Joint Statement on the Energy Performance of Buildings Directive (EPBD)

Now more than ever it is imperative for the EU to reduce its dependency of Russian gas by ensuring diversification of supply and technologies to accelerate EU’s autonomy while keeping the decarbonisation objectives at the highest level, including in the building sector. The Energy Performance of Buildings Directive (EPDB) can deliver the proper framework for this task, provided that the proposed solutions are indeed proportionate and aligned with the stated objective to decarbonise and ensure the EU energy independence.

Recently, the Council agreed on its general approach, stating that “All new buildings should be zero-emission buildings, and all existing buildings should be transformed into zero-emission buildings by 2050.”

The signatories endorse that overall objective, but are greatly concerned that some of the proposals will hinder the possibility for European citizens to have access to the necessary incentives and technologies to upgrade obsolete and/or inefficient heating systems with the progressive integration of more efficient and hybrid solutions fuelled by the new generation of renewable and low-carbon liquid products. We had relayed our concerns in March 2021[1] and are pleased that some of them were taken into account.  However, we would reiterate certain points.

In particular, we believe the proposed introduction of an explicit recommendation to Member States to ban fossil fuels based technical building systems to be too broad, as it could lead to the disproportionate and discriminatory ban of low-carbon and renewable fuel technologies, predominately used in low-income households and/or off-grid communities, that are already currently  fulfilling the decarbonisation objectives and should therefore continue to be allowed, alongside the technology used for them.

To reach the Commission objective, a more proportionate and effective solution could for instance be the introduction of a narrowly defined, limited ban as recently adopted in France[2], only prohibiting the installation of new boilers with emission equivalent or a superior predetermined threshold. This approach would allow a proper level playing field for all clean solutions to contribute to meeting the EU decarbonisation targets, without disproportionately banning fuels and/or technologies which would be able to help meet these objectives, including already available low-carbon and renewable solutions. Another option to consider is the German approach, which debates on how to best to incorporate 65% of renewables with a combination of technology (eg. hybrid systems) and low carbon and renewable liquid fuels.

The proposed definition of “on-site” is too narrow and de facto excludes several sources of energy such as low-carbon and renewable liquid fuels, creating an unfair distortion and discriminating against consumers which cannot benefit from onsite sources. Furthermore, the definition takes into account only direct emissions when assessing the benefit of on-site renewable energy for additional uses (e.g. mobility), and prevents the recognition of the real environmental footprint of the energy sources considered and their real decarbonisation potential, in direct contrast with the stated requirement “to calculate the life-cycle global warming potential of new buildings” set out in the Directive.

As stated[3] by several MEPs, “Majority of buildings in rural areas are not connected to the electricity or to the gas grid, and it is technically not feasible or cost-efficient for consumers to rely only on renewable energy produced on-site, such as solar power. To achieve a fully decarbonized building stock by 2050, such buildings should be able to utilize other readily available renewable energy sources produced off-site, to be granted the status of a zero emissions building.”

Low carbon and renewable liquid fuels are drop-in fuels: they can be progressively added to the fuel mix without changes to the infrastructure which guarantees a fair and just transition. Their deployment would be an easy win.