An Implementation Guide for Regulators and Policymakers Presented by Bernard Tenenbaum and Chris Greacen USAID E3 Energy Division Seminar Washington, DC—March 10, 2014 Co-authored with Tilak Siyambalpitya and James Knuckles Available for free downloading at From the Bottom Up: How Small Power Producers and Mini-Grids Can Deliver Electrification and Renewable Energy in Africa*

“We need megawatts, not megawords.” ~Zambian Government Official,

Outline Electrification: The Centralized vs. Decentralized Approaches SPPs/Mini-Grids and Regulatory Overview What is an SPP? 4 Types of SPPs and Overlap with Mini-Grids Regulation 3 Types of Regulatory Decisions Key Regulatory Issues Retail Tariff Setting To Regulate or Deregulate? Selling To and Buying From the Main Grid (Feed-In & Backup Tariffs) “When the Big Grid Connects to a Little Grid” The Case of Tanzania 3

The book’s focus is on regulation. But regulation is only one piece of the puzzle! Tanzania’s program 1. SPP regulatory framework developed by EWURA More complete than anywhere else in Africa. Goal: Light-handed regulation Process as well as prices. (Kenya versus Tanzania) 2. Grants from donors through REA or directly to M-Gs Connection grants (US $500 per new connection for mini-grids) Grants for feasibility studies (business plans and environmental assessments) 3. Availability of financing (equity, loans from local commercial banks supported by a US $25 million WB line of credit, risk guarantees) 4. Technical assistance for developers, the REA and the electricity regulator (side-by-side assistance not reports) 4

Electrification: Centralized vs. Decentralized Tracks Two Tracks of Electrification Decentralized Track Centralized Track Centralized Track Solar Lanterns Solar Home Systems Mini-Grids & SPPs Grid Extension – Main or Regional Micro- Grids ?

ATTRIBUTESTier-0Tier-1Tier-2Tier-3Tier-4Tier-5 Peak Available Capacity (W eq ) ->1>20>200>2000 Duration (Hrs)-≥4 ≥8≥16≥22 Evening Supply (Hrs) -≥2 ≥4 Formality (Legality) ---√√√ Quality (Voltage)---√√√ Appliances and services Task Lighting AND Phone Charging General Lighting AND Television AND Fan Tier-2 AND any low-power appliances Tier-3 AND any medium-power appliances Tier-4 AND any high-power appliances Possible electricity supply technologies Dry Cell (DC) Solar Lantern (DC) Recharg. Batteries (DC) Solar Lantern (DC) Recharg. Batteries (DC) SHS (DC) SHS (DC or AC) Micro-grid (DC or AC) Mini-Grid(AC) Grid (AC) Mini-Grid(AC) Grid (AC) 6 Levels of electrification—it is not all or nothing!

Micro-grid vs. Mini-grid

What is a Small Power Producer (SPP)? Small independently operated electricity generator (private, coop or community owned) Supplies and usually operates an isolated mini-grid or sells to a utility on the main grid or to an existing utility-owned isolated grid Usually defined by regulators according to size, fuel and technology (10MW or less?). Should include hybrid generators! AKA “distributed generation” (US and Europe) or “decentralized generation” or “decentralized distributed generation” (India) or “mini-grids” (worldwide) or “mini-utilities” (IFC 2012) 8

9 4 Types of SPPs / Mini-Grids Location of Generation Connected to Isolated Mini- grid Connected to Main Grid Nature of Customers Selling Retail to End Customer Case 1 SPP + M-G Case 3 SPP + M-G Selling Wholesale to Utility Case 2 SPP Case 4 SPP

Case 1— SPP selling at retail on an isolated mini-grid Small generator connected to a few kms of distribution selling to village customers. Best with an anchor customer. Electrification—direct. Cambodia (198, diesel, private), Mali (150, currently diesel, private, sell to about 15% of rural population) and Sri Lanka (250+, micro-hydro, coops). Case 4—Grid-connected SPP selling at wholesale to national utility A pure SPP (just a generator, not a mini-grid). No retail customers. Sells under a “feed-in tariff”(FIT). Sri Lanka (100+, mini-hydro, private), Thailand (264, mostly biomass, private), Tanzania (3, mini-hydro or biomass, private). Electrification—indirect or none. “I don’t want the headaches of selling to poor households.” Case ???—Small power distributors (SPDs) Buy at wholesale and resell at retail. No generation. Nepal (community), Cambodia (private), India (private franchisees?) and Bangladesh (coops). Africa-??? How promoted? Option 1-bottom up project-by-project (Tanzania). Option 2- top- down promoted concessions (geographic and local) (Senegal & Mali) Types of SPPs (continued)

Regulation “The less we have to do with government, the happier we are.” ~ Indian micropower developer, November 2012 “Regulation can provide a fertile ground. But regulation does not make a market.” ~ IFC Official, World Bank Group Workshop, January 30,

3 Types of Regulatory Decisions 12 Economic Technical Process Retail Tariffs (Cases 1 and 3) Cost of Interconnection (Cases 2 and 4) Feed-in Tariffs (Cases 2 and 4) Price of Backup Power (Case 4) Safety of Connections Voltage and Frequency Standards Relay Requirements for Different Generators Stakeholder Consultation Requirements Negotiated vs Standardized PPAs? Provisional License: Exclusive? How Long? Milestones?

Four Key Issues for Regulators 1.Retail Tariff Setting 2.To Regulate or Deregulate Small Isolated SPPs? 3.Selling To and Buying From The Main Grid (Feed-In and Backup Tariffs) 4.When the Big Grid Connects to a Little Grid 13

The Case of Tanzania

Good NewsBad News SPP program works… TANESCO is insolvent 15

300 kW – remote mini-grid 300 kW – remote mini-grid Target 1400 customers Target 1400 customers Mawengi village, Njombe, Tanzania Mawengi village, Njombe, Tanzania LUMAMA hydropower project 16

300 kW – remote mini-grid 300 kW – remote mini-grid Target 1400 customers Target 1400 customers Mawengi village, Njombe, Tanzania Mawengi village, Njombe, Tanzania LUMAMA hydropower project Mini-gridMain grid RetailCase 1Case 3 Wholesale to utility Case 2Case 4 17

Mwenga 4 MW hydro 800 households in 15 villages (expanding to 4000) & sells to the grid 18

Isolated mini-grid Main grid wholesale to utility Case 1Case 3 retailCase 2Case 4 19 Mwenga 4 MW hydro 800 households in 15 villages (expanding to 4000) & sells to the grid

TPC, Moshi 17.5 MW – selling 3-4 MW to main grid Cogeneration Sugarcane bagasse 20

TPC, Moshi 17.5 MW – selling 3-4 MW to main grid Cogeneration Sugarcane bagasse 21 Mini-gridMain grid RetailCase 1Case 3 Wholesale to utility Case 2Case 4

Regulatory & Commercial Framework Documents Main gridIsolated Mini-grid (off-grid) Standardized PPA* Standardized Power Purchase Agreement for Purchase of Grid- Connected Capacity and Associated Electric Energy Between Buyer and a Small Power Project Standardized Power Purchase Agreement for Purchase of Off-Grid Capacity and Associated Electric Energy Between Buyer and a Small Power Project Tariff methodology* (Feed-in Tariffs) Standardized Tariff Methodology for the sale of Electricity to the Main Grid Under the Standardized Small Power Purchase Agreements. Standardized Tariff Methodology for the Sale of Electricity to the Mini-grids Under the Standardized Small Power Purchase Agreements Process Guidelines (roadmap) Guidelines for Developers of Small Power Projects (SPP) ; Includes standardized forms Process rulesRules for Developers of Small Power Projects (SPP) Interconnection Guidelines* Guidelines for Grid Interconnection of Small Power Projects (Parts A, B, C) Interconnection Rules* Rules for Grid Interconnection of Small Power Projects (Not yet provided) Annual Tariff Calculations * (Feed-in-Tariffs) Detailed Tariff Calculations under the SPPA for the Main Grid for each year Detailed Tariff Calculations under the SPPA for the Mini-grids for each year 22 * Applies to cases 2 and 4 only.

Key Features of SPP framework (cases 2 and 4) 23 Small Power Purchase Agreement (SPPA) Buyer “must take” SPP’s output if SPP is connected to the main grid Term – 15 years (expanding now to 25?) SPPA type depends on context: (1) selling to an existing isolated mini-grid; (2) selling to main grid Isolated SPPA switches to Main grid SPPA upon interconnection with main grid Concern by some investors / developers: too simple to get international finance (?) Standardized Feed In Tariff (FIT) Methodology Avoided Costs of the Utility (possible switchover to technology specific FITs?) Local Currency Denomination Reflect Seasonality (Main Grid) Floor and Cap Prices Technology Neutral

Annual Feed-in-Tariff Levels (Calculated by EWURA for SPP wholesale sales) MAIN GRID TZS/kWh Mid Yr Rate (TZS/$) US$/kWh $0.073$0.079 $0.076$0.096$0.107 ISOLATED MINI-GRIDS TZS/kWh US$/kWh $0.253 $0.265$0.238$0.303$

SPPs in Operation (tiny.cc/SPPstats) ProjectMWType of Resource Grid typeStatus ACRA - LUMAMA 0.3HydroNew isolated mini(Case 4) In operation / community based TANWAT2.34Biomass – wood Main (Case 1)In operation. Selling 1 MW (2010) TPC Co- Generation 17Biomass -- Bagasse Main (Case 1)In operation. Contracted to Sell up to 9 MW to TANESCO Mwenga – Mufindi Tea 4HydroCases 1 & 3 In operation Ngombeni1.5Biomass – coconut wood Existing mini (case 2) In operation. 25

SPPs with signed PPAs (tiny.cc/SPPstats) ProjectMW export ResourceGrid typeExpected COD Symbion – KMRI Tunduru 0.3BiomassTANESCO isolated July 2014 Symbion – KMRI Kigoma 3.3BiomassTANESCO isolated Dec 2014 St. Agnes Chipole – Songea 7.5HydroTANESCO isolated Jan 2015 NextGen Solawazi2.0PVTANESCO isolated Jan 2015 Andoya Hydro Electric Co. 1.0HydroTANESCO Isolated Feb 2015 EA Power – Tukuyu10HydroTANESCO main Feb 2015 Darakuta Hydro0.24HydroTANESCO main Nov 2015 Mapembasi Hydro10HydroTANESCO main 26

Promoting Mini- and Micro-Grids Regulatory Actions Proposed in Tanzania Key regulatory issue Tanzania proposed regulatory action 1Retail Tariff Setting Do not mandate that the operator must charge the same tariff as the national utility. Allow operators to cross-subsidize between customer classes Allow operators to sign power sales contracts with customers above a specified kW without requiring prior regulatory approval. Allow operators to make loans to potential and actual customers to connect and to buy appliances and machinery. 2To Regulate or Deregulate Small Isolated SPPs? Exempt small system operators (less than 100 kW) from licensing and prior tariff approvals.

Promoting Mini- and Micro-Grids Regulatory Actions Proposed in Tanzania Key regulatory concern Tanzania proposed regulatory action 3Selling To and Buying From The Main Grid (Feed-In and Backup Tariffs) No peak power component to backup power tariffs if load factor <15%. (in late 2014 or early 2015…) Technology-specific feed-in tariffs (e.g. solar higher than biomass) with premium for projects that offset diesel. 4When the Big Grid Connects to a Little Grid Specify what rights isolated mini- and micro-grid operators have “when the big grid connects to the little grid.” (Example: conversion to SPD.) Require the national or regional utility to provide annual information on planned expansion of high and medium voltage grid in the short and medium term.

For more information, please contact: Bernard Tenenbaum: Chris Greacen: Tilak Siyambalapitiya: James Knuckles: Thank you

Annex

Issue 1: Retail Tariff Setting: The Revenue-Cost Gap “Mind the gap.” ~ London Underground announcement 31

Example: 300 kW hydro at US$4500 per kW (Cases 1)(Africa) USD 0.6 million in Rural Electrification Agency grants of USD $500 for each of the 1200 households the project serves Loan at 12% interest, 10-year tenor 32 Additional Donor Grant (USD) Commercial Tariff (USD/kWh) Residential Tariff (USD/kWh) Scenario 1none $0.153 National uniform $0.04 National uniform Scenario 2$160,000 $0.153 National uniform $0.04 National uniform Scenario 3$160,000$0.24$0.067 Retail Tariff Setting: Measuring the Gap

Retail Tariff Setting: Measuring the Gap (Scenario 3) 33

The project is commercially viable only if it receives a donor capital grant and it can charge retail rates above the “legal” or “political” uniform national tariff and it can cross-subsidize across customer classes (Scenario 3). 34 Retail Tariff Setting: Measuring the Gap

35 Five Recommended Regulatory Actions 1.Allow M-Gs to charge retail tariffs above the uniform national tariff if required to recover efficient opex & capex costs. 2.Allow M-Gs to cross-subsidize their retail tariffs (usually by charging businesses more than households). 3.Allow M-Gs to enter power sales contracts with businesses without requiring prior regulatory approval of contract terms. 4.Require M-Gs to charge tariffs that include depreciation on equipment financed through grants. 5.Allow M-Gs to recover the costs of on-bill financing for connections, internal wiring, appliances and machinery. Retail Tariff Setting: Closing the Gap

Issue 2: To Regulate or Deregulate Small Isolated SPPs? (“light-handed regulation to the max”) Regulator’s safe strategy: When in doubt, regulators will regulate. But this may not be a good decision. Arguments for (some) deregulation (“light-handed regulation to the max”): Successful decentralized rural electrification—little or no price reg (Cambodia & Sri Lanka) Substitutes exist & markets are “contestable” – Gov. of India Need to experiment with different business models (India: Husk Power vs OMC vs Gram Power) Administrative necessity (“too many to regulate”) 36

To Regulate or Deregulate? (continued) An example: the OMC Power (India) business model Hybrid generator (solar & diesel) selling to mobile tower owner/operator (anchor customer) under a long-term PPA Renting rechargeable battery boxes to village households & businesses that are delivered daily No deposit; no connection charge; no government subsidies(?) Regulation: multi-dimensional, not an “all or nothing” proposition Tariff regulation—No Licensing—Registration (informational) not licensing (approval) Safety regulation—Yes General recommendation: 5 year price tariff dereg with backstops for small private isolated mini-grids. Possible backstops: annual reporting, complaints by many customers, registration 37

Issue 3: Selling To And Buying From the Main Grid (Feed-In And Backup Tariffs) 38

Issue 3: Wholesale Sales to the Main Grid: Power Purchase Agreements 39 RecommendedNot Recommended Standardized for all SPPsPerformance requirements A duration long enough to repay project debt, and at least as long as mandated FIT availability A deemed generated energy clause (but utility must provide historical data on frequency and duration of interruptions) A “must buy” clause that obligates the utility to purchase all of the SPP’s power output A 50 percent discount on regular demand charges for backup power to SPP customers with a load factor <15% Eliminate demand charges for SPPs connected to unstable transmission systems and charge an energy charge higher than the energy charge paid by industrial customers.

The Backup Power Tariff Controversy When the Grid is Unstable Complaint of a grid-connected African SPP operator: “This is the ultimate indignity. I have to shut down because of a disturbance or lack of capacity on the national utility’s system. Even though he caused the problem, I am the one who gets hurt. And I get hurt in two ways. First, I lose revenues because I am not able to make sales. Second, I have to pay him high demand and energy charges under his backup tariff because I need his electricity to restart my generator each time the shutdown ends.” 40

Selling Wholesale to the Main Grid: Feed-in Tariffs (FITs) (Case 4) Tariff support mechanism for renewable energy generators or co- generators or hybrid generators. TZ(2012): Main grid-$0.096; Existing TANESCO Isolated Mini-Grid-$0.303 Based either on the value to the utility and/or society of the electricity generated (buyer’s cost) (Tanzania), or on the cost of electricity generation for each designated renewable or co- generation technology (seller’s cost) (Uganda) But who pays for the premium if the FIT exceeds the buyer’s cost? Donors’ proposed “top-up” program in Uganda. SPP developer: “The price is fine but how long will it take to get paid.” 41

Selling Wholesale to the Main Grid: Feed-in Tariffs (Case 4) Phase I + FITs are set at or below the buying utility’s avoided costs including tx savings (Tanzania) or technology specific levelized costs (Uganda) below the buying utility’s avoided costs. Phase II + Some FITs are allowed to exceed the buying utility’s avoided costs when funds for these higher tariffs are available. + Differences can be made up by outside donor “top up” grants This two-phased approach allows a country to “walk up the renewable energy supply curve.” 42

Feed-in tariffs (FiTs) are important but don’t forget about…. Guaranteed interconnection & pre-specified rules for sharing interconnection costs Guaranteed purchases (“must-take” requirement) Physical ability to receive the power Guaranteed sale of back-up power Pre-specified pricing formula for purchase of SPP’s power with adjustment mechanisms (FiTs) for life of PPA Standardized interconnection and operation procedures (see Guidelines on EWURA (Tanzania) website) 43

Selling Wholesale to the Main Grid: Technical Requirements The following technical requirements are recommended for SPP and main grid interconnections: Regulators and utilities can incentivize SPPs to produce electricity at certain times of day or in certain seasons. SPP power output quality must meet or exceed the main grid’s requirements, and protective relays should be in place to disconnect the SPP in the event of faults or unacceptable power quality. Main grid operators should be able to know SPP operating status. Meters should be capable of measuring the full range of electrical parameters, as well as imports from the main grid and exports to the grid. 44

Issue 4: When the Big Grid Connects to a Little Grid “Companies may fear that their investment in off-grid solutions may prove worthless if the grid is indeed extended.” ~ Alliance for Rural Electrification, Hybrid Mini-Grids for Rural Electrification: Lessons Learned. 2011, p

When the Big Grid Connects to a Little Grid: Business Model Options Business ModelGeneratorMinigrid 1. SPDScrapped or RelocatedUsed by SPD to resell electricity purchased at wholesale 2. SPPUsed to sell electricity to main grid No longer used, sold or leased to the utility to sell electricity to retail customers 3. SPP & SPD Combination Produces electricity for retail sales and sales to main grid and/or used as backup supply source Used to supply electricity to the SPP-SPD’s retail customers 4. BuyoutNo longer used or sold to utility 5. AbandonmentScrapped or relocatedScrapped 46

47 When the Big Grid Connects to a Little Grid: SPD Option “Small Power Distributor” Buys power at wholesale rates from the national utility and then sells it at retail rates to households and businesses in one or more localities. (Model #1 on the table.) SPDs are common in Asia (Nepal, Cambodia, Bangladesh and Vietnam). Under consideration in Mali, Cameroon and Tanzania. Special case: SPPs who convert to SPDs but maintain their own power supply as a backup supply source, for local voltage support and for possible wholesale sales to the national or regional utility. (Model #3 the table)

48 When the Big Grid Connects to a Little Grid: SPD Option

49 When the Big Grid Connects to a Little Grid: Distribution Margins Country Bulk Supply Tariff (US cents / kWh) Retail Sale Price (US cents / kWh) Distribution Margin (US cents / kWh) SPD Ownership Bangladesh3.70 (0-100 kWh) Rural Cooperatives Vietnam2.40 (0-50 kWh) 6.40 ( kWh) Cooperatives or Private Companies Nepal Community Associations Cambodia Private Operators

SPPs In Operation in TZ (July 2013) ProjectMWType of Resource Grid typeStatus ACRA - LUMAMA 0.3HydroNew Isolated (Case 1) In operation / community based TANWAT2.34Biomass –woodMain (Case 4) Selling 1 MW (2010) TPC Co- Generation 15BagasseMain (Case 4) In operation. Contracted to Sell up to 9 MWe to TANESCO Katani Power Plant 0.3Biomass – Waste New Isolated (Case 4) In Operation – Pilot, not connected to network Mwenga – Mufindi Tea 4HydroCases 3 & 4 In operation 50

SPPs with signed PPAs (July 2013) ProjectMWResourceGrid typeExpected COD Ngombeni Mafia1.4BiomassTANESCO Isolated June 2013 Sao Hill Energy15Biomass –wood (CHP) MainDelayed. COD ??? Symbion – KMRI Tunduru 0.3BiomassTANESCO isolated July 2014 Symbion – KMRI Tunduru 3.3BiomassTANESCO isolated Mar 2014 St. Agnes Chipole – Songea 7.5HydroTANESCO isolated Mar 2014 NextGen Solawazi2.0PVTANESCO isolated Nov 2013 Andoya Hydro Electric Co. 1.0HydroTANESCO Isolated Feb 2015 EA Power – Tukuyu10HydroTANESCO Isolated Feb

Necessary permits, clearances and procedures for application 52 EWURA license to operate Business license, tax registration, etc. Power Purchase Agreement (PPA)* Land title or lease Resource Rights (e.g. water rights from River Basin Water Office) Letter of Intent (LOI) (from buyer) Environmental and Social Clearance (NEMC) Building Permit Sequence is important to avoid competing claims on project sites