Dear NERSA, public consultation takes more than a few days 

OUTA has asked the National Energy Regulator (NERSA) to reconsider the extremely limited consultation process it has started on its electricity division’s strategic planning.

NERSA announced the process on Twitter on 15 March and in an e-mail to stakeholders on 18 March. The NERSA consultation paper is dated 10 March but it does not appear to have been published then.

NERSA has set the deadline for public comment as 20 March and plans a public hearing for 24-26 March.

“This is really inadequate as public consultation. Even those who were alerted on 15 March have less than five days to comment while those alerted late on 18 March have just one working day,” says Liz McDaid, OUTA’s Parliamentary and Energy Advisor.

The NERSA consultation is about strategic planning for its electricity division. This includes a strategic assessment of the electricity supply industry (ESI), and challenges in the sector. NERSA has drafted seven broad questions for comment, including: What needs to be fixed in the ESI and how should it be fixed? What is working well in the electricity sector and why?

“OUTA appreciates NERSA’s intention in engaging its stakeholders in such an important matter as the substance of the discussions of widespread public interest. But for NERSA to condense the future of South Africa’s electricity system to eight questions (not seven as stated in the email) is highly questionable,” says McDaid in her letter to NERSA.

“OUTA calls on NERSA to recall its workshop invitation, to do its homework and then to publish its own position paper for consultation. We need to see the rationale for NERSA’s thinking in order to participate constructively. The attempt to reduce public consultation to one day must be rejected with the contempt it deserves.”

OUTA notes that NERSA has also issued limited period consultations on two more matters of significant public interest:

• Negotiated Pricing Agreements, with the consultation paper and call for comment published on 17 March, for comment by 1 April;

• The municipal tariff guideline increase consultation paper, published on 12 March with a hearing for stakeholders on 9 April.

“We call on NERSA to reassess the public comment periods on these matters of strong public interest, to provide more realistic consultation,” says McDaid.

OUTA’s letter to NERSA is here.

The NERSA documents are here.

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