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Draft Licensing Exemption and Registration Notice

The Draft Licencing Exemption and Registration Notice  gazetted today for public comment. The Notice articulates the intention of the DoE, in consultation with NERSA, to repeal the Exemption Notice published under Government Notice Number 1231 of 10 November 2017 and thereby amend it , by renaming it as “the Schedule” and to further determine that any generation facility within the scope of the schedule must register with the regulator.

The Schedule 2: Exemption from Obligation to Apply for and Hold a Licence, is provided as an annexure to the notice. The Schedule 2 includes changes with regards to its number sequencing, the exemption of back-up and stand-by generation facilities from licencing and registration and the regulation of the relationship between reseller ad licenced distributor.

Through our engagement with both DoE and NERSA, it is expected that NERSA will provide clear rules of registration directly after the 30 day public consultation process of the notice above. It is also expected that NERSA will indeed draft and publish the re-seller rules concurrently and this will include the TWA Rules of 2012.

It is important to note that DoE and NERSA are also working on the extension of “the Schedule” to include the 1-10MW category.  As indicated by DoE previously, there would be a “Licence Lite” process to this category and will allow NERSA to determine this process. It is further expected, based on our engagement with DoE to date, that the DoE will, through the IRP, indicate the removal of a ministerial determination requirement for this category.

As we eagerly await the new IRP in August 2018, we will continue to put forward a strong position to have an open SSEG market.  As it stands, it is understood that there will be no limiting allocation or caps on these categories.

SAPVIA have engaged the DoE and NERSA and welcome their openness to consult and we believe that this is indeed a step in the right direction. We have found consultations to be positive and future thinking for the best of the industry.  Through our own PV GreenCard initiative we have recognised the need for the registration of systems and will fully support the NERSA to make this a streamlined and efficient process.

Should you have any comments on the Draft Licencing Exemption and Registration Notice and/or the annexed Schedule 2 please do share this with us at kim@sapvia.co.za for consolidation and submission. We would like to make our contributions to the DoE by 02 July 2018 and would appreciate if you could get your comments to us well before this time.

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