Every time we mention the words SSEG and registration in one sentence to any of our clients their reactions range anywhere from mild bewilderment to surprise and at times outright suspicion. While there are some who are nonchalant about the whole procedure and could care less about the details a good number ask very pertinent and hard hitting questions.
Even though most of the questions levelled at us are fair they do at times seem to be fuelled by a mistrust of the authorities. Unfortunately, whether these misgivings are justifiable or not it isn’t our place to comment on government policies. However, we aren’t blind to the fact that the City of Cape Town’s timing to enforce registration couldn’t have come at a worse time. The country’s main power utility is beleaguered by problems that have no short term solutions and the power plants seem to be perched atop a rather capricious precipice hounded by the beasts of mismanagement, corruption and imminent failure. In light of this, there has been a rapid uptake of PV systems over the past year.
The country’s main power utility is beleaguered by problems that have no short term solutions and the power plants seem to be perched atop a rather capricious precipice hounded by the beasts of mismanagement, corruption and imminent failure.
While SSEG Registration may seem like the latest catch phrase engineered in the bowel’s of the City’s municipal machine it has been around for quite some time. An SSEG is simply a Small Scale Embedded Generator. From the terminology one can glean that it is an inference to any means of generating electricity ‘independent’ of the power grid such as PV systems and wind turbines. The city’s documentation defines ‘small’ as any equipment that generates electricity not in excess of 1MW of power. The word embedded references the fact that most of these systems are connected to the city’s grid primarily through the main distribution board of a property.
In 2010 the City of Cape Town passed a bylaw known as the Electricity Supply Bylaw. Section 39 of this bylaw prohibits consumers from connecting any electricity generating equipment to their installations(property)without prior written consent from the Director. The section goes further to state that application for consent has to be made in writing. Section 8 of The Electricity Supply Bylaw was later amended in 2017 to be more explicit about the requirements and procedures involved with SSEGs. The amendment seemingly eliminated the ambiguity of what a new electricity supply is. The language was changed to include not just ‘new’ supplies but ‘modifications’ done to existing supplies, which is what SSEGs do(are)in essence.
In light of this it isn’t unreasonable for the City to ask for PV installations to be registered with them. In their well publicised marketing campaign last year the city focused its efforts on educating the public on the dangers of unsafe PV installations and the need for their regulation. While this was in fact a noble effort and in essence true it wasn’t the whole story. The campaign served as an impetus to have property owners register their PV systems. Naturally, threats of disconnection did much to aid their cause.
The campaign served as an impetus to have property owners register their PV systems. Naturally, threats of disconnection did much to aid their cause.
One of the main problems with SSEG registration is the timing. For years PV installations have been set up without prior approval(Section 8, 39 Electricity Supply Bylaw)and largely the legislation surrounding this seems to have been ignored until quite recently. SSEG registration was, to borrow the latin colloquialisms, de jure but not de facto. There is plenty of blame to be passed around on all fronts from installers to consumers right back to the City. In essence we are all playing a game of catch up with regard to installations that are already in place but have not yet been registered.
SSEG registration is a multilayered process. First and foremost is filling out and submitting the application form for consent to start on a new installation. Originally the waiting times given by the city for an approval letter were between 3-4 weeks and more recently 5-6 weeks. In reality, some of the applications languish for months in the electricity department before initial installation approval is given. Assuming that the installation has been approved, all supporting documents have to then be submitted to the city including the SSEG Contract between the City(Director)and the consumer. Of these supporting documents the most important is the commissioning report from an ECSA (Engineering Council of South Africa) registered engineer. The report is filled out by the engineer on site after he/she has inspected the system installed and is satisfied that it is compliant with current regulations and that it is safe and in working order. The SSEG contract has to be handed in in person to the relevant electricity department(South, North or East).
While the procedure seems pretty straight forward, in our experience it takes months for everything to go through. In addition, if there are complications with regards to the equipment installed such as: inverters not being on the City’s pre-approved list, the process becomes protracted and more taxing on all involved. The city has worked to streamline the application process revising the application form twice. However, more work still needs to be done. There is also a disparity in how the different electricity departments handle the submitted applications. Some (one) of the departments seem to be more efficient than the other two. We will note however that the city has admitted to being overwhelmed by the number of applications being received.
To try to propose a way forward would be akin to madness. We are after all not legislators and to some degree value the bureaucratic processes involved.
To try to propose a way forward would be akin to madness. We are after all not legislators and to some degree value the bureaucratic processes involved. Having dealt with numerous applications we also appreciate the magnitude of the task at hand. Be that as it may the present process is inefficient at best. The prevalence of PV installations will only rise as the country’s power woes continue. While SSEG registration is only focused on the Western Cape the City envisions a near future where legislation put in place will be applicable not only in the Western Cape but beyond i.e. the rest of the nation.
However, before that, we would proposition the City to set up a meeting with a sample of PV installations companies to discuss any hurdles that either party has faced and work on solutions. After all, PV installation companies are the ‘men on the ground’ trying to win the war of profitability while navigating the boggy marshland that is legislation. If and when SSEG registration becomes mandatory across the entire nation the process shouldn’t buckle under the weight of its own ambition. The City of Cape Town should present an iron clad solution ready for implementation in the other municipalities in the country.
After all, PV installation companies are the ‘men on the ground’ trying to win the war of profitability while navigating the boggy marshland that is legislation.
If PV installation companies and their clients were to wait on the City for approval letters, as per bylaw, to commence on new installations most projects would never take off. Not at the current rate the city is churning out(or not)installation approval letters. While this may be trivialised to an issue that only affects the wealthy few and institutions which are able to afford PV installations the PV industry in South Africa is growing. This industry is becoming an important part of the country’s economy and its affiliate industries. Having to wait for an approval letter to start work in some cases would mean casual labourers go without employment in the ensuing weeks.
We aren’t advocating civil disobedience and we never will. However, we would encourage PV installation companies and their prospective clients to start the application process as early as possible perhaps even during the quotation process. This way all parties can avoid the anxiety of having to wait for approval before ‘switching on’ an SSEG.
Finally, this article was written in the hopes of dispelling any fears with regard to SSEG registration. It was also written to highlight the complexities of the process involved and as an informative guide to all parties involved. Feel free to email comments or queries to the author using the email widget on the page.
Disclaimers/Disclosure: The views expressed in this article are those of the author and do not necessarily represent the views of Greenability Installations(Pty). Greenability Installations(Pty) offers its existing clients and potential clients a service for helping with SSEG registration for a fee.