On 11 August 2023 NERSA invited public comments on the NRS 048-9 Electricity Supply – Quality of Supply: Code of Practice – Load Reduction Practices (Third Edition, 2023) (“Load Shedding Code”). The closing date for submissions is 22 September 2023. 

The Load Shedding Code deals with emergency load reduction and may take the form of load shedding or load curtailment. The Code was developed to address the need for a national code of practice for real-time emergency load reduction. The code addresses not only the power system requirement (the load reduction required) but how this is done and communicated to have the least negative impact on critical infrastructure. 

The Load Shedding Code proposed changes include:

• consolidation of the loadshedding stages into a single system from stage 1 to 16, restricting all licensees to using the system as specified in the Code;
• clarification on methods for setting baselines for curtailment customers;
• Increased control of how load shedding and load curtailment are determined and carried out, providing more stability to the network and more certainty to curtailment customers;
• Inclusion of the right for curtailment customers to reduce 50 % of their load in increments of 10% per stage (2 stages of loadshedding), up to stage 10;
• the specification of compliance and reporting requirements;
• guidance on the implementation of smart metering as a technology platform for reducing the impact of load shedding on customers; and
• extensive editorial changes to this specification.

In its consultation paper NERSA invites comments on the following issues:

• Do you think the Licensees should maintain, develop and execute their loadshedding plans according to the practices in this code?
• Do you think Licensees should report and communicate on mandatory load reduction as a requirement by this code of practice?
• Should various electricity utilities consider applications for variations and/ exemptions?
• Should NERSA consider applications for variations and/ exemptions if the applicant fails feels undone by the electricity utility?

NERSA proposes the following principles by each Licensee for load reduction:

Principle 1 – Protection of the automatic under-frequency scheme

• Automatic under-frequency load shedding is an immediate, reactive response to a sudden unplanned loss of generation that might otherwise compromise the system integrity.

Principle 2 – Equitable participation by all customer installations

• All customers should by default be shed, and such shedding shall be in terms of pre-defined load shedding schedules unless agreed otherwise in writing between the licensee and the customer in terms of the provisions provided in the code.

Principle 3 – Protection of critical and essential loads

• Critical loads and essential load requirements shall be taken into consideration to limit the potentially negative impacts of mandatory load reduction.

Principle 4 – Availability of load shedding schedules

• Load shedding schedules shall be proactively developed, maintained, and made available to customers.

Principle 5 – Nature of the load shedding schedules

• Load shedding schedules should be developed in such a manner to ensure standardization across all licensees.

Principle 6 – Declaration of a system emergency

• Mandatory load reduction in accordance with this code of practice shall only be instructed under a system emergency declared by the System Operator in the case of a national emergency and by the regional or local control room in the event of a regional or local emergency.

Principle 7 – Minimized impact on customers

• The execution of mandatory load reduction should be undertaken in a pragmatic manner to minimize the expected impact on customers, subject to the necessary system load reduction requirements being met. 

Principle 8 – Predictability and advance warning of load reduction

• The execution of mandatory load reduction should be undertaken in a manner that maximizes the predictability for customers and for those executing the load reduction, subject to the necessary system load reduction requirements being met.

Principle 9 – Customers participating in load reduction

• Customers who participate voluntarily in formal, real-time load reduction products designed to avoid declaration of a system emergency shall be excluded from early stages of load shedding in accordance with the provisions of this code of practice.

The Loadshedding Code also proposes specific reduction in load required to stabilise the system – from stage 1 to stage 16. The current edition only goes up to stage 8. The Third Edition provides protocols for an increase in load shedding from the current 8 stages to 16 stages, with 24 hours of rolling blackouts occurring in a 32-hour period if South Africa were to reach Stage 16. Stage 16 is not a certainty – however measures need to be in place to regulate such state of affairs. 

In relation to the 16 stages NERSA invites public comments on the proposed loadshedding reduction and if there some better acceptable methods to achieve the necessary reduction without compromising the grid stability and grid security?

The publication of the consultation papers means that NERSA has not yet formulated any opinions on the key aspects the Third Edition addresses – but is raising them so that stakeholders can give their opinions and input on these issues to assist NERSA to make a well-considered decision.

LnP Beyond Legal encourages all stakeholders to engage in a robust debate by provide NERSA with public comments on the issues raised in the consultation paper. The view will go a long way in informing NERSA’s decision on developing a code of practice that takes into account current market realities when it comes to load shedding. 

Feel free to contact one of LnP’s energy specialists to engage on matters arising under the proposed changes to the Load Shedding Code.