Position Paper on Energy Performance of Buildings Directive Recasting

POSITION PAPER on the Recasting of the Directive 2002/91/EC of 16 December 2002 on the Energy Performance of Buildings

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Author : ConcertoPlus & Concerto communities

September 2008

The CONCERTO initiative focuses on the integration of the energy efficiency (EE) improvement techniques and the use of renewable energy sources (RES) towards sustainable communities supported by energy management strategies. Since the launch of the initiative in 2005, 45 participating communities are developing and demonstrating concrete strategies for a variety of measures which include the refurbishment of existing buildings, the construction of highly efficient eco-buildings, energy systems using renewable energy sources and polygeneration to supply whole districts with energy from renewable energy sources. Today about 5 million European’s live in CONCERTO communities and before 2010 approximately 300.000 people will be living and working in CONCERTO demonstration buildings or indirectly benefit from the CONCERTO measures. The contribution of all CONCERTO communities in terms of reduction of CO2 emissions is comparable to a 35.000 inhabitants town being totally CO2 neutral. But much more than a quantifiable amount of avoided CO2 emissions, the CONCERTO communities innovate in creating and implementing new mechanisms for the development of sustainable communities, and therefore the impact of CONCERTO is expected to be much higher in future.

For this reason the CONCERTO communities would like to present a collective position paper on recasting the Directive 2002/91/EC based on their own concrete field experiences.

The CONCERTO Communities appreciate the activities of the European Commission, of the European Parliament and of the Council to promote the improvement of the Energy Performance of Buildings Directive (EPBD) within the European Community.

Main conclusions and recommendations from the CONCERTO communities:

>The definition of the word “inspection” in article 8 and 9 should be clarified in order to have a common understanding of what an inspection procedure consists in. The regular inspection of boilers and/or air-conditioning systems should be kept and include ventilation systems although if they are not considered as air-conditioning systems. The results from the inspection should be documented in an inspection report.

>The lowering of the 1000 m2 total useful floor area threshold for existing buildings that undergo major renovation should be accompanied by new systematic technical, legal and financial supporting mechanisms defined at national level. In the same way, the 1000 m2 total useful floor area threshold for the requirements on ’alternative systems’ should be eliminated.

>The energy performance certificate should include energy needs and final energy use figures (as defined in EN15603), as well as the corresponding primary energy use and CO2 emissions ratings.

>For existing buildings, the actual energy consumption of the building in the past years should be clearly reported, in order to include the energy use of all electrical appliances and sensitise the user to his own influence: CONCERTO projects have demonstrated the benefit and the functioning of user feedback systems. The energy performance of the single components like heat pumps, ventilation or domestic hot water preparation systems should be also reported in the certificate.

>The quality of the inspections and the energy performance certificates can only be insured if a certified professional category legally recognized for certification is defined at national level. Member states should also be obliged to create national databases to ensure the storage of historical data and allow for statistical analyses. Member states should also set up a legal framework to oblige a third party, like notaries, to authorize a transaction only when a certificate is made available.

>Considering the public sector, every public building should act as front runner in energy performance aspects and have the energy performance certificate including the actual energy performance figures placed in a prominent place clearly visible to the public.

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