1. Green Building Council South Africa

Website: https://gbcsa.org.za/

Email: info@gbcsa.org.za

2. Institute of Energy Professional Africa

Website: https://iepa.org.za/

Email: info@iepa.org.za

3. Resolution Circle

Website: https://resolutioncircle.co.za/

Email: info@resolutioncircle.co.za

4. College of Cape Town (Pinelands)

Website: https://www.cct.edu.za/index.php/en/campuses/pinelands-main

Email: info@cct.edu.za

5. Ekurhuleni East Tvet College

Website: https://eec.edu.za/

Please Note: This list is limited to our knowledge of training providers, you are advised to check for others.

1. Why does South Africa mandate the display and submission of EPCs?

EPCs will promote energy consciousness with business operations, as well as an energy efficiency culture. .

EPCs can be an effective tool to monitor and track building energy performance and steer the industry toward better efficiency for improved economic growth and environmental impact mitigation, therefore leading to reduction in emissions and anthropogenic effects on climate change and global warming..

Improvement of verification process and quality assurance of the EPCs will enhance credibility of the information, allowing better government decision making and energy policy.

2. How to apply/implement an EPC?

To display and submit the EPC for your building, you need the services of a SANAS Accredited Inspection Body to do the assessment of your building and issue you with the certificate. See the following links that lists SANAS Accredited IBs and choose the one most suitable to work with:

https://www.sanedi.org.za/energy-performance-certificates/index.htm#SANAS-Accreditation

Please refer to the EPC guideline for a step-by-step approach of how to get an EPC:

https://www.sanedi.org.za/wp-content/uploads/2022/05/EPC-Guideline-_-FINAL-_-May2022.pdf

3. Are there penalties or fines for poor EPC rating?

There are no legislated penalties for a poor EPC rating. However, the rating on an EPC could play a role in attracting and retaining tenants and have an impact on the resale value of a property.

4. Can an EPC Inspection Body issue an EPC if there are no floor plans?

It is challenging to issue an EPC for buildings without any usable floor plans. A building’s rating is very dependent on building size (the net floor area (NFA)), as defined in SANS 1544:2014 and an EPC inspection body must go through significant effort to determine the NFA as accurately as possible. Without any floor plans, the likely options are to either suspend certification activities to afford the property owner the opportunity to find the “missing” floor plans OR to draft new floor plans for the building.

5. What are the penalties for EPC non-compliance?

Penalties for non-compliance with EPC regulation is a fine of up to R5 million and/or a prison sentence of up to 5 years. This penalty applies to both private commercial and state-owned buildings that meet the criteria for the mandatory display of an EPC. The regulations state that non-compliance will be in contravention of the National Energy Act which is detailed in Section 20 of the Act.

6. Why was the EPCs announced so suddenly?

This is a misconception. The inception of the development of the EPC commenced mid-2010 with the issuing of SANS 204:2011 “Energy Efficiency in Buildings” and SANS 10400 XA:2021 “Energy Usage in Buildings”. This was followed by the issuing of SANS 1544:2014 “Energy Performance Certificate” Standard in 2015.

Then the draft regulations for the mandatory display and submission of energy performance certificates for buildings (the EPC regulations) was published for public comments in July 2018 and therefor, the regulation came into effect from December 2020 and was published under the Gazette Notice 700 of 2020.

It would therefore be incumbent on accounting officers/building owners to obtain certifications as soon as possible, such that they are compliant before the deadline of 07 December 2022.

7. How long does it take to obtain an EPC?

It is dependent on available data. The biggest challenge (and the most time-consuming step) of the certification process is usually associated with the preparation of the information needed by the SANAS Accredited EPC Inspection Body.

This data includes consumption data (for all the energy carriers used by the building), floor plans and occupancy data. For property owners with large portfolios the information gathering challenges can be exacerbated by the complexity of the data required.

Once a property owner can hand a "building information pack" to the SANAS Accredited EPC Inspection Body, the process of issuing an EPC should not take more than 10 working days. With sufficient resources, an SANAS Accredited EPC Inspection Body should be able to issue several EPCs per week, provided that the information packs for these buildings have been prepared by the property owner.

8. What is the process to apply for an EPC?

With reference to the EPC guideline. The following steps are a guideline for the display and submission of an EPC by the Accounting Officers.

• a. Identify which buildings, or portions of buildings, need EPCs. A SANAS accredited EPC inspection body can assist with this step (see the next point).
• b. Identify SANAS accredited EPC inspection bodies who can deliver the certifications. There is a small window of opportunity (lasting another 2-3 months) to secure the services of an SANAS accredited EPC inspection body, before the demand for energy performance certification services far exceeds the available EPC inspection bodies’ capacity in the market.
• c. Understand the costs of EPCs and make budgetary provision to have the certifications done.
• d. Gather the information needed by an SANAS Accredited EPC Inspection Body. This must start as soon as possible as EPC “information risk” (i.e., the risk that information needed for certification is not available) is the biggest risk to achieve certification. The information that must be made available to the EPC inspection body includes:
                                 As-built floor plans
                                 Internal layout plans
                                 Grid consumption “data” files (e.g., bulk check meter load profiles and/or municipal accounts)
                                 Invoices for diesel purchased
                                 Invoices for gas purchased
                                 Solar PV production and consumption data (load profiles)
                                 Invoices for coal purchased (hopefully not too many of these)
                                 Information relating to energy exported from buildings
                                 Occupancy data
Note: The energy performance assessment period shall be one year in respect of the data for the preceding year.
• e. Building operating hours, especially where a building or a part of a building is operated outside of the SANS 10400 “norm”. An example would be a call center in an office building that operates 24/7, compared to the typical operating hours of an office building as listed in SANS 10400-2021. The typical operating hours of an office is 12/ 5.
• f. Brief internal staff (asset managers, building managers, other stakeholders) on the importance of EPCs and what their contribution can and must be to ensure compliance.
• g. Arrange EPC roll-out planning sessions (with the SANAS accredited EPC inspection body) to schedule and plan the delivery of EPCs according to numerous factors like building location, information availability, building complexity (this varies on a case-by-case basis).

9. What can I do to improve my building’s EPC rating?

Develop and implement an energy efficiency strategy for the building. This can include the following:

• Replace incandescent light bulbs with LED lighting
• Replace geysers with heat pumps (if hot water is used)
• Optimize the setpoints of the air-conditioning system
• Encourage the use of stairs to mitigate the use of the elevators
• Insulate the building thoroughly

10. Can I use Gross Lettable Area (GLA) to determine my EPC?

No, you cannot use GLA to determine your EPC. According to SANS 1544: 2014, you are required to use the Net floor Area (NFA) which is defined as the sum of all areas between the vertical building components (walls or partitions), excluding garages, car parks and storerooms.

11. What is the value of an EPC to my business?

EPCs are an internationally recognised tool to assess the energy efficiency of buildings. An understanding of the baseline energy (kWh/m2) of buildings is the starting point to achieving required improvements to buildings energy efficiency and this is what South Africa’s EPC mechanism will set out to achieve.

EPC mechanisms drive change by driving measurement and profiling of buildings, which can then prompt improvements. Building owners implement energy efficiency measures at scale as a result of fiscal incentives being available to do so, and to increase the scale/increase value of buildings (better EPC rating = lower operating cost). An EPC database can be used for identifying energy efficiency interventions across the building stock, and for carbon/climate reporting and target setting.

12. Can an EPC be used for sustainability reporting?

Not directly, however, an EPC can be used as part of the indicators required for sustainability reporting as an EPC shows the energy performance of a building against an appropriate benchmark.

13. If there is change of building ownership before the deadline, who is liable to get the building certified?

The person who will be the owner of the building by the EPC deadline of 7 December 2022 will be held responsible for the display of the EPC.

14. How many buildings need EPCs in South Africa?

It is estimated that the total EPC market is between 250 000 and 350 000 buildings for the occupancy classes currently included in the regulations.

15. Can I be fined for not certifying my buildings?

The penalty only applies to the buildings that meet the criteria for mandatory energy performance certification. Buildings that do not meet the criteria may consider voluntary certification and will not be penalised.

16. Do government buildings need to be certified?

The regulation for the mandatory display of an energy performance certificate stipulates buildings owned by an organ of state that belong to the specified occupancy classes and which exceeds 1000 m2 need an EPC.

17. When must the reference energy values in the new SANS 10400XA:2021 be used to determine a building’s EPC rating?

An EPC building rating must reference the new SANS10400XA:2021 document which came into effect in November 2021

18. Who do I directly contact for more information on EPC?

Please send an email to epcenquiries@sanedi.org.za and a SANEDI representative will assist you.

19.How do I register my buildings on the NBEPR??

Registration of buildings is currently not taking place yet, as the amendment is still under review. The public will be notified once the registration of buildings is promulgated.

20. Does a Non-Profit company that owns buildings need to comply?

Yes, If the building is privately owned or owned by the organ of state with the required sizes, has a dominant occupancy classification in terms of Regulation A20 of National Building Regulations, has been in operation for 2 years or more and has not been subject to a major renovation within the past two years of operation. .

22. How should a building owner/accounting officer go about submitting a certified copy of the ‘original’ EPC, if the original is a printed version of a PDF?

According to the EPC Guideline, the SANAS accredited Inspection body is to print out a colour copy of the EPC and give to the building owner/accounting officer. The building owner/accounting officer should submit a certified copy of the EPC to SANEDI within three months of issue. Building Owner or Accounting Officer should submit certified EPCs by a Commissioner of Oaths as per the Regulation requirement to EPCsubmission@SANEDI.ORG.ZA or deliver the hard copy to SANEDI Offices, Block C, Upper Grayston Office Park 152 Ann Crescent Strathavon, Sandton 2031.

23. Who ultimately issues the EPC Certificate?

The SANAS-accredited EPC IB must issue the EPC Certificate to the paying client, after uploading/submitting the relevant data to the EPC Building Register hosted by SANEDI. A certified copy of the EPC Certificate must be sent to SANEDI by the client’s Accounting Officer in the case of an organ of state, and the building owner in the case of a private building not occupied or operated by an organ of state within three months of issue.

24. Where and how to access the services of EPC Inspection Bodies?

The SANEDI websites on the following link provides a list of the accredited EPC inspection bodies. Be sure to ask any prospective EPC service provider for their proof of SANAS accreditation before appointing your EPC Inspection Body.

https://www.sanedi.org.za/energy-performance-certificates/index.htm#SANAS-Accreditation

25. Will SANEDI issue a standard template for certificate or certificate data they need for their database?

SANS 1544:2014 describes what a typical EPC needs to look like. See example below.

26. What happens when a building does not have an Occupancy Certificate and is privately owned, but occupied by an organ of state?

a) In the private sector, it is compulsory/mandatory to have an occupancy certificate before you are allowed to occupy the building. You can get a special dispensation from the Building Control Officer (BCO) to move in without one, but it has a validity clause. It is illegal not to have an Occupancy Certificate for an occupied building.

b) Any building in the private sector is legally obliged to have an occupancy certificate.

27. For a private building owned, occupied or operated by the government does one display the building owner name as well as the accounting officer on the certificate?

EPC Certificate displays the owner of the building for private owned buildings.

28. What buildings are excluded from the Occupancy Certificate requirement?

Public Buildings owned by the state (Government buildings)

29. What is considered an occupancy certificate?

Occupancy certificates are issued by the agencies and authorities of local government, which declares that the building is constructed as per the plans that were approved by the concerned authorities. Occupancy certificate is issued when a property is ready to be occupied.

30. Can you obtain an EPC without an occupancy certificate?

Yes, you can obtain an EPC without an occupancy certificate.

31. Why are there different types of building categories under “Services Rendered” on the IB accreditation certificate?

The types of buildings listed under “Services Rendered” are meant to denote the complexity of buildings that can be included in the services that the IB may offer.

32. What documentation states that if an office makes up more than 10% of the net floor area of a car dealership, then an EPC is required?

Any occupancy that comprises less than 10% of the net floor area shall be included in the predominant occupancy provided does not contribute more than 10% of the energy performance of the predominant occupancy. Refer to SANS 1544:2014.

Car dealership is not affected by 2022 EPC Regulation therefore, EPC is not required.

33. A school with multiple sizes of buildings as part of one school, if one building is over the squared meter requirement, must all the smaller buildings also get EPCs?

Only the buildings that are over the required nett floor squared meters require an EPC, the other smaller buildings do not. According to the EPC Regulation for private schools the square meters should be over 2000m2 and for government owned schools they must be over 1000m2.

34. Which buildings require EPCs to be displayed?

With respect to the provisions of the EPC Regulation and associated building classifications according to the National Building Regulations (SANS10400: XA:2021), only the following classes of buildings are currently required to display an EPC by December 2022:

35. In the case of a shopping mall, does it fall under an F1 classification i.e., large shop or is it something that would be made up of different classifications such as e.g. A1, A2, G1?

Large and small shops and wholesaler stores are not required by the regulation to display the certificate as they are classified under class F of the National Building Regulations.

36. Does a shopping centre need to display and submit an EPC?

Shopping centers are not affected by the EPC regulation.

37. In a shopping mall that has multiple categories of tenants, where tenant may fall into the EPC Regulation’s mandatory building categories, is an EPC required for the mall, or for each type of occupancy? Or should it be seen as a facility were e.g. over 90% of the occupancy is classified as F1, which does not require a certificate. Therefore, the mall itself would not require one either.

Shopping mall is a single building that has multiple of tenants and with different occupancy classes.

Shopping mall must have one EPC.

Occupancy class F1 is not affected by 2022 EPC Regulation therefore, EPC is not required.

38. We have been requested to quote on a campus with a few blocks in a specific area, and the consultant is stating they need one EPC for the campus, rather than an EPC for each building within the campus. Is this allowed?

Each building above the required nett floor squared meters requires a separate EPC on a campus or in an office park, whether it is one erf, or various erven linked.

39. In the Department of Public Works space – the departments commonly have a single premises with various buildings of different sizes, some more and some less than 1,000m2. In this case where the department is the landlord of the entire premises, are the buildings individually certified or is the premises certified?

Each building on the premises with a net floor area exceeding 1,000m2 requires It’s own EPC.

40. Is each building/Erf number treated separately e.g., when a business is across several Erven?

Erf is a number used to describe the property therefore, buildings that are located across several erf number must be treated separately as they share different stand number

41. Please clarify the classification for non-government buildings G1 (offices). Are this purely administrative functions? Does this exclude factories? E.g., head office admin in a separate building >2,000m2 does the head office then require an EPC?

Building class For offices is G1, Factories are D1, D2, D3 under A20 of the National Building Regulation. The Head office in a separate building with a net floor area of large than 2000m^2 EPC is Required. Factories are not affected by 2022 EPC Regulation.

42. We own a few buildings that we rent out to churches. How do we know if we are required to apply for EPC?

Confirm what the occupancy class is as stated on occupancy certificate and if they are used for their intended use. If the buildings fall under the required sizes, used as intended, has been in operation for 2 years or more and has a dominant occupancy classification in terms of Regulation A20 of National Building Regulations then an EPC is required for those buildings.

43.Does a private building over 2000m2 with different floors, and parking area require an EPC?

The net floor area is calculated from the ground floor to the top floor of the building and car parks are considered as exclusions. Therefore, private building with a net floor area of 2000m2 and falls under the required occupancy classes requires an EPC. Net floor area is described as a sum of all areas between the vertical building components (walls or partitions), excluding garages, car parks and storerooms.

44.Does EPCs apply to office spaces greater than 2000m2, including offices on a manufacturing/factory site?

EPCs applies to buildings with the net floor area of 2000m2 or more. If the offices are separate buildings from the factory and meet the required net floor area, then an EPC is required for that office building.

45.Should canteens and kitchens be included if they are in an admin building?

Yes, they are included as they form part of the net floor area.

46. Is an outdoor veranda considered an exclusion, or part of the indoor area?

It is an exluded area as it is not part of the net floor area made up by the vertical building components as per clause 3.11 of SANS1544:2014.

47. Stairwells in basements are they classified as an exclusion or included?

As it forms part of the basement, it is an excluded area. A continuous staircase from within the building envelope running down to the basement referencing to SANS 1544:2014

48. A building has implemented a completely new office upgrade fit-out, is this considered a major renovation?

A major renovation in the EPC Regulation for buildings includes the words “requiring planning approval” and in terms of SANS1544:2014 major renovations are those that have an impact on the operational energy use of the building. A renovation of the aesthetics would therefore not be seen as a major renovation.

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49. When is a major renovation classified as not requiring a new EPC, or not requiring an EPC to begin with?

Every time a building plan must be submitted for approval of a renovation, as per the National Building Regulations, the EPC is not required for two years. If you have an EPC already, and a renovation project is undertaken you need a new EPC after 2 years, if your 5-year renewal isn’t due yet.

50. Our client has an office building and regularly tenant changes occur where a new Occupation Certificate is requested, therefore they see these changes as a major renovation in terms of the law and are therefore do not require an EPC as they are continuously changing. Is this correct?

The terms of “occupancy” or “occupancy class” (as defined in SANS1544 3.12) with “occupation” (as in “occupation certificate”) must not be confused. A change in occupancy means changing the use/function type of the building e.g., converting offices into apartments. A change in tenancy occupation is not the same. An EPC is required.

51. Does the “two-year” clause in the Regulation relating to a “change in occupancy or operations in the 2-year period immediately prior to issuing the EPC Certificate” mean that an EPC won’t be required until occupancy stabilises to normal?

Yes, EPC won’t be required until occupancy stabilises to normal. EPC is required for the building that has been in operation for two years or longer and that has not been subjected to a major renovation or change of occupancy within the past two years of operation.

52. Can EPCs be revised during the 5-year validity period if a building owner retrofits, and the 2-year waiting period is abided by?

Yes, if the retrofit meets the definition of a major renovation.

53. Does a building that went through a major renovation and started operation after 7th December 2020 be exempted from getting an EPC until they reach 2 years in operation after which I presume the Regulation applies?

No, it will not be exempted. If your building has been operating or occupied for 2 years or more from the time of the major renovations, then you will require an EPC despite the date the Regulation came into effect..

54. SANS 1544:2014 or the EPC Regulation both do not provide for penalties. What penalties are going to be imposed?

Non-conformance with the EPC Regulation is a contravention of the National Energy Act whereas section 20.(1) applies which refers to Offences and Penalties who contravenes or fails to comply with any provisions of the National Energy Act. In terms thereof, the liability on conviction refers to the following penalties: 20.(1) (a) a fine not exceeding five million rand; 20.(1) (b) imprisonment for a period not exceeding five years; or 20.(1) (c) both such fine and such imprisonment.

In addition 20.(2) allows for amendments to the amounts referred to in 20.(1) in order to counter the effect of inflation.

55. How much does it cost to do an EPC assessment? How would or could the fees be structured for the assessment and issuing of the EPC?

Considering the varying complexities of buildings occupancy classes, building size, data collection methods and approach, and other contributing factors, each building and project cost will be unique. Quotations would need to be obtained from SANAS-accredited EPC IBs. EPC Regulation has not specified the rates that an IB would charge for the services of conducting a building audit/assessment and the issuing of an EPC. This is due to various factors affecting the cost such as, amongst others:

• a) the location of the facility to be assessed (travelling, accommodation, etc., if required),
• b) the size of the building, or the building portfolio,
• c) the complexity of the building,
• d) the availability of data/smart meters, and building information (or the need to install meters to gather the data, building plans, etc.),
• e) in-house expertise available to assist with collecting data and information, or getting the building IB ready,
• f) the level of resource you use for the assessment (Engineer, Technician, Energy Auditor).

56. Why does an EPC come at a cost?

To understand the cost of an EPC it is important to keep in mind that an EPC can only be issued by SANAS accredited EPC inspection bodies. This ensures that energy performance certifications are done according to the relevant standards and that the individuals performing the certification work have appropriate qualifications, training, and experience. Furthermore, for an inspection body to issue an EPC, comprehensive data collection, validation and analysis are required - all done by competent inspection body staff.

Costs can be mitigated if the property owner collects all required data and makes this easily accessible to the inspection body.

57. Is the EPC fee set by SANEDI or are EPC SANAS accredited IBs required to charge what they want?

The EPC Regulation has not specified the rates that an IB would charge for the services of conducting an energy performance audit/assessment and the issuing of an EPC.

Considering the varying complexities of buildings occupancy classes, building size, data collection methods and approach, and other contributing factors, each building and project cost will be unique.

58. How do you go about achieving SANAS-accreditation, to participate in the implementation of EPCs?

The SANAS electronic information packs are customised and sent to each applicant/interested party, depending on the questions asked. The packs contain copies of the relevant SANAS documents and the SANAS documents are revised and amended regularly.

All interested parties can initiate the accreditation process, the interested party must contact either one of the following SANAS representative, who will issue the interested party with the application package and assign them an accreditation number:

59. I see IBs need to be SANS 17020 accredited. Does this mean SANS17020 IBs will be able to extend their scope to include EPC?

Yes, current IBs accredited by SANAS, e.g. SANAS-accredited M&V IBs, can extend to offer EPC as well. The IB will need to demonstrate competency in EPC.

60. Are you allowed to assess your own facilities, or does it have to be an independent IB?

Building owners, accounting officers, energy managers, facilities managers, etc, may collect information for the EPC, however technical signatories of the EPC IB accredited by SANAS need to validate the data collected.

61. Can I only use a SANAS accredited inspection body to issue the EPCs?

Only a SANAS-accredited EPC inspection body can issue a building energy performance certificate. A building owner can use internal staff or contract the services of other consultants to assist with the gathering of information required by the inspection body, but the actual certification must be done by an accredited EPC inspection body.

62. Where can I get an accredited body to perform the Energy Performance Assessment and issue an EPC?

The SANAS and SANEDI websites has lists of the accredited SANAS EPC IBs.

63. From which date are the Regulations applicable?

Even though the gazetted Regulations indicate that the Minister of Mineral Resources and Energy (DMRE) signed the document in January 2020, the Regulations formally came into effect on the date of promulgation, which is 8 December 2020, and the ‘Sunset Clause’ is midnight on 7 December 2022. All applicable public and private sector buildings need to display an EPC, on-or-before this date.

64. Is the DMRE considering the extension of the EPC deadline?

If any regulation amendments to the deadline occurs, the DMRE will communicate through relevant channels in due course.

65. Is it allowed to calculate energy consumption using appliances wattages and operation hours for buildings without sub-meters and electricity bills.

No, is not allowed. It is mandatory for the assessor to use utility bills to calculate the energy consumption of a building, as stipulated in the standard (SANS 1544:2014 page 6) that when doing an EPC assessment, you need 12 months utility data.
When calculating the energy excluded the assessor must use the methodology mentioned in SANS 1544:2014-page 13 Section B which shows the methodology to use when calculating excluded energy.

66. Who is responsible for the display of EPC?

According to the EPC Regulation, for private owned, operated, or occupied buildings the building owner is responsible. For organ of state (government/public) owned, operated, or occupied buildings the accounting officer is..

67. Is the accountant of the government department the accounting officer?

The accounting officer of an organ of state will preside over the government department. To understand this, we show the definition of “Organ of State”:

[1] In the Constitution, unless the context indicates otherwise, "organs of state" means –

(a) any department of state or administration in the national, provincial, or local sphere of government; and

(b)any other functionary or institution - (i) exercising a power or performing a function in terms of the Constitution or a provincial constitution; or (ii) exercising a public power or performing a public function in terms of legislation.

[2] Despite subsection [1] above, "organ of state" does not include judicial officers or courts.

Section 82, shows for a municipality – the municipal manager appointed in terms of section 82 of the Local Government Municipal Structures Act no 117 of 1998, the municipal council must appoint:

(a) a municipal manager who is the head of administration and the accounting officer for the municipality: and

(b) when necessary, an acting municipal manager.

68. Where can we find the schedules mentioned in the EPC Regulation for accounting officers?

The schedules can be found in the Public Service Act, Proclamation No 103 of 1994, Schedules 1,2 and 3.

69. Is the Accounting Officer still responsible for the EPC if the organ of state is only a tenant?

Yes, the accounting officer remains responsible as the regulation section 3. (1) refers to the organ of state occupying or operating, in addition to owning, being responsible for the display of the EPC. The word tenant is defined as “a person or entity that occupies land or property rented from a landlord”.

70. When an organ of state rents a private building, does the 2,000m2 requirement apply for organ of state, or does the 1,000m2 requirement apply due to it being a public building?

Section 3. (1) of the Regulation refers to provisions of an organ of state owning, operating, or occupying a building that has a total net floor area of over 1,000m2 as per 3. (1)(c).

71. Does Accounting Officer include suspended Municipal managers?

A legal and valid appointee would need to be made that fulfills the role of an accounting officer in such a case.

72. Where would public universities fall under - "Accounting Officer"?

The EPC Regulation refers to accounting officers as per the Public Service Act Schedules, about public universities they fall under Schedule 1, under Department of Education in column 1, and column 2 refers to the Director General: Education.

73. If you are the Tenant is it the Landlord's responsibility or the business owner?

It is the responsibility of the owner of the building in the event of a private building, and the accounting officer if it is a publicly owned, operated, or occupied building.

74. What are the key differences between EPCs and the Green Star Rating of the Green Building Council of South Africa?

The EPC is a legislated requirement in terms of the Energy Act. Green Star Rating is a voluntary program.

75. What do I do if I have a building or facility not included in the current Regulations, but I am keen on obtaining and displaying a Certificate for my building, e.g. a hotel or shopping mall, or I have done an EPC assessment before the promulgation of the Regulations on 8 December 2022?

The EPC Certificate would need to be titled: ‘Voluntary’ Energy Performance Certificate for the specific facility/ies. The ‘Mandatory’ component only came into effect on 8 December 2022, so anything done before the formal promulgation of the Regulations, would constitute a ‘Voluntary’ EPC.

Note: The Standard 1544:2014, SANAS-requirements, etc., were all in place before this date, but the promulgation of the Regulations formally ‘operationalised’ the legislation, making it ‘Mandatory’ for the specified classes of buildings, within 2 years.

76. Who is responsible for data integrity?

The SANAS-accredited EPC IB and it’s inspectors/technical signatories.

77. Can you use utility bills if you don't have the meter calibration certificates?

Yes, the kWh and KVA from utility bills are used for the calculation. Ensure that the utility bill does not have estimates.

78. Are we just trusting the caloric values from suppliers or is some other form of verification required?

There are 3 sources of data to consider for the calorific value: The standard, supplier data and the actual calorific value of the fuel in question. It may be best to use the actual calorific value of the fuel, but that requires laboratory testing so the supplier data may be the best compromise for verification.

79. Is on-site generated energy excluded from the EPC calculations or not?

When looking at Net energy we look at consumed and energy exported. Energy generated on site for self-consumption is still used for energy consumption.

80. Is PV generated electricity included or excluded from the total electricity consumption of the building?

When looking at Net energy we look at consumed and energy exported. Energy generated on site for self-consumption is still used for energy consumption.

81. Does the solar PV installation improve the EPC rating?

The installation of a solar PV plant as the only building improvement will not change the EPC rating of a building. Only energy efficiency improvements that reduce the kWh/m2/annum of the building will improve a building's rating.

82. Does the use of diesel fuel affect the building’s EPC rating?

YES. Using diesel fuel will adversely affect the energy performance of a building.

SANS 1544:2014 requires the inclusion of the energy value in kWh of any liquid fuel (for example diesel) used during the year of assessment to determine the building Net Energy Consumption. Most buildings use diesel fuel in backup generators to provide electricity to a building when there is an interruption in the grid supplied electricity (e.g., during loadshedding). Energy is lost in the form of heat and noise during the conversion of diesel energy to electrical energy in the generator.

Therefore, the use of energy from a diesel-generator results in an energy footprint larger than that from using grid electrical energy.

83. How do you approach an EPC when a facility is a net exporter of electrical energy to the grid? (Grid tie PV generation with net export).

By looking at the Net Energy of consumption of the building and following the EPC process. The building should have a great energy performance rating.

84. Is unburned fuel emitted from your genset considered in the calculations?

Unburned fuel is unused fuel therefore, any used and unused fuel in the company’s possession must be accounted for. Unburned fuel must be considered in the calculations

85. Are electrical schematics a necessity for an EPC? For many older buildings these drawings aren't always available

No, it is not required.

86. Electrical standards and regulations and building regulations don’t require buildings to have separate metering and utility bills per building on one erf, can data estimates be made for each building taking the total utility bill divided by m2 and allocated to each building?

No, metering of multiple tenants is necessary when the tenants perform different activities and fall under different classifications according to SANS 10400-XA:2021. Metering and sub-meters need to be installed by the owner to be able to demonstrate the energy usage of each tenant.

87. The regulation expressly states that the EPC must be based on data from the preceding year of the assessment, however we have also seen communication that 2019 data is allowed due to COVID-19 – is 2019 therefore allowed?

The Regulation states the year preceding which remains the correct year of data required. EPCs assessed in 2022 will be required to use 2021 data.

88. For COVID-19 occupancy at a school, will one month’s utility bills be accepted when schools were operational just before lockdown?

Using only one month’s utility bills will not provide accurate data as the energy performance of a building fluctuates not only due to occupancy fluctuations, but seasonal fluctuations need to be considered as well such as summer and winter use patterns, as well as school holiday periods.

89. How do we normalise occupied and unoccupied areas that were experienced during COVID-19 lockdown?

SANS1544 section 4.3 provides the calculation with an example for normalisation. For example:

To determine the occupied floor area, the unoccupied floor area must be deducted off the net floor area.

To determine the effective energy consumption, the measured net energy consumption must be divided by the occupied net floor area.

The unoccupied floor area must then be prorated to the measurement period, with the example in section 4.3.2. Percentages of unoccupied floor area, and number of unoccupied floor area spaces, may differ from the example but the calculation achieves the result of usable floor area during the year.

90. Are there any technical courses (local/international) that you could recommend getting a better understanding, and potentially train staff on?

Energy Performance Certificate Training Institutions

Name of Institute	Telephone Number	Email Address
Institute of Energy Professionals Africa	(084) 622 4770	info@iepa.org.za
Green Building Council South Africa	CPT: (021) 486 7900 JHB: (010) 001 3550	info@gbcsa.org.za
Resolution Circle	(010) 020 3300	info@resolutioncircle.co.za

Disclaimer:
SANEDI populated this information for guidance purposes, we do not know the quality of their training and we only know of these training institutions, there might be other institution.

91. What is accepted as an accurate reflection of the floor space if a building plan conflicts with the actual measurement?

Measured data is the verified version of the building plan.

92. What if there is no building plan?

An architect can be called to formalise a plan or have the (IBs) self-measure the building and get the client to sign and verify their plan.

93. Some plans include temporary walls, some exclude temporary walls, some include half-mast erected temporary walls, are these temporary walls excluded?

Temporary walls and half -mast erected temporary walls are included as they form part of the building.

94. How to apply the design population from SANS 10400XA:2021 to the EPC calculation?

Where population is not known, the population shall be calculated in accordance with table 2- design population of National Building Regulation A21.

95. How does a building with multi occupancy receive an EPC?

Multiple occupancy is when multiple tenants occupy a building, with no one tenant accounting for less than or equal to 90% Of Net floor area. Building energy performance of multiple tenants should be prorated, combined, and compared with a prorated reference value. Each tenant contributes a kWh/m^2/a rating per percentage of area that it occupies of the full building therefore, One EPC will be issued for that building.

96. For a private building greater than 2000 m^2 that has a Predominant occupancy that is NOT one of the following occupancy types (A1, A2, A3 & G1) but does have areas in the building that are occupancy types A1, A2, A3 & G1, is an EPC required?

According to the Regulation the building does not require an EPC.

97. Under what circumstances would an EPC be required for the above building (Building with Predominant occupancy)?

When a building has a dominant occupancy classification which is (A1, A2, A3 and G1), operated for 2 years or more, has a total net floor area of over 2000sqm for private buildings and 1000sqm for public buildings and has not undergone any major renovations according to the Regulation.

98. Should unoccupied offices be included. ?

Unoccupied offices are included and are referred to as vacant spaces according to SANS 1544:2014.

99. From SANS 10400XA:2021, in Cape Town and Durban, high rise buildings use less energy than standalone blocks, but in Johannesburg the reverse?

Thermal resistance for walls at Johannesburg is higher from that of Cape Town and Durban. It is caused by different in Energy zone and temperature. Refer to SANS 10400-XA:2021.

100. Why does the trend between Stand-alone blocks and Multistorey offices differ for Johannesburg and Pretoria? The demand in Johannesburg for high rise building is more than for the stand-alone blocks, but then for Pretoria, the high-rise demand is much less than the stand-alone blocks?

It is caused by difference in thermal resistance for walls between the two places. Energy zone for Johannesburg is one (cold interior) and for Pretoria is 5 (sub-tropical coastal). Refer to SANS 10400-XA:2021 on Energy Zone Map for South Africa.

101.If the building is leased, who will be liable for obtaining the certificate? Should the building owner fail to attain one, who can be fined/ held liable for not attaining the certificate?

• • For a privately owned building the building owner will be liable.
• • For a public owned building the accounting officer will be liable.
• • For a privately owned building that is occupied and operated by an organ of state then the accounting officer will be liable.

102. Is it the responsibility of a Lessee or a Developmental and self-repairing Lease (that is, where you lease the land from the owner and build upon it. The Lessee is therein obliged to attend to aspects of compliance and repairs with respect to the building) obtain an EPC? In terms of the regulations, who would the obliged to obtain an EPC, in terms of a Developmental Lease?

If the title deed of the building is in the name of the land owner, it is the responsibility of the building owner to comply with the EPC regulations. If you are paying the lease for the land and you own the deeds of the building, it is your responsibility to comply with EPC Regulations.

103. If a building is managed by a building corporate body with a sqm above 2000, but has shared sectional deed titles (Less than 2000sqm) does the EPC apply to the building as one or each section will have to be certified separately?

EPC applies to the building as one .