Monday, July 16, 2018

A Swot Analysis Of The Meter Asset Provider Regulation (Part 1)

By Idowu Oyebanjo
The recently released Meter Asset Provider (MAP) Regulation by the Nigerian Electricity Regulatory Commission (NERC) in attempting to close the metering gap in the power sector has become inevitable because DisCos have failed to provide meters to consumers within the Nigerian Electricity Supply Industry (NESI) as anticipated by metering targets set in the performance agreements between Federal Government and Distribution Companies (DisCos).
As a result of this failure, estimated billing, electricity theft, meter bypass, illiquidity in the power sector, increased aggregate technical, commercial and collection losses (ATC&C) and consumer apathy towards the power sector reform have been some of the undesirable consequences. Lately, the National Assembly has determined to criminalise estimated billing in response to the cries of consumers nationwide who have in the last five (5) years remained unmetered, let-down and unprotected in the current regulatory environment. By this regulation, NERC aims to achieve revenue assurance within the NESI, reduce illiquidity, close the current metering gap of over 4.7 million meters within the next three years and eliminate estimated billing. It is therefore imperative to consider the Strengths, Weaknesses, Opportunities and Threats associated with the implementation of the MAP regulation.
The implementation of the MAP Regulation creates a different class of business for potential investors within the NESI otherwise referred to as Meter Asset Service Providers (MASPs). This aims to ensure the provision of an independent and competitive metering service that will be fair to both investors and consumers. By eliminating estimated billing, the regulator can much more readily appeal to the sense of justice of all consumers and secure their buy-ins into the financial, regulatory, commercial and environmental requirements of the power sector reform program. In this regard, the DisCos will be relieved of the huge financial and technical burden associated with financing, procuring, supplying, installing, operating, and maintaining electricity meters for consumers within the NESI. Attracting private investment in this manner into what is expected to be a viable metering business has the potential to service a 600 billion Naira market with the opportunity for employment creation and improvement in local content within the NESI as MASPs have to procure 30% of meters from certified local manufacturers. As DisCos are helped with metering, they stand the chance to more readily meet their business goals in the face of very much reduced apathy from consumers. An additional benefit for a “MAP consumer” is the preferential tariff to be enjoyed.

Protecting, securing and assuring the revenue stream within the NESI is fundamental to its survival. A successful implementation of both MAP and Eligible Customer regulations strengthens the regulatory framework of the NESI and provides a template for the privatization of other electricity utilities in Africa. This will be consistent with the principles enshrined in both the Economic Recovery and Growth Plan (ERGP) and the Power Sector Recovery Program (PSRP) in resetting the power sector reform and repositioning the Nigerian economy. Investor confidence will increase with the proper implementation of this regulation.

The MAP regulation can at best be described as work in progress. The implementation of the MAP Regulation as a full scale roll-out rather than a pilot which could have provided all stakeholders the opportunity to learn and perfect exigencies that may occur before full scale implementation is a weakness. The absence of a robust and central data aggregation and revenue assurance system for the NESI that MASPs can latch onto, the unavailability of Meter Service Agreements (MSA), Service Level Agreements (SLAs), and robustly specified metering codes and technical requirements are some other factors which need to be considered before full-scale implementation.

The experience of consumers during the botched Credit Advance Payment for Metering Implementation (CAPMI) scheme where customers paid for meters and some are yet to receive meters paid for after, in some cases, a decade is still fresh in many minds. Even so, there are questions about the transitional stage from being a “DisCo metered consumer” to a “MAP consumer” especially in terms of the payment of outstanding bills owed the DisCo by a conventional consumer who wishes to become a “MAP consumer”. This has to be settled.

The implementation of the MAP regulation will provide revenue assurance and cash flow that will assist with the liquidity problems facing the NESI. To be done properly, an effective consumer enlightenment and sensitization campaign to ensure customer buy-in is key. Thus, customers can be taking as very important, and they are, for the successful operation of a vibrant power system. This way, customer enumeration can be more easily accomplished.

The actual metering gap is more than the estimated 4.7 million. A recent report by Price Waterhouse Cooper (PWC) puts it as over 30million. This provides opportunity for a continuous business income stream for investors. Yes, financing MAP presents a unique and exciting opportunity because MASPs are the closest to the cash flow as they interface directly with consumers within the NESI. Saying that, the implementation has to provide a clear line of sight relative to the revenue stream, be of lower but calculated risk, and preferably not be negatively impacted by Forex. It is best for lending to be in Naira or where this is not the case, NERC can index to cushion the impact of foreign exchange. NERC will also have to ensure the sacrosanctity of contracts as well as the consistency, predictability and sustainability of the regulatory framework. As much as commercial Banks do not have the muscle to invest further in the power sector with their “fingers” already burnt, they should be able to provide working capital for MASPs where possible. In view of its fiduciary responsibility, it is only logical for institutions such as the Bank of Industry (BOI) to play a leading role in transactions of this nature.
The implementation of the MAP regulation opens up extensive employment opportunities, transfer of technology and know-how, training, etc for meter manufacturers, importers, installers, and vendors offering professional services in this area of the economy.
*Engineer Idowu Oyebanjo is a power system expert from the UK

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