Response to the Public Consultation on the EPBD revision

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s Public Consultation procedure regarding the revision of the Energy Performance of Buildings Directive (EPBD).

Our contribution touched upon planning and policy instruments, information provision and energy performance certificates, as well as enabling more accessible and affordable financing for building renovation.

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Recommendations to shape the decade of buildings renovations

Reducing energy demand and increasing energy efficiency in the buildings sector is a prerequisite for achieving the EU’s energy and climate objectives. This position paper calls on the European Commission to revise the Energy Performance of Buildings Directive (EPBD), aligning its objectives with the European Green Deal.

The revision of the EPBD is a unique opportunity to increase energy savings, optimise energy consumption and reduce GHG emissions from the buildings sector.

In this respect, the EPBD should introduce new policy signals to stimulate a minimum of a 3% renovation rate per year combined with an average energy efficiency improvement of 75% across Europe. This will help the EU to reach its environmental goals while contributing to fast economic recovery, local job creation and delivering of multiple benefits to citizens.

Currently, building renovations occur at a slow pace in the European Union. Only 1% of the total building stock undergoes renovations annually, an insufficient rate to make buildings fit for the EU’s climate goals. To achieve the objectives of the European Green Deal, the decade 2020-2030 must be the witness of an unprecedented wave of renovations resulting in emissions cuts from buildings by 60% by 2030.

The paper presents seven recommendations aimed to:

  1. Acknowledge buildings as energy infrastructure and apply the Energy Efficiency First principle
  2. Introduce Minimum Energy Performance Standards for all the existing building stock
  3. Aim for energy efficient, flexible, and smart-ready buildings
  4. Promote a neighbourhood approach to maximise energy efficiency
  5. Update the Energy Performance Certificates, introduce digital Building Renovation Passports and explore the link with the Digital Building Logbook
  6. Provide more and better technical assistance and build capacity to increase the demand of renovation projects
  7. Ensure all new buildings are both highly efficient and fossil free from 2025 onwards

 

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Boosting energy efficiency through the revision of State Aid rules

The European Commission should revise EU State Aid rules so they can help boost energy efficiency across Europe.

To ensure that the energy markets are fair, flexible, and secure, the EU State Aid rules must address investment gaps by providing enabling conditions for attracting private investment. This is politically relevant considering the context of the Renovation Wave Strategy, which calls for doubling annual energy renovation rates, and considering the investments in energy efficiency improvements required to contribute to the decarbonisation of the industrial sector.

The European Commission recently announced the plan to revise the Energy and Environmental Aid Guidelines (EEAG) and the General Block Exemption Regulation (GEBR) to provide an enabling framework for public authorities to support high-quality renovation while making the most efficient use of limited public funds.

Pending the revision, the Commission announced in the Sustainable Europe Investment Plan and European Green Deal Investment Plan that the current State Aid rules will be applied with the flexibility to support an increase in the rate and depth of energy efficiency improvements, stressing that aid to energy efficiency investments would be simplified and enhanced.

While we support more flexibility in the short-term, we call on the Commission to also seize this moment to:

  • Decisively create a level playing field for energy efficiency investments;
  • Address the overall complexity by simplifying requirements on eligible costs; and
  • Provide clear guidance on the current EU State Aid rules for energy efficiency.

 

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The Urban Waste Water Treatment Directive to fully realise water and energy savings (updated)

Overall, the Urban Waste Water Treatment Directive (UWWTD) has played a substantial role in improving the quality of European water resources and reducing pollution levels in water bodies. However, Europe remains some way from full compliance with collection and treatment requirements and has made little progress with water reuse. We believe the 28-year-old Directive should be updated to better address these critical issues and today’s challenges including climate change, resource scarcity, increased energy consumption and population growth.

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Response to the Roadmap on the EPBD revision

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s publication of an inception impact assessment on the revision of the Energy Performance of Buildings Directive (EPBD). The Alliance brings together businesses, think thanks and Members of the European Parliament to ensure that the voice of energy efficiency is heard across the business and political community.

The EU has committed to a net-zero economy by 2050, and to reach at least -55% GHG reductions by 2030. To get there, this decade must be witness of an unprecedented wave of renovations resulting in buildings emissions reduction by 60% by 2030. Reducing energy demand and increasing energy efficiency in the buildings sector is a prerequisite for achieving the EU ’s energy and climate objectives. Currently around 75% of the building stock is energy inefficient yet almost 85-95% of today`s buildings will still be in use in 2050 . Only 1% of European buildings undergo energy renovations each year and on average the energy saved through renovations is just 9% in homes and 16% in commercial and industrial buildings. The yearly deep energy efficiency renovation rate barely reaches 0,2% for both residential and non-residential buildings.

At this pace, cutting carbon emissions from the building sector to net-zero would require centuries. Last but not least, 75% of buildings energy consumption is still based on fossil fuels. The renovation rate is therefore far too low considering the environmental challenges and the economic opportunities that lie ahead. The Renovation Wave acknowledges this problem and the need to increase the rate and the depth of renovations setting the objective of at least doubling the annual energy renovation rate by 2030 in view of reducing GHG emissions of buildings by at least 60%. EU-ASE believes that the review of the EPBD is a unique opportunity to increase energy savings, optimise energy consumption and reduce GHG emissions from the buildings sector. In this respect, the ongoing revision of the EPBD is key to introduce new policy signals to stimulate a minimum of a 3% renovation rate per year combined with an average energy efficiency improvement of 75% across Europe. This will help the EU to reach its environmental goals while contributing to fast economic recovery, local job creation and delivering of multiple benefits to citizens .

Other measures designed for the decarbonization of the building stock, such as carbon pricing, can be part of this effort, yet we believe it should not replace impactful regulatory measures such as the EPBD which drives energy savings necessary to meet climate neutrality. In our view, policies related to the building sector, including the EPBD, should be kept in the Effort Sharing Regulation sectoral scope with increased ambition.

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