CHAPTER FIVE

COMPARATIVE ANALYSIS OF THE FRAMEWORK FOR END-USE ENERGY

EFFICIENCY IN GHANA AND NIGERIA

5.1 Introduction
This chapter seeks to analyse and compare the existing frameworks for energy efficiency in
both Ghana and Nigeria. The aim is to point out where Nigeria is deficient and ultimately
learn from Ghana.
5.2 Grounds for Comparison

To embark on this comparative analysis, select grounds have been earmarked as the basis of
comparison, they are:

a. Legal frameworks
In Ghana, the Energy Commission Act, 1997 regulates the energy sector of Ghana. The
ECA was passed as a uniform act to regulate all forms of activities in the energy sector in
Ghana, ranging from the transmission, wholesale supply, distribution and sale of
electricity or natural gas,1 and the refining, storage, bulk transportation, marketing and sale
of petroleum products,2 while it also made provision for the promotion of energy
efficiency and conservation.3
Accordingly, the Act empowers the Minister responsible for Energy to have ministerial
responsibility for the Commission,4 while also empowering the Minister to, on the advice
of the Commission, make regulations in respect of electricity and natural gas, on the
conservation of electricity and natural gas5, and other related matters.6
Given Ghana’s drive towards implementing energy efficiency, in 2005, the Minister
responsible for Energy, relying on the powers vested in him by the provision of Regulation
56 (1) (a) (i) of the Energy Commission Act, and especially on the advice of the Energy
Commission, made the “Energy Efficiency Standards and Labelling (Non-Ducted Air
Conditioners and Self-Ballasted Fluorescent Lamps) Regulations, 2005 (LI 1815)”.
These regulations introduced the first sets of MEPS into the appliances market in Ghana.

1
Section 11 (a) ECA, Ghana
2
S. 11 (b) ECA
3
S. 42 (a) and S. 56 (1) (a) (i) ECA
4
S. 55
5
S. 56 (1) (a) (i)
6
S. 56 (1) (a) (ii) to (vii)
 This exercise of power was further exercised in the years 2008 and 2009, when the
minister further made the following regulations, also on the advice of the Energy
Commission, to wit:
a. The Energy Efficiency (Prohibition of Manufacture, Sale or Importation of
Incandescent Filament Lamp, Used Refrigerator, Used Refrigerator Freezer, Used
Freezer and Used Air-Conditioner) Regulations, 2008, LI 1932, and
b. The Energy Efficiency Standards and Labelling (Household Refrigerating
Appliances) Regulations, 2009 LI 1958.
These regulations all together were made to regulate the import, sale, and manufacture of
specific bulbs, non-ducted air-conditioners, refrigerators, freezers and refrigerator-
freezers in Ghana.7
In Nigeria, there is no one law that regulates the energy sector as a whole, rather, there
exists several laws that guide each sector individually.
The electricity sector in Nigeria however is regulated by the Electric Power Sector
Reform Act (EPSRA),8 an act enacted with the aim of transferring select assets of the
now defunct National Electric Power Authority (NEPA) to private companies.
However, there exists the Energy Commission of Nigeria Act.9 This Act established the
Energy Commission of Nigeria, and charged the agency with the responsibility for
coordinating and the general surveillance of the overall development of various energy
resources in Nigeria.
Although, the agency is empowered to make develop policies for the energy sector, for
which it developed the National Energy Policy 2003 and a revised version in 2013,
which both recognise the need for Nigeria to be energy efficient, there has been no law
developed from these policy solely for the regulation of energy efficiency in Nigeria.
What exists in Nigeria to date are policies which legally are not enforceable.
It must be noted however that in 2018, the National Assembly sought to amend the
Energy Commission Act by conferring power on the ECN to accord priority to the
promotion, regulation and standardize the development and utilization of Renewable
Energy, Energy Efficiency and Conservation in Nigeria,10 which would have essentially

7
Chapter 4 of this thesis offers more information on the legislations, both primary and subsidiary, enacted in
Ghana, for the regulation of energy efficiency in Ghana.
8
Nigeria’s Electric Power Sector Reform Act, 2005
9
supra
10
Energy Commission Act (Amendment) Bill, 2018. Retrieved June 6, 2019
http://www.nass.org.ng
 made the ECN the focal agency for energy efficiency in Nigeria, however, President
Muhammadu Buhari declined assent to the bill on the ground that the bill infringes on
the powers of the Rural Electrification Agency, with regards to the electrification of
unserved and underserved communities in Nigeria.11
b. Institutional frameworks
Energy efficiency in Ghana was successful, not only because laws were put in place, but
also because institutions were put in place, of which they all understood their roles in the
scheme of things.
The prominent institutions in Ghana’s drive towards achieving energy efficiency are the
Energy Commission, Energy Foundation and finally, the Ghana Standards Authority.
The Energy Foundation, a non-profit public-private partnership institution, was
established in 1997.12 The Foundation is devoted to the promotion of energy efficiency
and renewable energy in Ghana.13 The foundation was established under collaboration
between the Government of Ghana, energy sector stakeholders, and private sector
consumers; to promote sustainable development and energy efficient consumption of
energy in all forms in Ghana; to educate consumers through public campaigns,
educational programmes and seminars, about the rights and responsibilities of consumers,
the benefits of reducing energy waste, and assisting electricity consumers to improve
energy efficiency, and to strengthen the private sector, to improve economic productivity
by developing energy efficiency.14
The Foundation, in 1999, together with the LBNL, carried out a survey titled “Ghana
residential energy use and appliance ownership survey: Formal report on the potential
impact of appliance performance standards in Ghana. The survey thus became the
foundation for the development of the energy efficiency regulations and by extension,
minimum energy performance standards and labels in Ghana. 15 Following this, the
foundation also organized a National Forum on Electricity Efficiency, a forum which
identified the barriers that could hamper the adoption of electricity efficient technologies
and also proffered solutions.

11
Votes and Proceedings of the Nigerian Senate of Thursday, 17th January, 2019. Retrieved June 6, 2019
http://www.nass.org.ng
12
The Energy Foundation: Incorporation and Operational Structure. Retrieved on 31st March, 2019 from
https://www.efghana.org/incoporation/
13
ibid
14
Ibid
15
Ibid.
The Energy Commission was established by the Energy Commission Act of 1997, with
the mandate to advice the Minister on national policies for the efficient, economical, and
safe supply of electricity, natural gas and petroleum products, having due regard to the
national economy.
Building on this mandate, the EC advised the Minister in charge of Energy to make
regulations for energy efficient appliances in Ghana, and also played a prominent role in
the introduction of the incentives to encourage the adoption of energy efficient appliances
in Ghana, to wit: the CFL Exchange Programme, and the Refrigerator Rebate and
Exchange Programme.
The EC is also empowered to appoint inspectors, whose role is to ensure that inefficient
appliances are not sold in Ghana nor manufactured therein.
Finally, the MEPS that formed the basis for the regulations made for lighting bulbs and
refrigerators in Ghana were developed by the Ghana Standards Authority.
A perusal of these agencies would reveal one distinct factor, which is the fact that in the
drive towards achieving energy efficiency in Ghana, each agency had a distinct role to
play, and each played its role effectively, thereby preventing an overlapping of roles.
In Nigeria however, there has been a lack of direction and uniformity on the agencies
entrusted with promoting energy efficiency in Nigeria. What exists in Nigeria however
are different agencies, with each embarking on individual projects towards the
enhancement of energy efficiency.
For example, the Federal Ministry of Environment initiated the Rural Energy Access
Project (REAP) through its Renewable Energy Programme Unit to address the need to
source and deploy alternative and sustainable sources for lighting purposes, whereby
energy efficiency spells empowerment as it brings light to the rural poor who suffer most
from a dearth of electricity. This programme in itself infringes on the objectives, plans
and programmes of the Rural Electrification Agency, which is essentially charged with
the electrification of unserved and underserved communities in Nigeria.
The Energy Commission of Nigeria on the other hand has also involved itself with
programmes that encourage energy efficiency, while the Federal Ministry of Power is at
the moment empowered to bring to life the NEEAP, and so on.
The SON has also played a role, by developing standards and labels to guide consumers.
To this day, there is no lead agency for energy efficiency in Nigeria, and the ECN
(Amendment) Bill, 2018 would have cured the confusion and regulatory overlap.
c. Incentives
One of the most prominent factors in Ghana’s drive towards achieving energy efficiency
was the introduction of incentives into the mix, to allow for the accelerated adoption of
energy efficient appliances in Ghana.
To ensure a transformation in the lighting and refrigerating appliances markets in Ghana,
the Government of Ghana introduced three incentives: the removal of import duties and
Value added tax (VAT) on CFLs, the CFL exchange programme and the refrigerator
rebate and exchange programme
The CFL project which aimed to transform the lighting situation in Ghana, also aimed at
achieving the following:
a. a reduction in peak electricity demand;
b. stabilization of the electricity grid system;
c. elimination of transformer overloads; and
d. Reduction of diesel and other thermal generators to supplement hydro and other
cheaper power generation options.16
Furthermore, the intention was that the CFLs would provide a reasonable increase in
energy efficiency.17 To co-ordinate the CFL distribution, a National Implementation
Committee, chaired by the Minister of Energy was set up.18 The committee also had the
Executive Secretary pf the Energy Foundation and the Chief Executive Officer of the
Energy Commission as members of the NIC.19
Based on the model adopted by the committee for the actualization of the project, the
Energy Commission handled the transportation of the CFLs, while it also collaborated
with District Assemblies, the Military, Police and the Prisons Service in the distribution
of the CFLs to regions and districts. 20 The Energy Foundation on the other hand was
saddled with the task of educating the public on the intended exchange and the benefits
of using CFLs as against incandescent bulbs. This it did by holding town hall meetings
with stakeholders, erecting billboards, TV adverts and radio jingles, and depositing
educational materials in post boxes.21 In addition to these, the Energy Foundation also
embarked on training what they called the “replacement gang.” The replacement gang

16
Energy Commission 2009. Final Report – CFL Exchange Programme Impact Assessment.
17
Ibid.
18
S. Gyamfi et al
19
Ibid.
20
A.K. Ofosu-Ahenkorah, supra
21
Kofi Agyarko. “Energy Efficiency Drive: The Story of Ghana.” Energy Commission.
 consist of individuals who have received training and were engaged to remove the
incandescent bulbs and replace them with CFLs.22
The dedication put into it by the distributors and members of the replacement gang
ensured that the distribution and installation of all the 6 million lamps took place in just
three months.23
At the end of the project, several benefits had accrued to both government and
individuals who were beneficiaries of the CLFs.
Some of the benefits are24:
a. peak saving of 124 MW;
b. delay in thermal energy generation expansion investment of 105 million United
States Dollars;
c. at an average of crude oil price of US$120 per barrel recorded between October 2007
and October 2008, the energy cost saving was estimated at US$39.5 million per
annum;
d. reduction of 148, 000 barrels of light crude oil for thermal electricity generation;
e. CO2 savings of 105, 000 tons; and
f. Mean household income savings of about GHC31 in 25 districts across the country
in over 6 months.
In addition to these changes listed, one major noticeable impact of the exchange
programme was the fact that it gave rise to a rise in CFL penetration from 20% in 2007,
to 79% in 2009, and conversely, saw to a reduction in Incandescent bulbs penetration
from 58% in 2007 to 3% in 2009.25As a result of these positive changes, the project and
by implication, Ghana, received a Global Energy Efficiency Award in 2010.26
Buoyed by the positive impacts of the CFL programme, the government of Ghana,
wasted no time in keying into the refrigerator rebate and exchange programme, which
saw to the transformation of the refrigerating appliances market in Ghana.
The first document to recognise the need for Nigeria to adopt energy efficiency was the
National Energy Policy of 2003, followed by this was the NEP, 2013, a revised version of
the NEP 2003, which further built on the recognition of energy efficiency. In 2015, the

22
A.K Ofosu-Ahenkorah, supra
23
Kofi Agyarko, 2013. Towards Efficient Lightning Market, the Case of Ghana. Power point presentation made
at the ECOWAS Regional workshop initiatives on Standards and Labelling, Efficient Lightning and Energy
Efficiency in Buildings, Ouagadouguo, Burkina Faso, 22nd April, 2013.
24
Energy Commission (2009)
25
Energy Commission, 2009. Evaluation of Ghana CFLs Programme Report.
26
Ofosu-Ahenkorah, supra
NREEEP was also developed which also recognised the need for Nigeria to mainstream
energy efficiency, following which a NEEAP was drawn up.
It must be stated that the NEP 2013 and NREEEP, 2015 contain robust policies which
recognise the place of incentives as a tool for ensuring that the target consumers adopt the
energy efficient appliances.
The NEP, 2013 under its short-term strategies for energy efficiency provides that there
shall be the provision of economic, fiscal and financial incentives to promote energy
efficiency in all sectors of the economy in Nigeria, while there shall also be the
introduction of energy efficiency awards in all sectors of the economy, to encourage the
citizenry to adopt energy efficiency. In addition to this, the NREEEP, 2015 contains
specific strategies specially designed to accelerate gains in efficiency in Nigeria, some of
which are:
1. The Creation of an energy efficiency fund to be managed by the Federal Ministry of
Power or its appointed agent to provide rebates to on-grid customers who implement
substantive changes in their equipment to gain efficiency.,
2. The development of a framework for the distribution of the energy efficiency fund as
reimbursement for applicable technologies based on a list of qualified energy
efficiency expenditures,
3. Maintaining a list of qualified energy efficient equipment for which buyers will
receive a refund,
4. Researching and developing other financing mechanisms for energy efficiency,
including options of private sector financing,
5. Improving the overall macro-economic and financial framework that ensures the
availability and affordability of long-term funding for investors in energy efficiency,
and so on.
However, despite these policies, there does not exist a single consumer-based incentive
programme in Nigeria which encourages the adoption of energy efficient appliances in
Nigeria, and there are no direct incentives for companies to engage in the manufacture of
energy efficient appliances, although there exist incentives which companies interested in
manufacturing energy efficient appliances can take advantage of.
Be it noted that the UNEP programme which saw to the distribution of over 6 million
CFLs in Ghana was introduced to Nigeria, which would have seen to the distribution of
over 1 million CFLs in Nigeria. To make this happen however, the UNEP, ECN and the
 Government of Nigeria, being individual counterparts had obligations to contribute certain
quota to the project.
While the ECN and the UNEP were forthcoming with their individual contributions
however, the Government of Nigeria failed on its part.
According to the terminal evaluation report of the project, “The government pledged
$5,000,000 for the project. This was however not released to the Project, due to the
complex political dynamics that characterised the period of implementation with resultant
frequent changes in the leadership of the Ministry of Environment. Allocations were made
in the national budget for this commitment but appropriation proved difficult due to
challenges mentioned above. High level meetings were held with both the Federal
Ministries of Finance and Environment to unlock the funds which served as opportunity
for government to reaffirm its commitment to the project and willingness to do all within
its powers to ensure the release of the funds, but the funds were eventually not released.”27
Thus, the programme did not fulfil its expectations.

5.3 Conclusion
This chapter embarked on the comparative analysis of the frameworks put in place so far
by both Ghana and Nigeria towards achieving energy efficiency.
The chapter brought to fore the organised method by which Ghana went about
implementing its energy efficiency programmes and policies, while also shedding light on
the disorganization that exists in the Nigerian sphere, which has delayed Nigeria’s
adoption of energy efficiency.

27
United Nations Development Programme. Promoting Energy Efficiency in Residential and Public Sector in
Nigeria. Retrieved 29 May 2019 from https://info.undp.org/docs/pdc/Documents/NGA/00060200_PIMS
%204122%20ProDoc%20Nigeria%20EE%20Appliance%2024%2011%202010%20(3).doc pp 37.