To the kind attention of Kadri SIMSON
Minister for Economic Affairs and Infrastructures of Estonia
Cc: EU27 Energy Ministers, European Commissioner Miguel Arias Cañete and Bendt Bendtsen MEP
Brussels, 1 December 2017
I am writing to you on behalf of the European Alliance to Save Energy (EU-ASE). EU-ASE is a multi-sectoral business organisation whose members have operations in your country and across the 28 Member States of the European Union, employ 340.000 people in Europe and have an aggregated annual turnover of €115 bn.
Considering the strategic relevance of the ongoing negotiations between the Council, the European Commission and the European Parliament on the Energy Performance of Buildings Directive (EPBD), we count on your full support for an ambitious revision of this key Directive, as put forward in the report adopted by the European Parliament on 11 October.
The revision of the EPBD is a unique opportunity to strengthen the business and investors’ confidence in the building sector to further develop a comprehensive approach to their efficiency (by looking both at optimized energy supply and their energy consumption) and to put new and existing buildings’ performance at the centre of the EU’s energy transition.
We call on you to include the following key provisions in the final legislative text:
- • Enrich long-term national renovation strategies with the inclusion of a 2050 objective, a differentiation of building typologies, the addition of trigger points, the concept of voluntary building renovation passport to support staged deep renovation, milestones in 2030 and 2040 and measurable progress indicators. Only credible and robust renovation strategies will incentivize private investments, facilitate access to financial tools and hence boost the very low buildings’ renovation rate;
- • Set a mandatory requirement for the equipment of building automation and control in non-residential buildings by 2023 to reflect the latest technological developments and enable buildings’ connectivity to the energy system. Ensure effective controls and monitoring in large residential buildings; enshrine appropriate control functionalities in individual rooms;
- • Require that the overall energy performance of the complete altered technical building system is assessed at part load;
- • Set a mandatory framework to define and implement the Smartness Indicator in all Member States on the basis of a design/methodology set in Annex Ia, while ensuring its complementarity with Energy Performance Certificates;
- • Ensure consistency in Annex I with the Energy Efficiency First principle through adequate consideration of energy needs in the energy performance calculation as well as the equal treatment for on-site and off-site renewables. In fact, it is essential to support an energy transition where both high energy efficiency solutions and integration of renewables are working together in a mutually reinforcing manner.
The EPBD is a key piece of legislation to enable the transition towards a smarter and more efficient building stock; it must not be set aside from the rest of the Clean Energy Package.
We trust you will take in due account our recommendation to go in the right direction, as set by the report adopted by the European Parliament.
President of the European Alliance to Save Energy (EU-ASE)