Review of the Electricity Regulatory Act and related Electricity Pricing Policy.

The Casting, Forging, and Machining Cluster (CFMC) is concerned that industrial users are burdened by municipal tariffs. The EPP promulgated in 2008 is largely ignored and is not seen as a policy directive but rather as a rough guide. The EPP has little relevance in the current process of setting municipal tariffs.

In many municipalities, these tariffs are poorly structured, not cost-reflective, and contain illegal and unrelated subsidies that lead to unjustified increases in production costs. Individual producers are unable to offset these costs through productivity increases alone. These unjustified increases in municipal and industrial tariffs and poor security of supply have led to an increasing loss of competitiveness of South African companies in the global market.

The current structures and pricing processes tax producers upfront for a small profit and serve to destroy the economy. The review document offers little, although the changes are exciting. CFMC believes that local governments need to be encouraged to follow the law and related guidelines. Enforcement of the guidelines is problematic. CFMC cautions that the ideals of a fair and equitable process will be further limited if deviation and non-compliance are allowed. Market corrections in the ESI will not necessarily benefit the industry. There is a risk that free-market outcomes will be compromised. The CFMC is concerned about the lack of controls on municipal electricity bills, which largely offset inefficiencies. And regardless, we do not have sufficient knowledge and information to have a constructive discussion on cost structures, cost drivers and unbundling.

Load curtailment is a valuable tool to encourage industrial users to reduce their load in times of need. CFMC is keen to work with municipalities to facilitate introducing such a programme in industrial areas.

In the past, Steve Tshwete Municipality has provided good support and acceptable (within the legislative framework) tariff increases to industrial areas. Security of supply remains a concern in light of the recent municipal strike and continuous vandalism of municipal infrastructure. The debate between the stakeholders must be held soon; our town needs its industries to remain economically viable.

A copy of the full submission is available to members at the MCCI secretariat; please contact us at info@middelburginfo.com.