Following the entry into force of the revised version of the Energy Performance of Buildings Directive (EPBD) on 9 July 2018, the Architects' Council of Europe calls for an ambitious implementation of the Directive by the Commission and Member States. ACE welcomes some improvements (renovation targets, consideration of well-being and comfort) but regrets that the co-legislators have not gone far enough in some areas (Energy Performance Certificates [EPCs], disclosure of data, measurement of actual performance).
ACE welcomes the high level of ambition for the renovation of the building stock: setting the objective of transforming "the national stock of residential and non-residential buildings, both public and private, into a highly energy efficient and decarbonised building stock by 2050" (art. 2 bis) is a prerequisite for boosting investment and accelerating the transition to a more efficient, comfortable and healthy building stock. ACE is also pleased to see that the energy efficient renovation of the building stock is seen as a means to fight climate change (recital 7). ACE advocates that energy retrofits need to be incentivised and regulated as part of overall functional and aesthetic upgrades of buildings in order to deliver greater return on investment in terms of property value and well-being.
ACE welcomes the introduction of new references to indoor environment quality, well-being and comfort. This goes in the direction of a more holistic approach to building performance at a building, neighbourhood, city and stock level. ACE considers that it is crucial to target improvements across all four pillars of building performance: consumption of natural resources, indoor environmental quality, occupant satisfaction and value over the life-cycle of a building. However, ACE estimates that the EPBD does not sufficiently tackle life cycle impacts and is concerned that this can result in unintended environmental impacts (embodied energy, material pollution, life cycle costs, building resilience).
While ACE expected more in this area, it welcomes some dispositions allowing for a greater consideration of measured and actual building performance and steps towards a limited disclosure of data, for statistical and research purpose (Article 10). ACE calls for the harmonisation of reporting metrics across Member States and the disclosure of building performance data to ensure the rapid and continuous improvement of energy efficiency measures and technologies.
ACE will closely monitor the development of the Smart Readiness Indicator (SRI) and the feasibility study on an optional Building Renovation Passport. While ACE recognises the benefits of building automation and smart devices, it also warns about their risks and costs, as they have been identified as a cause of performance gap and the source of excessive maintenance costs.
ACE asserts that the Energy Performance Certificates (EPCs) are not sufficiently reliable to be used to underpin financial measures (art. 10, paragraph 6). Throughout the legislative procedure, ACE has called for the validation of calculated EPCs with measured operational performance data. Only validated EPCs should be used to underpin financial instruments.
Finally, ACE strongly opposes the exemption of systems from inspections when equipped with smart features. ACE believes that inspections (onsite or remote) are absolutely necessary to ensure that building systems actually achieve their expectations. ACE recommends allowing inspections to be carried out remotely instead, and only once the remote and on-site readings have been reconciled. This would still significantly reduce the legislative burden and would create an incentive to get the automation installed and commissioned so that it can be remotely accessed and operated.
Member States now have 20 months in which to transpose the revised EPBD into national law. Aware that much remains to be done in the coming months, ACE will continue to support its Member Organisations during the transposition period and to contribute to the work of the Commission, for a more ambitious implementation of the revised EPBD.