On 27 October, South Africa's Department of Electricity and Energy and the World Bank Group hosted an online workshop on the draft National Energy Efficiency Strategy. 957 people registered for it. The draft sets a target of 132 petajoules of avoided final energy demand by 2035, about 37 terawatt-hours. Its diagnosis is more useful to Nigeria than its target.
The draft explains why South Africa's earlier efficiency strategies under-delivered. The constraint, it says, "has not been technical potential, cost-effectiveness or awareness of the opportunity, but the absence of adopted instruments, assigned responsibility, durable financing and verified measurement." Later it is blunter: "Timely and accurate data is the single most consequential enabler of this Strategy, and its absence is the most serious gap identified in Part Three."
This piece is about the last item on that list, verified measurement, and why it matters for a Nigerian programme that pays part of its grant a year after commissioning. Two notes first:
- The quotations come from the draft strategy (Version 1, dated 1 August 2026), which DEE has published for public comment. I read it on 28 October. Page numbers are the draft's printed ones, and sources are listed at the end. The draft may change.
- Gen318's commercial interest is stated at the end.
What South Africa found when it went looking for data
The draft rates South Africa against sixteen indicators from the World Bank's RISE framework. It adds that its ratings are the authors' own and "do not represent official RISE scores, nor do they constitute an endorsement or position of the World Bank Group". Two of the red ratings concern measurement:
- Large energy users. South Africa "has virtually no mandatory energy efficiency requirements for large energy consumers. There are no mandated energy audits, efficiency targets, energy management systems, or measurement and verification programmes for large-scale users" (p. 26).
- Energy statistics. National energy balance information is not timely and lacks accuracy, and "There is also no centralised and up-to-date repository for energy data" (p. 28).
Its list of barriers is blunter: the available data "is incomplete and inconsistent, hindering evidence-based policymaking, baseline setting, and programme targeting" (p. 23). The executive summary shows what that costs: "Agriculture and power generation still require stronger data before numerical targets can be finalised" (p. 7).
What it plans to build, and in what order
The draft does not respond with a new technology. It responds with sequencing:
- Year 1 (2026/27). Adopt a monitoring and evaluation methodology "before programmes scale, so that every intervention launched under this Strategy carries a measurable baseline from day one" (p. 55). Promulgate regulations on the mandatory reporting of energy data, and require large users to complete energy management plans.
- By 2028/29. Commission the first version of a National Energy Data Repository and field the first national energy consumption survey (p. 56).
- Money that depends on measurement.
- A government-backed Super ESCO with "robust MRV protocols".
- Utility efficiency obligations under "standardised measurement and verification under SANS 50010".
- A simpler claiming route under the Section 12L tax allowance, which gives a deduction of 95 cents per kilowatt-hour of verified savings (p. 26). Smaller projects would use "deemed savings or standardised baseline approaches that cut M&V costs" (p. 40).
The phrase that matters is "from day one". A baseline is cheapest to record before an intervention starts; built later, it rests on bills and estimates. An operating record has no such fallback: a month a site did not log cannot be logged later.
The Nigerian programme with the same dependency
DARES is the $750 million mini-grid and off-grid programme the World Bank finances in Nigeria. As dispatch 12 set out, its project appraisal document says the grant for isolated mini-grids "will be disbursed against two pre-defined milestones: commissioning and customer connections, and upon meeting a certain capacity utilization factor one year after commissioning." The same document says that "smart meter integration with Odyssey will be required from mini grid projects in order to verify electricity consumption".
DARES is not South Africa's strategy, and I am not claiming it has South Africa's data problem. The appraisal document plans for metered verification, which is the kind of measurement South Africa says it lacks. The point is narrower. By design, the second DARES payment rests on a utilisation figure measured a year after commissioning. Like South Africa's targets, that figure is only as good as the record behind it, and the record has to begin at commissioning.
So the question South Africa has just asked itself in public is a fair one for every DARES developer to ask privately: when the one-year milestone falls due, what will the record for each site show, and how much of the year will it cover?
Three labels every reported figure needs
South Africa's draft and the Nigerian programme point to the same three disciplines. None of them is specific to any product.
1. Say what kind of number it is. The draft's deemed-savings route for small 12L claims is sensible: measurement costs money, and small projects cannot carry it. But a deemed saving is an estimate. If deemed and measured savings are added together, a national progress report cannot say how much of the total was measured. Label each figure as measured or deemed, and keep the two in separate lines.
2. Say how much of the data arrived, and never record a gap as zero. A meter that should report every fifteen minutes and reports once an hour has delivered a quarter of its data. A check on what did arrive can still pass at 100%. Completeness has two parts: the share of expected readings that were received, and the share of received readings that passed checks. Neither can stand in for the other. South Africa's complaint that its data is "incomplete and inconsistent" is close to these two parts. A gap should be stored as a gap: a zero reads as "no consumption" or "no supply", and lowers a baseline or raises an outage count without anyone deciding it should. This is cheap to require in a reporting regulation and very expensive to correct in a national database afterwards.
3. Say how well the baseline fits. A facility's consumption can fall for reasons unrelated to the measure: lower output, a cooler year, fewer occupants. A savings figure should say whether its baseline was adjusted for those, how well that baseline fitted the data, and how wide the uncertainty is. ASHRAE Guideline 14 and LBNL's acceptance guidance describe the usual measures: R², CV(RMSE) and NMBE.
Gen318's interest
- Gen318 builds software that keeps operating records for solar, battery, generator and metered sites in Nigeria. It reports data completeness both ways and keeps missing data as missing. We have a commercial interest in this argument.
- Our product only partly matches this. It does not yet adjust a baseline for output or weather, or report the baseline's fit. Today's diesel-savings figures use a flat baseline and are graded as modelled.
- We have no commercial presence in South Africa. We are preparing a comment on the draft, on method only, along the lines of the three labels above.
- None of the three labels requires Gen318. Any developer, regulator or funder can write them into a reporting template with the systems they already use.
One question for DARES developers. Before your first site is commissioned, decide what its one-year record will contain and how you will show how complete it is. The cheapest day to start that record is the first one.
Corrections to anything above are welcome and will be listed.
Sources
Fetched and read on 28 October 2026. The draft strategy, the comment notice and the World Bank appraisal document are primary sources.
- Draft National Energy Efficiency Strategy 2025–35, Version 1, 1 August 2026 (DEE, PDF): the diagnosis (p. 30); the data gap (pp. 23, 28, 53); agriculture and power generation (p. 7); large users and the 12L deduction (p. 26); the Year 1 and 2028/29 sequencing (pp. 55–56); the Super ESCO, obligations and the 12L deemed-savings route (p. 40); the RISE disclaimer (p. 24); and the 132 PJ / 37 TWh target (p. 7)
- Notice of the draft strategy for public comment (DEE, PDF)
- EE Business Intelligence, report-back on the 27 October 2026 workshop (email to registrants, 28 October 2026): hosts (DEE and the World Bank Group), date and registration count
- Nigeria DARES Project Appraisal Document, P179687, 21 November 2023 (World Bank, PDF): grant milestones (p. 57) and smart-meter verification
- DARES (Rural Electrification Agency): the $750 million World Bank financing
- Acceptance criteria and documentation for M&V savings (LBNL, 2019, PDF): baseline fit measures, recommended guidance values (not pass/fail), and savings uncertainty
