Fuel Supply Agreement, Transmission Connection Agreement, and Transmission Use of System Agreement would be included as schedules of the PPA, in the first yearly review of the REFIT.

Tariffs set for the included technologies

The tariffs set out in the REFIT are generous when compared to international feed-in tariffs and cover the cost of generating renewable energy plus a ”reasonable profit” to encourage developers to invest. The tariffs are competitive globally and have been designed to take into account the higher risks associated with project development in a new environment, where there may be greater challenges in terms of finalising power purchase agreements and actually getting grid connection.

The table provides the REFIT Phase 1 tariffs, which have been published and gazetted by NERSA and Phase 2 tariffs, which have recently been published.

Renewable energy feed-in tariffs proposed for the western cape

	Technology	tariff [Rand/kWh]	tariff [€/kWh]
Phase I	Landfill gas power plant	0,90	0,09
	Small hydro power plant (less than 10MW)	0,94	0,10
	Wind power plant	1,25	0,13
	Concentrating solar power (CSP) with storage	2,10	0,21
Phase II	Concentrating solar power (CSP) without storage	3,14	0,32
	Biomass solid	1,18	0,12
	Biogas	0,96	0,10
	Photovoltaic systems (Large ground or roof mounted)	3,94	0,40
	Concentrating Solar Power (CSP) Central Tower with storage capacity of 6 hours	2,31	0,23

Key Issues of tariff implementation

Grid connection and Licensing Procedures

It is generally considered that there are three primary challenges to getting renewable energy generation on line, firstly the price (which is now being addressed by the REFIT), secondly the PPA (a draft is proposed under REFIT Phase 2), and finally the actual grid connection.

Although the REFIT guidelines provide a basic structure for the implementation of the programme, further clarity is still required on key issues such as the pre-qualification criteria, licensing process, and fixed timelines in South Africa. Some of these issues are presently under discussion.

• Pre-qualification criteria: This is still an issue which appears to be an ongoing debate and is of major concern to developers. In order to quantify the potential market and make sure only good quality projects are brought on line, it is understood that a pre-qualification process may be proposed as part of the REFIT application process. Although this issue has not been finalised, this could have the effect of discouraging a certain amount of investment in renewables and increasing risk to developers and investors. Experience in other countries in the establishment of FITs shows that certain parties, including utilities have also proposed combining a tender with a FIT, however this proved to be unworkable and was rejected. The integration of any tendering processes would also significantly increase the costs of project development and would also slow down the project development process. A decision on this issue is awaited.
• Single Buyer Office: According to a Cabinet paper, the national electricity utility Eskom was appointed as the single buyer of electricity in the country, with both the right and obligation to buy power. The need for a single buyer is justified in this country due to the small power market in which the various players operate. At present, it is considered that the market in South Africa is not large enough or diverse enough to sustain multiple power buyers.
  In response to this, Eskom established the Single Buyer Office (SBO). Under the REFIT, Eskom’s SBO was appointed as the REPA.
  The office is instrumental in facilitating investment in renewable energy in South Africa and because the SBO is critical for the take-off of the renewable energy industry and is responsible for the power purchase agreements between Eskom and IPPs, many industry players are calling for its independence from Eskom.
  Although there is general agreement on the need for an SBO, there are concerns and questions about its impartiality since it is established within Eskom, and that it will not favour or support smaller power projects.
  It is understood that there are proposals and discussions to house the SBO externally to Eskom, however no decision has been made to date, although it is understood that a draft bill has been proposed to establish an independent System Operator.
• Power Purchase Agreement: In order to provide greater certainty to developers and investors, it has been proposed by NERSA that there will be a standardised PPA. A draft PPA, based on the Medium-Term Power Purchase Programme (MTPPP), PPA was released for public comment in August 2009 and is expected to be finalised by the end of October of this year.
  The main concerns from developers about the PPA was the greater security and therefore limited risk it provided to Eskom, compared to that for developers.
• Project size: A small number of developers have raised concerns that the SBO may only be interested in larger renewable energy projects, with a suggestion that this may only include projects above 20MW. The REFIT however focuses on all projects above 1MW.
  
• Licensing procedures: It is expected that the detailed guidelines will be developed and published in the near future to assist and support project development in a clear and transparent manner. These guidelines will also need to clearly specify the detail application process, identifying the roles of particular stakeholders, and also defining the timelines for the relevant authorities to address and respond to the various issues.
  It is expected that these guidelines will also provide guidance on the specific obligations for the REPA, and therefore Eskom’s Single Buyer Office, to purchase power.
• Grid Connection: The REFIT states that the developer is responsible for the shallow grid connection and that the utility is responsible for any grid upgrades. Although this principle is agreed, the precise mechanisms have not been put in place. This is of particular concern to a number of wind developers who have some sites identified, but could be facing a four year delay, which is the present timeline for such network upgrades.

Cost Recovery and Capacity cap

To date, no PPAs have been signed by the SBO, due to concerns and a lack of clarity on the cost recovery mechanisms. Although the REFIT indicates that the costs of the REFIT will be recovered from all electricity consumers using existing pass-though mechanisms, there are concerns about the potential impacts on electricity prices if there is a high interest from developers and extensive project development. High electricity prices could have significant negative socio-economic impacts both for industry but also the country’s poor.

As a means to address this, proposals have been made to put in place limitations on capacity for the various technologies. The capacity cap was provided for in the initial guidelines to allow some measure of control for NERSA on power projects, with the overall aim of preventing significant increase in consumer electricity prices in the event of major take up of the REFIT. Although the level of the cap is not specified, NERSA has the mandate to exercise this if it is considered necessary.

The concern from developers is that irrespective of what the renewable energy resource availability is in the Western Cape Province and throughout the country, it is possible that there may be limits on the amount of renewable energy projects that NERSA will approve and licence and the SBO will contract to purchase electricity from.

A renewable energy installation cap under the REFIT for all of South Africa would lead to a finite amount of renewable energy projects which would be approved for the feed-in-tariff. This would provide major uncertainty for investors and developers and would remove long-term security for the programme. In other countries, the implementation of a capacity cap has caused programmes to stall and fail.

It is therefore important that there is further debate on how this cap will be set and the implications. The first step will be to get a comprehensive understanding of the potentially viable resource and the cost implications on national electricity tariffs. Based on price projections for conventional power, many of the REFIT technologies will be competitive in the short- to medium-term with only solar PV and CSP requiring mechanisms to limit consumer tariffs increases.

Small-Scale RE Projects

Since the introduction of the REFIT, there have been calls from non-governmental organisations, private sector, lobby groups and the general public to include small-scale projects in the REFIT, as these are presently excluded. NERSA has indicated that this will be included in Phase 3.

It is noted that there are two key challenges to small scale projects.

Firstly, under the Electricity Regulation Act (Act No. 4 of 2006), all generators connected to the national grid require a generation licence, issued by NERSA. For the numerous small-scale projects, this could pose a significant capacity burden on the Regulator in terms of processing the licences. It is possible for the Minister of Energy to issue a notice to exclude certain technologies for example small scale solar PV, however it may be more advantageous to establish a small-scale generation licence in order to monitor projects connected to the grid. Such a licence could be simplified in terms of the application and approval process.

Secondly, the role of Municipalities is of importance and needs to be taken into account as these are the bodies that manage many of the municipal electricity networks and would be the ones most likely to interface with small-scale renewable energy generators. Their precise role and potential obligations needs to be defined.

Other technologies

Although phases 1 and 2 provide a REFIT for a wide range of technologies, there are still certain omissions that could be brought on at a later date, for example wave, tidal, bagasse and pulp and paper waste. This needs further analysis to define the status of the technology development and also if the REFIT is the most appropriate mechanism for support in the short- to medium-term.

In addition, it is possible that an off-grid REFIT may be considered in the future for mini-grids and isolated grids, taking into account the need for increasing access to electricity across the country, but also using renewables as a cost-effective and sustainable approach.