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SAPOA responds to NERSA proposals
Date published 1 March 2009
SAPOA has moved quickly to respond to the Power Conservation Programme (PCP) Rules published by the National Energy Regulator of South Africa (NERSA) in a consultation paper last month.
As the voice of the industrial and commercial property industry in SA, SAPOA has identified several areas of concern, chief among them that mulit-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 penalities to be passed on to the actual consumers - the tenants," says Douw De Kock, chairman of SAPOA's Energy Efficiency Task Team and Group Utility Manager at Broll. He 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 priviledges with regard to penalties charged. "In the case of shopping centres and office buildings, more than 80% of electricity consumption is controlled by tenants. The landlord has limited capacity to influence consumption if punitive tarrifs can't be passed on to the actual consumers," explains Douw. "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 issue is the sector saving target for multi-tenanted buildings, SAPOA believes that the current proposal of 20% 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% savings target for multi-tenanted buildings, if the applicable rate is reduced from, say 25GW to 20GW" Douw elaborates.
Futhermore, SAPOA strongly recommends that all calculations should be based on actual readings, not estimates as outlined in the consultation paper, indeed the Task Team believes any reference to estimates in the Rules should be clearly defined or omitted entirely.
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," Douw says.
Author: Shopping SA
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