EuroACE Feedback: EPBD Inception Impact Assessment Roadmap

EuroACE welcomed the work of the Commission in revising the Energy Performance of Buildings Directive (EPBD) as part of the ‘Fit for 55 Package’. The revision is instrumental to the double challenge of ensuring our building stock can play its role in achieving the revised 2030 and 2050 EU climate targets, and scaling up the Renovation Wave to support a swift economic recovery from the COVID-19 pandemic.

Doubling the energy renovation rate (currently around 1%) will not be enough. Tripling the current rate and focussing more on the depth of energy renovations, via a holistic approach that takes into account energy savings, CO2 emissions reduction and the improvement of Indoor Environmental Quality, is of vital importance. Rate and depth should be given the same level of importance throughout the Roadmap.

We applauded the Commission’s horizontal approach to the revision. The EPBD should create mutually reinforcing synergies with other Fit for 55 initiatives, starting with the alignment around the Energy Efficiency First principle and the recognition of how energy efficiency interacts with the EED, RED II, EU ETS, ESR, Ecodesign and the Energy System Integration Strategy.

Reducing energy demand first will ultimately enable a swifter and more technically feasible transition towards fully decarbonised energy supplies. The revision should therefore drive further significant improvements in the operational energy performance of buildings, using passive and active technologies and building automation and control systems, while also supporting whole life cycle carbon approaches based on Level(s).