The goal of the proposed regulations, released recently for comment by the department, is to minimize load-shedding and thus improve the quality of electricity supply. The proposals focus on prohibiting certain practices that draw unnecessary loads from the electricity supply.

“We fully support the intention of the proposed regulations,” says SAPOA CEO Neil Gopal.

“However, we believe that the tone of the regulations is unnecessarily negative. A positive incentive would be more effective in encouraging good consumer behaviour.”

SAPOA identifies several specific sticking points in the draft regulations.

“We are concerned that terminology is not used consistently throughout the draft, and we would like to see a clearer definition of the requirements for legal compliance,” explains Tsakane Shilubane, SAPOA legal services manager.

He points to the example of Section 2(a) in the draft regulations, which refers to the management of lighting. The recommendations include: the prohibition of incandescent lighting; the prohibition of lighting unoccupied buildings; and the prohibition of street and highway lighting during daylight hours.

“The regulations don’t provide a good definition of energy-efficient alternatives to incandescent lighting,” points out Shilubane.

“They also don’t specify when the lighting of unoccupied buildings should be limited, especially where security is a concern, nor do they address whether street lights will be permitted in winter when days are shorter and darker.”

Another example is Section 2(b)ii which prohibits the installation of an electric geyser without solar heating in homes of more than R750,000.

“We believe this is very vague and requires clearer explanation,” adds Shilubane.

The differentiation between residential and commercial properties is another factor that requires greater clarity for the regulations to be effective.

“SAPOA is of the view that perhaps we need a more nuanced approach to electricity tariffs which promote demand-side management by different categories of users,” says Gopal.

“Implementing by-laws at a municipal level is also something that we believe is worth further consideration to reinforce demand-side management at the local level.”