PROPERTY: Red Flags For Multi-Tenanted Buildings
Recent Western Cape Business News
The SA Property Owners’ Association (SAPOA) has moved quickly to respond to the Power Conservation Programme (PCP) Rules published by the National Energy Regulator of SA (NERSA) in a consultation paper last month.
As the voice of the commercial and industrial property industry in SA, SAPOA has identified several areas of concern, chief among them that multi-tenanted buildings are not adequately considered in the PCP rules.
SAPOA’s first concern is one of definition.
“The rules don’t clearly define multi-tenanted buildings, or differentiate them from other commercial properties and therefore do not allow for penalties to be passed on to the actual consumers – the tenants,” says chairman of SAPOA’s Energy Efficiency Task Team Douw De Kock and Group Utility Manager at Broll.
De Kock adds that there is no clear definition of industrial property in the rules, something that SAPOA believes should be addressed.
A second concern for SAPOA is that property owners of multi-tenanted buildings are treated as unofficial licensees in the reselling of electricity to tenants – which means they don’t have the same rights and privileges with regard to penalties charged.
“In the case of shopping centres and office buildings, more than 80 percent of electricity consumption is controlled by tenants. The landlord has limited capacity to influence consumption if punitive tariffs can’t be passed on to the actual consumers,” explains De Kock.
“As a result, the aims of the PCP rules would not be met and some centres may have to close on the back of punitive charges.”
SAPOA proposes that property owners be given the same rights and responsibilities as licensees, and tenants be given the same rights and responsibilities as consumers.
A third sticking-point is the sector saving target for multi-tenanted buildings. SAPOA believes that the current proposal of 20 percent is simply not feasible and suggests a lower rate with an increased base platform.
“The same net effect would be generated by a more realistic 10 to 12 percent savings target for multi-tenanted buildings, if the applicable rate is reduced from, say, 25GW to 20GW,” De Kock elaborates.
Furthermore, SAPOA strongly recommends that all calculations should be based on actual readings, not estimates as outlined in the consultation paper.
“Indeed we believe any reference to estimates in the Rules should be clearly defined or omitted entirely,” adds De Kock.
In addition to its comments and proposals to NERSA regarding multi-tenanted buildings, SAPOA submitted additional input on issues ranging from excess energy charges, to timeframes, and the obligations of licensees.
“We are committed to the principles of energy conservation that underpin the PCP Rules and look forward to engaging with NERSA further in the interests of sustainable development,” concludes De Kock.
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