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BPIE's response on the EPBD-consultation

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The consultation is designed to allow respondents to answer questions that are important to them, their knowledge and experience, and/or their concerns. The questions are in English; Commission services invite respondents to respond in any official EU language.

Overall Assessment

In your opinion, has the EPBD contributed sufficiently to accelerate investments in improving the energy performance of the EU's building stock. Although the effect of EPBD has not been quantified, its basis on avoided energy demand and requirements for RE installation in buildings is definitely in the right direction. The main purpose of EPBD is to improve the energy performance of buildings and to that extent to reduce energy consumption in the EU.

Facilitating enforcement and compliance

A clearer definition of the desired energy performance of a near-zero energy building in European legislation would support a more coherent approach by national governments. The implementation of the definition of "major renovation" varies greatly from Member State to Member State and in some cases has not even been implemented. Renovation targets should be clearly defined and directly aimed at unintended applications of the provisions on major renovations.

Minimum energy performance for replacing/renovating parts of the building envelope (roof, wall, window, etc.) and replacing/upgrading/installing technical building systems (heating, hot water, cooling, etc.). Better guidelines need to be developed for understanding the contribution of renewables in NZEB buildings. Certification of the energy performance of buildings, including tailored recommendations for improving the energy performance of buildings.

Quality of the certifiers: There should be a harmonized system across European member states that sets minimum standards for certifiers' training and their professional experience. No, but it is difficult to evaluate as the analysis of the MS Cost Optimal approach has not yet been published. The checking of EPCs after the completion of the works (as for example in Austria, Belgium or France) has proven to be effective in solving recurring problems due to changes between design and execution.

What do you think about the different ways of calculating the energy performance of buildings at national/regional level?

Energy Performance Certificates (EPCs) and stimulating energy efficient renovation of the building stock 16

Provide an overview of the building stock that gives a clear and informative picture of the number, type, energy performance and floor area of ​​the range of different types of buildings in the country 3. Clearly identify the set of policies that, following designed to achieve a deep renovation of the building stock. Work with market dynamics, especially the trigger points when renovation works can be more.

Is setting a minimum target for renovation that Member States should undertake (eg annually; percentage of building stock) important and requires further attention in the context of meeting the goals of the EPBD. Yes, the minimum renewal targets are important and essential to ensure that the objectives of the EPBD are met. There should be targets for upgrading all social housing to at least average stock level within say 10 years.

The lack of comparability is largely due to the differences in the quality of the EPC between countries (sometimes only within one country). EPCs have made building owners and tenants aware of cost-effective ways to improve the energy performance of buildings and, as a result, help increase renovation rates across the EU. EPCs are still often seen as an additional administrative burden for building owners, and not as a useful tool that supports the improvement of energy performance and/or accurately estimates the properties of a building.

The EU has supported the improvement of the energy performance of buildings for many years with a number of financial support programmes. What are the main reasons for the insufficient use of the available funding for energy efficiency in buildings. The profile of investments in energy efficiency has not been highlighted among sectors of the economy with the capacity to invest and drive the market, such as large companies.

Energy poverty and affordability of housing

However, there are some exceptions such as in France, where the French energy transition law states that 50% of future building renovations should focus on low-income households to reduce energy poverty by 15% by 2020; and in England, where the Fuel Poverty Strategy states that the fuel poverty target is to ensure that as many fuel-poor homes as reasonably practicable achieve a minimum energy efficiency of Band C by 2030. Are energy costs for heating and air conditioning set available to interested buyers/tenants. Property owners are generally not obliged to provide information on energy costs to prospective tenants/buyers.

However, in some cases the energy costs are part of the Energy Performance Certificate, which must be attached to the rental/purchase agreement.

Ensuring new highly efficient buildings using a higher share of renewable energy

Smarter regulatory frameworks are needed to maximize the share of energy that is stored or used immediately and locally, especially during peak times. Today's energy market is cross-border and decentralized and is no longer a collection of national systems in which large fossil fuel power plants supply passive consumers. The significant penetration of decentralized and largely inflexible renewable energy production technologies is fundamentally challenging the supply-demand balance of the new European energy market.

This is due to the electrification of the energy market through low-carbon applications such as transport and space heating. A market design is needed that provides storage and more flexibility in demand response, allowing consumers to better participate in the markets. Buildings, as the largest actor on the demand side, are an important player in this transition, but their role in the new energy market has been studied only to a limited extent.

In the complex energy system, energy efficiency and innovative technologies such as storage and demand response play a crucial role in accelerating the transformation of our homes from simple energy consumers to much more active players. Buildings can play a key role in addressing the challenges of the new energy market through energy efficiency and demand-side flexibility. What obligations are missing at EU and national level, and at regional and local level to meet the goals of the EPBD.

Links between EPBD and district and city levels, smart cities and heating and cooling networks.

Links between the EPBD and district and city levels, smart cities, and heating and cooling networks

Information campaigns on energy use in buildings: Building owners, whether private, corporate or public sector, often do not consider the potential energy savings and costs due to energy efficiency measures. Their operation should be supported by financial incentives, market instruments, access to resources, information exchange and platforms that connect relevant professions and potential clients. Targets for energy saving obligations must be mandatory and ambitious: Energy companies are in a very good position to provide quality services and maintain a steady stream of profits while implementing energy efficiency measures for the benefit of the end consumer.

The EPBD should reinforce other government actions aimed at helping energy companies meet their obligations set out in the Energy Efficiency Directive. The framework for the EPBD should be set up accordingly so that it effectively channels the actions under the ESO towards greater savings and towards actions such as elimination of fuel poverty. Coalition for Energy Savings (2013) Guidance for strong implementation of the Energy Efficiency Directive EEFIG (2015) Energy efficiency - the first fuel for the EU economy.

GBPN (2013) Investing in energy efficiency in Europe's buildings, from the perspective of the construction and property sector. Have cost-optimal policies been developed that improve the performance of buildings so that they use less heating and cooling while ensuring a decarbonised energy supply. The uncertainty of some methods and the cloud of possible cost-optimal curves do not necessarily guarantee cost-optimal levels, but rather point towards more consistent and coherent EU construction policies.

In addition, the cost-optimal methodology followed by Member States should be supported by EU guidelines, in line with best practice and aimed at the highest scientific standards.

Awareness, information and building data

Sustainability, competitiveness and skills in the construction sector

The construction sector plays an important role in the European economy, generating almost 10% of GDP and providing 20 million jobs, mainly in micro and small businesses. Through the EU's BUILD UP Skills initiative, between 2011 and 2013, energy efficiency skills needs and gaps were identified for blue-collar workers in the construction sector in 30 countries (EU, Norway and the Former Yugoslav Republic of Macedonia). From 2013, the BUILD UP Skills initiative focused on implementing the national status quo analysis by setting up national training and qualification programs for blue-collar workers.

The competitiveness of construction companies is an important issue, not only for growth and employment, but also for ensuring the sustainability of the sector. The construction and use of buildings in the EU accounts for approximately half of all derived consumption of raw materials and energy. The European Commission aims to help the sector become more competitive, resource-efficient and sustainable.

Skills development in the construction sector is critical to meeting NZEB targets and ensuring long-term performance. The current EPBD does not cover the quality of the works, therefore schemes have been developed to upgrade the quality of the works on other grounds (Building skills, local political will, private initiatives, etc.). The positive French experience with quality frameworks for building airtightness or the failure of the Dutch certification scheme for ventilation system installers suggests that clear requirements or incentives and a robust compliance framework are important success factors to consider when promoting good quality work.

Life cycle analysis shows the relative small importance of the embodied energy of a building, compared to the energy consumption during the operational phase.

Buildings systems requirements

Operational management and maintenance

Referências

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Além disso, como também é confirmado por vários estudos e pesquisas da Buildings Performance Institute Europe (BPIE), em 2011 [5] e em 2013 [6-7], os EPCs tiveram o potencial de