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This document contains the Applicant's Heads of Argument and Practice Note filed by the City of Cape Town in the High Court of South Africa (Gauteng Division, Pretoria). The City is seeking a declaratory order regarding the interpretation of section 34 of the Electricity Regulation Act 4 of 2006 (ERA), arguing that a ministerial determination is not required for an independent power producer (IPP) to establish a new power plant and supply electricity to the City. The City contends that the current interpretation held by the National Energy Regulator of South Africa (Nersa) and the Minister of Energy is either legally incorrect or unconstitutional as it infringes upon the autonomy of local government.

This industry brief by GreenCape examines the financial viability of using battery energy storage systems (BESS) for tariff arbitrage in the Western Cape, South Africa. It focuses on leveraging time-of-use (TOU) tariffs to reduce energy costs by charging batteries during off-peak periods and discharging during peak periods, particularly as the decline in loadshedding has left many existing BESS installations underutilised.

This industry brief by GreenCape reviews water and sanitation by-laws across municipalities in the Western Cape, South Africa. It evaluates the completeness and clarity of these local regulations against a 2005 model by-law, highlighting the implications for businesses—particularly water-intensive industries—regarding fees, audits, industrial effluent, and alternative water sources.