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The South African National Standard (SANS) 10400-XA is an instrument made by government to regulate energy use and encourage energy efficiency in building. For this purpose the government sets a set of requirements for the retrofitting of existing buildings and for the design of new buildings.
The National Energy Efficiency Strategy (NEES) issued by the South African Department of Energy (DOE) in 2005 set a national aspirational target for EE improvement of 12% by 2015 (using a 2000 baseline). The NEES covers all energy using sectors and allocates a specific target for each one. As occupied buildings are found in all sectors, SANS 10400-XA cuts across all sectors and ultimately supports the country’s GHG emission reduction targets as per the Copenhagen commitment to 34% below its “business-as-usual” growth trajectory by 2020, and by 42% by 2025, subject to specified conditions.
The majority of South Africa’s buildings are considered to be highly energy inefficient. Moreover, the building stock is likely to increase substantially over the next decades. Given the need for urgent energy efficiency improvements in the sector, the government launched mandatory energy performance standards (MEPS) for buildings.
In order to mitigate the energy demand in buildings of various sectors, the South African National Standard 10400-XA (in short SANS 10400-XA) was introduced in 2011. SANS 10400 includes several parts from A to X. For instance, Part B is about Structural Design or Part L deals with Roofs. Part XA (or SANS 10400-XA) regulates the maximum allowable energy consumption for all new buildings as well as significant additions to existing buildings.
SANS 10400-XA offers some kind of flexibility to building owners or architects on how to achieve energy performance requirements. There are two main options. On the one hand, the Prescriptive Approach, for instance, requires wall insulation for certain types of buildings. On the other hand, two more approaches exist (the Performance Approach and the Reference Building Approach) mandating that a so-called “Competent Person – Energy” accompanies the design and construction process of a building. A Competent Person is defined in SANS 10400-XA as “a person who has the necessary education, training, experience and contextual knowledge to make a determination in terms of a functional regulation”. In this case a Competent Person – Energy will typically be a mechanical engineer or architect, who has been on appropriate courses pertaining to the SANS 10400XA ‘Energy Usage in Buildings’ Regulations. Most multidisciplinary engineering consultancies offer this service.
In both instances the objective is to reduce energy consumption. Ultimately the regulation does not concern itself as to how energy savings, except for hot water, are achieved but that a minimum threshold is met, through a combination of passive and active measures.
Compliance with SANS 10400-XA is required and is monitored through Building Control Officers employed with local building authorities.
Minimum energy performance standards for buildings can be found all over the world. For instance, the Chinese government introduced a building code for residential buildings. Initially, the Chinese code applied only for buildings in cold regions, but was extended to other climate zones. Unlike in South Africa, where building code verification is carried out by Building Code Officers, in China compliance checking is done through third-parties, which are, in turn, supervised by semi-governmental (local) organisations.
In most industrialised countries such as Germany building codes have been implemented and belong to the set of core measure to drive down energy consumption in buildings. In such country groups, buildings codes are, generally, more tightly interwoven with a set of measures (e.g. energy performance certification, financing support through grants or loans for energy efficient construction or refurbishment).
Buildings in South Africa are known to be very energy inefficient. Moreover, a combination of a temperate climate and low energy costs stimulate the excessive consumption of energy. SANS10400-XA aims to address this by imposing MEPS for all new buildings.
SANS10400 as a mandatory building standard evolved gradually. The timeline of energy regulations for buildings in South Africa can be summarised as follows:
Based on historical trends and anticipated government investment programmes (social housing), it is likely that investment in residential and non-residential buildings will grow on average at around 2% per year between 2008 and 2050 which would result in the total building stock doubling by 2050. If CO2 emissions were unchecked, this would result in a twofold increase in emissions (UNEP, 2009).
The primary objective of the programme is to improve the energy efficiency performance of all new buildings or additions to existing buildings. SANS10400-XA is only a requirement for additions if they are of a nature where building plans must be submitted to the local authority for approval.
Both active and passive measures are used.
It is a national regulation.
The National Building Regulations and Standards Act (1977) makes it an offence to erect any building without the approval of the Local Authority in which jurisdiction the building is to be erected. The Act makes provision for the Minister of Trade and Industry to issue National Building Regulations in terms of the Act. Compliance with these regulations is therefore mandatory.
Passive cooling techniques
Passive solar heating
Domestic Hot Water
Building Energy Management
The SANS 10400-XA seeks to reduce the energy consumption of new buildings or significant additions to existing buildings. Hence, it is to prevent energy-inefficient buildings from entering the market.
More specifically, SANS 10400-XA requires that:
These methods include (i) the Prescriptive Approach requiring building owners to implement a set of energy-saving technologies and measures. The Prescriptive Approach is also referred to as the deemed-to-satisfy approach. For instance, wall insulation is required for some types of buildings or if the total glass area exceeds 15% of the floor area, the glass areas must be shaded. In that respect, it should be noted, that the Prescriptive Approach also includes requirements included in the SANS 204, which is a voluntary building standard. The Prescriptive Route is generally used for houses and smaller buildings. This route requires that a set of rules is adhered to for water heating, insulation and glazed areas, i.e. windows, glass doors and roof lights.
The following figures from the City of Cape Town illustrate a schematic outline of what is required:
Orientation: According to the voluntary SANS 204 standard the building should be compact in Plan with rooms that are used most and the major areas of glazing placed on the northern side of the building to allow solar heat to penetrate the glazing during the winter months. The major axis of the building should run east/west and the roof overhang should provide shading to the windows from the midday summer sun.
Apart from that, there is (ii) the Performance Approach. For this second approach a so-called rational building assessment/design is compulsory. The design should demonstrate the building’s theoretical annual energy consumption, which may not exceed the maximum values in the regulation. While the Prescriptive Approach can be carried out by an ordinary architect, the Performance Route requires a “Competent Person – Energy”, who has to be approved by the respective local authority. A competent person is someone who “has the necessary education, training, experience and contextual knowledge to make a determination in terms of a functional regulation“ (Sustainability Institute 2013). Hence, architects may also perform this function. Thirdly, building owners are also free to opt for (iii) the Reference Building Approach. It requires using materials/systems tested and certified by Agrément South Africa, a public body assessing construction material, to ensure that building values do not exceed a referenced building, which has met the requirements of the prescriptive approach. Again, a “Competent Person – Energy” accompanies the building design and construction process.
SANS10400-XA programme is tightly integrated and interwoven with other measures to promote energy savings in South Africa’s building sector. For instance, the SANS10400-XA can be seen as an essential contribution towards attaining the national 12% voluntary energy savings target from then National Energy Efficiency Strategy as well as the country’s GHG emission reduction targets as per the Copenhagen commitment to 34% below its “business-as-usual” growth trajectory by 2020, and by 42% by 2025, subject to specified conditions. Moreover, it supports the Green Economy policy and Green Jobs of the Economic Development Department. These two policies identify and aim to maximise the opportunities being presented by the new green economy to create new economic development and job creation.
Apart from that, the South African Energy Development Institute has promoted the issue of energy efficient buildings through national awareness raising programmes such as the My Green Home campaign. Even though the initiative targets only building refurbishment and training occupants to more rationally use energy, the campaign can be considered to raise the public’s awareness for energy efficiency, in general. Hence, by becoming more informed about the issue people may become inclined to invest in energy efficiency measures and technologies that result in buildings overperforming SANS 10400XA.
For further information on policies facilitating energetically efficient buildings, bigEE hosts an article on South Africa’s policy package.
If building owners seek to exceed requirements established through the SANS 10400-XA, they are allowed to fulfill guidelines set with the SANS 204. The SANS 204 is a voluntary building standard, which exists in parallel to the SANS 10400-XA.
SANS 10400XA is a regulation and all building plans are required to meet the minimum requirements. Therefore the policy does not include innovative elements
Compared to international standards the values of maximum allowable energy consumption are not overly stringent. As a result most new buildings comply without any additional measures, as shown in the figures below (GIZ, 2014) and there is a strong argument for an immediate need to revise the figures.
DEA: Department of Environmental Affairs
Block E: SANEDI office park
GBCSA: Green Building Council SA
Solid Green: Energy Consulting Company
The same study found that a similar figure emerges for hotels
South Africa is split into six climate zones as shown in the map below
But if the allowable energy consumption per zone is compared the differences are very small, as shown in the graph below, raising the question as to whether different allowances per climate zone are required at all. Perhaps a more straightforward approach where a level is set for the entire country would be more practical. This is currently being reviewed by SABS and there may be specific reasons to keep the existing climate zones.
Optimisation of the policy package
The policy package could be optimized through the introduction of Energy Performance Certificates (EPCs), in particular. EPCs can contribute to raising the awareness of energy consumption in buildings and facilitate information on cost savings resulting from energy efficiency measures and technologies. This may give an impulse for market transformation towards more buildings constructed in line with higher energy performance levels. In several countries, EPCs are mandatory and must be disclosed once a building is let or sold (e.g. see the bigEE’s Good Practice Policy on Australia’s Commercial Building Disclosure). Apart from that, for instance, in Germany building owners that seek to significantly overperform the country’s minimum energy performance standard are eligible for a preferential loan (see bigEE’s Good Practice Policy on Germany’s Energy Efficiency Refurbishment and Construction Programme).
A national education and awareness campaign could change perceptions of ‘just another regulation making things difficult’ to ‘this is a well-considered and relevant regulation’.
The following pre-conditions are necessary to implement SANS10400XA:
Agencies or other actors responsible for implementation
While architects and developers are in charge of the correct implementation of the code requirements, Building Control Officers, which are employed with local authorities, are responsible for approving construction designs and further information provided by architects and developers.
However, the position (authority) of Building Control Officers should be strengthened and kept up to date with policy, technical and regulatory developments. In particular, in recent times BCO positions are often neglected, especially in medium and smaller municipalities. A programme to train BCO in medium and smaller municipalities was funded by the Swiss Development Corporation and was very effective. Additional and continuous activities such as these should be considered for the future. Moreover, fines and penalties are not onerous, as many of them date back to when the National Building Regulations were introduced in 1977. As a result where transgressions occur the BCO are often powerless
SANS 10400-XA was only added to existing building standards, which were not energy-related.
Since 1977, the National Building Regulations and Buildings Standards Act, No. 103 has existed. The Act makes it an offence to erect any building without the approval of respective local authorities. Furthermore, the Act makes provisions for the Minister of Trade and Industry to issue National Building Regulations (NBR). Architects and other actors relevant for building construction must comply with NBR and local authorities or, particularly, aforementioned Building Control Officers assess whether a building complies with NBR requirements. NBR, in turn, are comprised of the SANS 10400 series. The Series includes several parts from A to X. For example, Part B is about Structural Design of a building, Part D is on Public Safety or Part L on Roofs. And Part XA on Energy Usage was added only recently in 2011.
The following figure may help for illustration purposes.
Please note that the bottom of the figure suggests that there are different ways to comply with SANS 10400-XA by either using a prescribed way to fulfill energy performance standards or by submitting a rational design with the help of a Competent Person – Energy.
The regulation does not have a specific target but supports the voluntary EE target of 12% and contributing towards the country’s GHG emission reduction targets as per the Copenhagen commitment to 34% below its “business-as-usual” growth trajectory by 2020, and by 42% by 2025, subject to specified conditions. To meet these targets an 8% revision on previous allowance required every two years.
The programme has received support from the Swiss Development Corporation and the German Gesellschaft für internationale Zusammenarbeit (GIZ).
Actors responsible for design
South African Bureau of Standards
Construction Development Industry Board (Government Agency)
Actors responsible for implementation
Local government BCO
The programme results are not monitored or evaluated.
Passive design features, such as insulation, natural light etc will improve the thermal comfort and experience of building occupants. SANS10400XA also mitigates greenhouse gas emissions and, hence, climate change impacts. Since South Africa’s energy and power mix is dominated by coal, health affecting air pollution may also be addressed.
The following barriers have been experienced during the implementation of the policy
Several barriers have been experiences through implementing the SANS10400XA programme, some of which are shown below:
The following measures have been undertaken to overcome the barriers
Energy savings are not monitored or evaluated.