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.

Strengths
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.

Weaknesses
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.

Opportunities
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.

Threats
The biggest threat to the implementation of the Meter Asset Provider (MAP) regulation is the regulatory inconsistency and policy summersaults for which the Nigerian Electricity Supply Industry (NESI) has come to be known in the eyes of the international community. What if, for socio-political reasons, the MAP regulation is withdrawn and the metering service charge removed some few months down the line post-investment? A related issue is around the ownership of meters to be installed. Will the consumer own the meter and carry it when they leave the property as was possible previously if they relocate within the same DisCo franchise area? Will the consumer pay for meters owned by others as well as pay for the electricity consumed (a service) and metering service rendered (another service) in the procurement of same service? Consumers may see this as a case of double-dipping! As the regulation makes provisions for consumers who wish to make an upfront full payment for meters, will such a consumer continue to pay for similar charges if they relocate elsewhere within the NESI? The best way around these and allied issues will be to decouple the consumer from the asset by means of a metering point administration number (MPAN) unique to every property to which electricity is supplied and metered. Theretofore, every consumer will pay a service charge for metering and this component can be included in the MYTO tariff structure. Also, the issues around customers who have paid for meters and are yet to receive them under the CAPMI scheme have to be resolved. There is the risk around sustainability of policies made in this regard and generally, within the regulated electricity supply industry in Nigeria.

The major stakeholders in the implementation of MAP are the consumers, the DisCos, the MASPs and the financial organizations who will provide funding for the investment required. To succeed, the process has to have a line of sight and be seen to be transparent.

The monies due to each party has to be handled by an independent and dedicated system or body which escrows the payments made by consumers and distributes to relevant parties based on a previously agreed sharing formula. The implementation has to be such that investors and financiers can have consistent cash flow and recoup their investment in reasonable time.

To this end, there is a need for a clear financial or capital structure in the implementation (debt and or equity) for MAP and financiers who will provide long-term loans at single-digit interest rates. Sadly, the Central Bank of Nigeria (CBN) that has been in the fore-front of the Nigerian Electricity Market Stabilization Aid, currently has a limited budget available to provide finance for Meter Asset Service Providers (MASPs). That said, the CBN is only prepared to provide funding in the form of re-financing for MASPs that can demonstrate viability and sustainability of their business model.

The time deadline provided for DisCos to procure the services of MAPS is one hundred and twenty (120) days following the 3rd of April, 2018 date of declaring the regulation. In comparison to the level of activities to be carried out for a competitively tendered procurement process and the number of certified MASPs for the entire country (22), this time is insufficient and need increasing. MASPs should also not be limited by the number of permits they have to obtain to accelerate the delivery of meters to cover the sure-to-increase metering gap. Also, economy of scale should be encouraged to ensure the warranty on installed meters are up to the shelf life, ten (10) years say, of installed meters.

For the general implementation of the MAP regulation to be a success, there is need for the proper monitoring and development of a competitive MAP procurement process. Nigerian Electricity Regulatory Commission (NERC) tenders’ auditors will ensure transparency and review the procurement process. Both pre and post-installation audits are imperative. MASPs must have the technical competence and financial capacity to carry out the intended services and the procurement process must ensure this is the case. We need to have genuine investors who will be willing to put money into investing in infrastructure, which in this case are the durable and fit-for-the purpose electricity meters for the NESI. This will also mean the power system will have a much desired enforcement system devoid of the corruption-ridden judicial system we have to day. The special court for the NESI will rely on the efforts of specially trained enforcement officers who will render swift services up to adjudication based on laid down procedures.

According to the regulation, consumers will have to pay a metering service charge (a lease charge) for the services provided by a MAP. In view of the level of consumer apathy today, and more so, as many consumers have paid for meters previously under the CAPMI scheme and are yet to receive the meters, there is an urgent need for an extensive enlightenment and sensitization campaign to be championed by NERC to seek the understanding of consumers nationwide. It is best to involve consumer advocacy and civil society groups, consumer protection council, and other affiliate organizations during the communication efforts to make this campaign a success. Yet, there is still the issue of consumers who reject the offer to have meters installed in their property. Thus, a robust enlightenment campaign for market participants and customer re-orientation to be championed by the DisCos and NERC is apt.

The absence of robust data and communication systems on which the stakeholders including the MASPs can leverage is another area of need. For the NESI to function optimally, and by extension for the implementation of the MAP regulation to be a success, there is a dire need for customer enumeration, consolidated with asset information systems. This provides an opportunity for DisCos to sponsor an energy networks association (ENA) to be saddled with delving into core technical problems within the NESI for and on behalf of the stakeholders. Issues to be looked at include but not limited to cost-reflectivity of tariffs, customer charging methodology, consolidated and centralized high-fidelity data capture of consumers and assets, technical policies for the successful operation of power assets and systems, specifications for plants, components and devices, research and development (R&D), investigation into failures and recommendations etc.

As metering services have hitherto been in the jurisdiction of DisCos, there will be cases of existing contracts with certain metering services providers that need to ultimately operate based on the MAP regulatory framework. While a process to ensure the sacrosanctity of such contracts has to be put in place, a cut-off date for migrating all such legacy metering services contracts to operate in line with the MAP regulation has to be determined. Such existing contracts between DisCos and their current metering service providers have to be declared to NERC now to preserve the integrity of the new regulatory regime.

Also, it is possible for a DisCo to frustrate the process of implementing the MAP regulation if for example additional mundane and impeding requirements are placed on MASPs in the procurement of their services as the regulator has only provided minimum requirements for MASPs with Discos at liberty to demand further requirements in conformance with their asset management policies. This has the potential to slow down the implementation of the MAP regulation. The antidote to this is the separation of the “wire” business of DisCos from the energy supply business to be provided by separate legal entities, owned by existing DisCos, MASPs or others. In addition, as MASPs have to procure 30% of meters from certified local manufacturers, a system has to be worked out to ensure that MASPs patronise local manufacturers of meters and if possible tracked by the regulator. Also, the percentage of local content involvement can be increased (or flipped) to make original equipment manufacturers (OEMs) to open shop in Nigeria which brings with it attendant employment opportunities and allied economic benefits that impact positively on the country’s GDP.

The absence of technical specification and standards of electricity meters to which MASPs must adhere leaves room for sub-standard meters to be installed within the NESI. This threatens the sustainability of the business for MASPs and may ultimately lead the consumers back to status quo. The required specifications will include requirements for technology, data management and communication systems. There is also the issue of collaboration between NERC and Nigerian Electricity Management Services Agency (NEMSA).

The MAP regulation is a step in the right direction towards entrenching full retail competition in the NESI as envisioned by the Electric Power Supply Reform Act (EPSRA) 2005 which has to be updated to reflect the changes brought about by the declaration of the eligible customer and meter asset provider regulations. Its implementation is only a part of the solutions to the myriads of problems bedevilling the power sector. Closing the metering gap does not in itself remove the problems associated with ATC&C losses, cases of electricity theft and meter bypass, low morale and deficiency in human capital resources within the NESI.
The next step in the direction of full-scale competition in the distribution system within the NESI will involve the separation of the “wire” services from the energy supply services to allow DisCos to carry lower risks and focus on the required investment in the operation and maintenance of the weak network infrastructure while reducing the aggregate technical and non-technical losses in the distribution network.

By: Idowu Oyebanjo
Engineer Idowu Oyebanjo is a power system expert from the UK.

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