OUTA files complaint against Eskom

Photo: Ian Landsberg

Photo: Ian Landsberg

Published Feb 21, 2017

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Johannesburg - On February 17, the Organisation Undoing Tax Abuse (OUTA)

lodged a formal complaint, evidence and detailed submission to the Competition

Read also:  Minister's Eskom support worries IPP

The Dentons investigation and report into financial,

operational and procurement irregularities at Eskom in the lead up to and

aftermath of load shedding in 2014/15;

The Deloitte report and subsequent investigation by the

Special Investigating Unit (SIU) into coal procurement irregularities before,

during and after the load shedding of 2007/8; and

The Public Protector's report on state capture in South

Africa, which had a heavy emphasis on the allegedly irregular relationship

between Eskom and the Gupta family, and led to the resignation of the former

Eskom CEO.

A summary of OUTA’s case against Eskom has been extracted

from its full submission to the Competition Commission, and is provided below.

Click here for the full submission by OUTA to the

Competition Commission

Summary of OUTA’s

case against Eskom

Electricity is a key input into the South African

economy. It was historically very affordable, leading to an energy-intensive

yet thriving economy.

Electricity prices have risen dramatically in the past

ten years, due amongst other things to the fact that Eskom has set out on a

new-build of power plants that is running severely over budget. It is also

likely that poor governance by Eskom’s leadership has fostered corruption and maladministration,

which has led to price increases.

At present, power from independent power producers and

especially renewable energy is considerably cheaper than new Eskom power, and

in many cases cheaper than Eskom’s average selling price of electricity.

Indeed, the cheapest renewable energy may soon be cheaper than Eskom’s average

cost of production.

This situation is likely to be exacerbated in the next

few years as Eskom is allowed by NERSA to again raise its price considerably in

order to recoup sunk costs.

Consequently, large consumers like municipalities and

energy intensive users could buy power from independent power producers at

costs far below the costs of buying from Eskom (about 25 percent now, perhaps

40 percent in two years).

Even if the costs of expanding and running the national

grid are compensated for, this price differential would remain significant.

This is due to the fact that Eskom is no longer a cost-effective producer of

electricity.

Eskom is however a vertically integrated monopoly. Its

generation division and its grid management functions are embedded within one

state owned enterprise.

Read also:  The Eskom dilemma

To protect the monopoly of its inefficient electricity

generation division, Eskom has been engaged in various abuses of its monopoly

position, and exclusionary acts that deny its competitors access to the

national grid.

Market abuse

The complaint is that Eskom is abusing its dominant

market position in the South African electricity supply industry (ESI) as a

vertically integrated electricity utility who is refusing to sign power

purchase agreements (PPAs) with independent power producers (IPPs) which have

been appointed by the Department of Energy (DoE) as preferred bidders in the

DoE’s renewable energy IPP procurement programme (REIPPPP) (Tender No:

DOE/003/13/14), in defiance of government policy and international conventions

signed by the Republic of South Africa, and in attempt to retain its historical

electricity generation monopoly for the long term and to squeeze out new market

entrants/IPPs and competition from the South African ESI.

The complaint is furthermore that Eskom is using the

abovementioned recalcitrance, media channels and selective facts (which are not

factually accurate regarding renewable energy IPPs) to attempt to influence the

policy debate on the country’s energy mix in its favour, which policy is

underpinned by the Integrated Resource Plan (IRP) 2010 and updates thereto,

most prominently the IRP 2016 just released for public comment.

The impact of this agitation may be that, while the

lowest cost electricity path for the country  as per the CSIR would see Eskom’s market share drop to

approximately 15 – 28 percent by 2050 (depending on who owns the gas fleet),

the building of a large nuclear fleet and continued reliance on coal power

would see them maintain a market share of approximately 55 – 70 percent,

depending on the exact scenario that unfolds and who owns the gas fleet. This

might extend Eskom’s market monopoly into the next century.

Eskom’s motive is clearly to ensure its dominant position

for the next 34 years at least but probably the next 70 – 100 years. If Eskom

succeeds in including the unneeded and very expensive nuclear programme in the

IRP and/or to continue with such procurement in circumvention of the IRP, its

dominant market position will be assured for this period of time unless they

meet with insolvency, at great cost to the country and its tax payers.

Section 8(b) of the Competition Act prohibits a dominant firm from ‘refusing to give access to an essential

facility when it is economically feasible to do so.’ The national grid

is submitted to be an essential facility – 'an infrastructure or resource that cannot reasonably be duplicated,

and without access to which competitors cannot reasonably provide goods or

services to their customers'.

As appears from the totality of the documentation

submitted:

Eskom is a dominant firm

 –

Eskom’s own website indicates that they generate approximately 95% of the

electricity used in South Africa and it is undisputed that they have a complete

monopoly on transmission and is seen by government as the ‘Single Buyer’ of electricity;

that refuses to

give access – It is clear that Eskom is: refusing to sign

agreements with IPPs named as preferred bidders under Rounds 3.5 and 4 of the

REIPPPP; is defying ministerial determinations to so; is ignoring communication

from the DoE’s IPP Office attempting to get these projects to financial close;

has been actively and over time seeking ways to stop issuing budget quotes for

connecting to the grid to these companies; and has been programmatically

allowing existing and binding budget quotes to lapse;

to competitors –

The IPP’s are clearly competitors that are incrementally removing Eskom’s

position of dominance as they become operational;

to an essential

facility - The national grid is an ‘essential facility’ – ‘an

infrastructure or resource that cannot reasonably be duplicated, and without

access to which competitors cannot reasonably provide goods or services to

their customers’;

while it is

economically feasible to do so – From a national perspective, the

CSIR has shown definitively, as has the  work done on the IRP at the request of the Ministerial Council

on Energy (MACE), that a gas and renewable energy future is by far the

lowest cost for the country. Thus, it is clearly financially feasible for the

country to go down this road that Eskom is trying to scupper. From Eskom’s own

perspective, it is a national utility that is supposed to serve the country,

and is wholly owned by government. Its finances are governed by legislation and

Eskom is essentially allowed a certain return on capital deployed which is paid

for by Nersa setting electricity rates at a level that would give Eskom their

legislated return. It is clear that the costs of connecting IPPs to the grid

and also the impact of any loss of sales that Eskom may incur through IPPs

coming in all go into the calculation of the electricity tariff that is passed

through to the electricity rate payers of the country. Under recoveries and

over recoveries are equalised in time through the Regulatory Clearing Account.

Eskom at present is over recovering but in the long run will still be brought

back to its regulated return. Eskom’s absolute profit is a function of its

market share (capital deployed) but it should not be Eskom’s aim as a national

utility to remove all competition. The  Government White Paper on Energy Policy of 1998 envisions

exactly the opposite.

TAKING ACTION: Outa’s Wayne Duvenage

Moreover, with reference to section 8(c) of the Competition

Act which prohibits a dominant firm from ‘engaging in an exclusionary act’... if the anti-competitive

effect of that act outweighs its technological, efficiency or other

pro-competitive gain.

Refusing to sign PPAs is an ‘exclusionary act’ – it ‘impedes

or prevents’… IPP’s… ‘from

entering into, or expanding within the market’.

Nothing is gained for the country by Eskom’s behaviour

and it is imminently feasible for Eskom to welcome IPPs to the grid, as its

website purports to do.

Exclusion

Eskom’s exclusion of IPPs from the national grid amounts

to an exclusionary act that has an anti-competitive effect. The

anti-competitive effect of the act far outweighs any relevant gains.

The effect of Eskom’s abuse of its dominant market

position and exclusionary acts, if unchecked, would be that the South African

economy becomes hostage to Eskom’s steeply increasing price path, that the

country’s competitiveness is very likely to suffer, and that economic activity

would be suppressed and/or would decline to the prejudice of the common good in

the country.

Moreover, the nascent IPP sector would be destroyed and

the capital deployed there would be partially lost with the remainder being

deployed elsewhere in the economy or outside the country.

In the process Eskom’s prices would continue to rise

while the costs of domestic solar with storage would continue to drop, risking

a cross-over point at some time in the future where a sufficient number of

customers have chosen to leave the grid so that the remaining customers can no

longer sustain payment of Eskom’s fixed costs and marginal costs on a lower

base of sales.

At that point, on the present trajectory, the IPPs will

have been driven away and South Africa would be left with neither a functional

electricity utility nor a thriving private sector. Moreover, unless unbundled,

the Eskom’s grid operations would be compromised by the problems created by

Eskom’s generation division.

These abovementioned actions occur at a time where the

country has an opportunity to migrate to a modern and cheap electricity system

with affordable electricity, high sustainability and low levels of pollution.

This energy future  as detailed by the CSIR is dominated by gas and renewable

energy and requires Eskom to allow competition into the market.

Eskom is however agitating to keep competition out of the

market and to steer the country towards a nuclear/coal dominated energy future that

will cost the country approximately ZAR 90-billion per annum more than the

clean energy future dominated by renewable energy and gas, and enabled by

Independent Power Producers. The quantum of damage was  revealed by the CSIR at the IRP public hearings in December

2016.

For order of magnitude, evidence can be tendered that

shows that this amount, if not wasted, could pay or fund the following:

Free tertiary education for three times the number of

students South Africa has today; or

Three new Gautrain projects per year - or about 100

Gautrain projects by 2050; or

The proposed National Health Insurance scheme within 4

years, and 9 times over by 2050; or

Approximately 900 000 RDP houses every year, and

30-million RDP houses by 2050; or

Free tertiary education in South Africa, plus one

Gautrain every year, plus 90 000 RDP houses every year, and still fund the

National Health Insurance scheme within about 14 years.

Moreover, as detailed in the suite of documents

submitted, Eskom is claiming that as a grid operator it does not have the

capability to connect the new gas and renewable energy plants to the national

grid fast enough and that therefore, the vastly more expensive nuclear/coal

option should be chosen. This unsubstantiated and self-serving claim has now

led to an artificial and very low constraint being inserted in the modelling of

the country’s future energy blueprint (the IRP) that leads inevitably to a

modelling outcome steering us towards the expensive nuclear future.  See CSIR presentation to IRP 2016 hearings, December 2016.

Calls for fine

It is appreciated that the Competition Commission will

conclude the matter as it considers best, given its mandate. OUTA nevertheless

submits that the logical end-state in the energy sector would be the following:

Eskom should be fined now in order to signal that such

behaviour will not be tolerated;

Eskom should be unbundled so that its generation and grid

operations become the distinct endeavours of two distinct, state-owned

corporate entities. The Department of Energy or the National Treasury should

become the owner of the national grid company incorporating a market operator,

while the Department of Public Enterprises can remain as the shareholder of the

generation company ( see here for an extensive expert report on the matter);

In this manner Eskom’s present conflict of interest would

be removed, allowing the grid company to buy the most inexpensive power

available on the market;

Municipalities should in principle be granted ministerial

determinations to build their own generation plant or to buy directly from

IPP’s, as may start to become easier/possible given mooted amendments to the

Electricity Regulation Act that are in draft at present;

The resultant grid company must enable and facilitate a

rational integrated resource plan by buying the electricity that the plan

requires from both public and private electricity generators;

The Eskom decommissioning schedule must be completely

transparent to allow the grid operator to clearly understood in the national

interest so that we know when the existing capacity will disappear (or not) and

so that the required level of capacity can be maintained around it;

Investigation must be done into adding flexibility to the

Eskom coal fleet (e.g. the ability to operate at intermediate outputs and/or to

ramp up and down in response to demand) so that it can support the development

of a renewable energy dominated electricity system;

Any further Eskom new-build should be scrutinised to

ensure that the resultant electricity can be provided to the country on a

cost-effective and competitive basis;

The Eskom new-build at Medupi and Kusile should be

scrutinised vis-à-vis decommissioning schedules for existing coal plant to

ascertain whether some of the inefficient older plants can be commissioned

early alternatively whether some of the planned new units should be scrapped

entirely or can be postponed;

Electricity price increases could then be contained by

allowing low-cost alternatives to Eskom to gradually penetrate the generation

mix to a much greater extent;

Eskom’s amortised plant would still have an important

role to play in providing the national economy with low cost electricity until

such time as these plants are decommissioned;

Eskom’s sunk costs on plant not yet amortised could then

be amortised over an appropriate period of time and financed in a manner that

ensures that electricity prices stay stable and the competitiveness of the

national economy is maintained;

An assessment needs to be done to ascertain whether the

new Grid Company as a distinct entity from the existing Eskom would have the

required skill, ambition, money and know-how to expand and modernize the grid

as required by the future energy mix of the country. If not, competition should

be considered in that market and/or the entity might be replaced by an

international operator that is up to the task.

The above is enabled by unbundling Eskom into “GenCo” and

“GridCo”. The current internal conflicts of interest incentivise Eskom to act

in an anti-competitive manner and this can only be resolved by separating the

entity as described herein.

Mandate

It is submitted that the Competition Commission has the

mandate to do what is required as described above. It can fine Eskom and to

order Eskom to refrain from further abuse of their dominant position and/or

refrain from committing further and on-going exclusionary acts.

It is further submitted that there is no other remedy

than unbundling Eskom to ensure that abuses do not recur in future. This indeed

was the very reason why parliament approved the now-aborted ISMO Act. Eskom’s

conflict of interest runs so deep that only extreme bona fides on the part of

Eskom can avoid abuses as described herein.

At the moment Eskom is deeply implicated in fraudulent

practices by both the Public Protector’s 'State of Capture' report and the Dentons report. There is thus

no reason to believe that Eskom can be trusted to display bona fides.

The Competition Tribunal has the authority to order a

divestiture of shares, in terms of sections 58 and 60 of the Act. It is

submitted that the unbundling of Eskom into a “GenCo” and “GridCo” as described

herein would not amount to a ‘divestiture’ as the State would continue to hold

the shares in all assets presently owned by Eskom – the assets would merely be

placed in two distinct, state-owned enterprises preferably administered by two

distinct ministries.

It is submitted that the provisions of section 60 (2) –

(4) of the Act would consequently not apply to such an order.

It is nevertheless submitted that careful consideration

needs to be given by the Commission to what entities may need to be joined

should the matter proceed to the Tribunal, with the Republic of South Africa

being one possibility.

The Competition

Commission is requested to:

Investigate the complaint;

Move it to the Tribunal as expeditiously as may be

possible;

Fine Eskom, bearing in mind that a fine against the state

owned entity might not change the behaviour in that the fines may not be

punitive because the fines will be recouped from the public through tariff

increases to the consumer or via Treasury intervention;

Consider a recommendation for the unbundling of Eskom

Generation and Eskom Grid Operations into two distinct, state owned entities

with two distinct boards serving two distinct agendas;

Move for such additional and/or further relief from the

Tribunal as the Commission may see fit, given the imperatives described above.

In the event that the Competition Commission is of the

opinion that any of the relief requested herein is beyond the mandate of the

Tribunal to order (which is denied), the Commission is requested nevertheless

to move for such relief as may be competent at the Tribunal and in parallel,

without delay, in terms of section 21 of the Act is requested to investigate

the regulatory regime permitting the present abuse (section 21(k) would apply)

and to report same to the Minister of Trade and Industry, who would then table

the report in the National Assembly in terms of section 21(3) of the Act, thus

enabling the resolution of the matter by statutory means.

Note: The

above is a summary of OUTA’s case against Eskom, extracted from its full

submission to the Competition Commission.

Click here for the full submission by OUTA to the

Competition Commission

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