Understanding who needs an EPC

By Frikkie Malan, head of sustainability at Remote Metering Solutions

The regulations for the mandatory display of building Energy Performance Certificates (EPCs) in South Africa is expected to promote energy efficiency awareness and the improvement of building energy performance. EPCs will help property owners to identify which buildings represent the greatest potential for energy efficiency improvements.

An EPC is a certificate that shows the energy performance of a building as a rating from A to G, with A being the most efficient and G the least efficient rating. In terms of the regulations, an EPC must be displayed in the building, visible to the public. EPCs can be an effective tool to monitor and track building energy performance.

Which property types must have an EPC by December 2022?

Not all buildings are required to get an EPC. The following building occupancy classes must display an EPC by the December 2022 deadline.

Occupancy Class A1 – Entertainment and public assembly: Occupancy where people gather to eat, drink, dance, or participate in other recreation. Typical examples include restaurants, night-clubs, sports pubs, gyms, and so on.

Occupancy Class A2 – Theatrical and indoor sport: This is an occupancy where people gather for the viewing of theatrical, operatic, orchestral, choral, cinematographical, or sport performances. Some examples include movie theatres and live theatres.

Occupancy Class A3 – Places of instruction: As the name suggests, these are where school children assemble for the purpose of tuition or learning. It also includes occupancy other than primary or secondary schools where students or other persons assemble for the purpose of tuition or learning. This would therefore include schools, colleges, universities, and Technikons.

Occupancy Class G1 – Offices: Large multi-storey office buildings, banks, consulting rooms, and similar buildings that feature lifts and energy consuming services that operate on a typical daytime occupancy. This includes stand-alone blocks or a campus of buildings that form an office park but operate separately.

In addition to occupancy class, another qualifying criterion is building size. Privately owned buildings (that belong to the occupancy classes listed above) greater than 2000m2 must obtain an EPC. Building owned, operated, or occupied by an organ of state has a minimum size threshold of 1000m2. It is important to note that even if a building is privately owned, if it is OCCUPIED by an “organ of state” the size threshold becomes 1000m2/.

Understanding the exceptions

Of course, there are exceptions to consider.

For example, when it comes to office space (occupancy class G1). This type of occupancy class can be part of a mixed occupancy building – for instance, an industrial property with an office component. In these cases, the building must be evaluated against the following criteria:

• Is the occupancy class of the building that needs an EPC greater than the minimum size threshold (e.g., 2000m2 for privately owned buildings)?
• Is this occupancy class distinct, in other words can a clear boundary be drawn around it?
• Does this occupancy class consume more than 10% of the total building’s energy consumption?

If the answer to all three questions is yes, then this portion of the building would most likely need to be certified.

Let’s unpack this a bit. Say a property owner owns a shopping mall. This is not one of the occupancy classes that need an EPC. But, within the mall there are restaurants and a food court. Does the building owner need to get an EPC for the shopping centre (remember, restaurants and the food court would belong to occupancy class A1)?

• Question 1 – is the area of the restaurants and food court more than 2000m2? Let’s assume it is. So, one of the criteria has been met.
• Question 2 – is the energy consumption of this occupancy class more than 10% of the total building. Let’s assume that all the restaurants and the food court are being metered and it can be determined that the energy consumption is more than 10% of the total building consumption. So, the second of the three criteria have been met.
• Question 3 – is this occupancy class distinct? The answer must be no. The restaurants are distributed throughout the shopping centre and the food court is on its own. So, the third of the three criteria have not been met.

The answer then is that the building (the whole shopping centre) does not need and EPC nor does the portion(s) of the building that is class A1 need a certificate.

Penalties for a poor EPC rating

If a property owner fails to obtain and display an EPC (and submit the EPC to SANEDI) before the December 2022 deadline, he or she would be in contravention of the National Energy Act. Contraventions of the Act can be penalised with:

• Up to 5 years in jail.
• A fine of up to R5 million.
• Or both!

The regulations for the display and submission (to SANEDI) of building energy performance certificates make it a legal requirement that property owners must comply with.