Under Section 5 of the Nigerian Electricity Regulatory Commission’s (NERC) Order on Migration of Customers and Compensation for Service Failure Under Service-Based Tariff Framework 2023 (NERC/2023/003), the procedure for feeder migration between tariff reviews are as follows –
“5. DisCos that intend to migrate load clusters/feeders across service bands to provide committed service levels on a sustainable basis shall comply with the following procedures –
a. The DisCo shall file an application with the Commission for the proposed migration supported with the following –
(i) Name and location of the feeder(s) designated for migration.
(ii) Report on the metering status of the designated feeder(s).
(iii) Only feeders provided with smart meters shall be eligible for upward migration.
(iv) A report on the quality of supply covering a minimum period of two weeks confirming the eligibility of the feeder for migration.
(v) The current and proposed service bands along with the respective tariffs.
(vi) The number of customers affected.
(vii) The proposed effective date for the feeder migration.
(viii) Any other justification for the feeder migration.
b. The Commission shall review the application and issue approvals for satisfactory applications within ten (10) working days of the receipt of the migration request.
c. DisCos shall ensure that all affected customers receive notice of feeder migration at least five (5) days before the implementation of the approved migration. The communication by DisCos must indicate the name of the feeder, the affected areas, and the current and proposed tariff/service bands. Notifications shall be via bulk MS to all affected customers to be migrated. DisCos shall further utilise their websites and other possible channels, in addition to the bulk SMS for communicating and continuous engagement with the affected customers.
d. Implementation of the approved migration shall take effect from the 1st day of the billing month”.
NERC, in its bid to ensure that electricity consumers identify their feeders, has developed a feeder mapping or unified database alongside a uniform feeder nomenclature. A DisCo making an application is expected to employ the approved uniform feeder name for proper tracking.
All DisCos must meter all their feeders (11kVA & 33 kVA) and ensure such meters are smart via API (Application Programming Interface), which enables NERC to remotely monitor readings from all meters – vide KPI Performance Indicators. According to Section 5(a)(iii) above, a DisCo need not apply for upward migration of a feeder if a smart meter has not been installed at the feeder, even where such a feeder is qualified for an upward migration.
The DisCo is required to provide a report on the quality of supply covering a minimum period of two weeks confirming the eligibility of the feeder for migration. The Draft Guidelines for Migration of 2021 puts it this way –
“DisCos wishing to migrate a load cluster or feeder shall engage and communicate with affected customers in the load cluster (or feeder) to be migrated to a higher tariff service band no later than 14 days before the effective date of the proposed migration. The focus of the engagement and communication shall be the service commitment by the DisCo to affected consumers and the regulatory process in the event of service failure.”
The key issue here, whatever language the draftsman has employed, is the ability of the DisCo to “sustain” the service level of the proposed migration.
