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Over the
course of the past year EU institution and stakeholders conducted long
negotiations on the 2nd review of the EPBD.
REHVA has worked with its Member Associations to define its position about the
draft legislation and contributed with its comments during the legislative
process. As expected, the EP proved to be more ambitious and listened to the
voice of EU level stakeholders in key issues for REHVA, including the
strengthening of IEQ requirements, ensuring proper maintenance supported by
effective inspections schemes and committing to ambitious EU energy efficiency
targets. Members States (MS) were reluctant to approve additional binding
requirements, the difference in the positions even resulted in a temporary
collapse of the trialogue talks between Council and EP end of 2017. Finally,
the parties reached an agreement just before Christmas in an 8-hours intense 3rd negotiation round. This agreement was confirmed by
the ambassadors of MS on 31 January 2018, so the compromise directive text can
be approved in April 2018.
The recast
EPBD integrates many requirements regarding the acceleration of deep energy
renovation of buildings in Europe. A major success of the political
negotiations was that MS agreed to develop national renovation
strategies to achieve an energy efficient and decarbonised European
building stock by 2050 reducing the EU greenhouse gas emissions by 80–95%
compared to 1990. The strategies shall set mid-term goals for 2030 and 2040 and
define milestones with measurable progress indicators.
The
consideration shows that MS’s are seeking the cost-efficient equilibrium
between a decarbonised energy supply and reducing the final energy use of
buildings, implying an average 3% renovation rate towards nearly zero energy
level, where “nearly” is understood as cost-effective and therefore depends on
the costs of a non-renewable energy unit (the carbon emission part of the
energy supply) and the cost of measures to reduce the energy use of buildings.
The
strategies shall also address healthy indoor climate conditions, fire safety
and risks related to intense seismic activity.
National
renovation strategies should address the following aspects:
·
an
overview of the national building stock and expected share of refurbished
buildings in 2020;
·
identification
of cost-effective approaches to renovations relevant to building type and
climatic zone, considering potential trigger points in the building life-cycle
·
policies
and actions to stimulate cost-effective deep renovations, including staged deep
renovations or building renovation passports;
·
policies
and actions to target the worst performing segments of the national building
stock, split-incentive dilemmas, market failures, and actions to alleviate
energy poverty;
·
policies
and actions to target public buildings; national initiatives to promote smart
technologies and communities, as well as skills and education in the
construction and energy efficiency sectors;
·
an
evidence-based estimate of expected energy savings and wider benefits, such as
those related to health, safety and air quality.
The
directive advises MS to ensure that the measures to improve energy performance
don’t focus only on the building envelope but include all relevant elements and
technical systems. When buildings undergo major renovations, MS shall encourage
that technical building systems are replaced or upgraded to high efficiency
ones as far as technically and economically feasible. Technical building
systems play an important role in reducing costs and maintaining or improving
the IEQ in our buildings.
The
directive puts more emphasis on the quality and compliance of energy renovation
and encourages that financial measures related to energy efficiency are linked
to quality, and to certified performance improvements, which should be assessed
by comparing EPCs issued before and after the renovation, or by adequate energy
audits.
Inspection was another tough part of the talks and here the Council set through its position.
The EP proposed mandatory regular inspections and cancelled “adequate advice”
as an alternative, a position strongly supported by REHVA and several EU level
stakeholders. Both requirements were modified in the final compromised version.
The
articles 14 and 15 on inspection of heating and air-conditioning systems have
been changed on mayor points. The threshold for inspection of heating systems
is changed from 20 to 70 kW rated effective output (ventilation included). MS
have the sole competence to decide on the appropriate measures and frequency,
including “advice, so even avoid having inspection schemes. MS can opt for not
requiring repeated inspection until the systems or the buildings heating and
cooling requirements have changed. For small scale installations, the
documentation of the system performance by installers is approved as sufficient
support of compliance with performance requirements. Technical building systems
of buildings that are part of an energy performance contract are exempted from
regular inspection.
To
directive states the importance of inspection in achieving building energy
performance improvements and improve the operational energy performance of
HVAC. Inspections should assess the sizing and the capabilities of the
equipment to improve system performance also under part load operating
conditions and encourage the upgrade and replacement of inefficient HVAC
systems.
Building
automation and control (BAC) systems are considered as the most cost-effective
alternative to inspections in large non-residential and multi-apartment
buildings. The directive requires that non-residential buildings above an
effective rated heating or combined heating and ventilation system output of
290 kW are equipped with BAC-s by 2025, where technically and economically
feasible. Buildings with BAC installed are exempted from regular inspection.
REHVA had a different position regarding the role of BAC and their capacity to
replace inspection, advocating for mandatory third-party testing.
The
Directive also mandates the Commission to conclude, by 2020, a feasibility
study about the possibilities and timeline to introduce the inspection of
stand-alone ventilation systems and an optional building renovation passport
complementary to Energy Performance Certificates (EPCs) providing long-term,
step-by-step renovation roadmap for specific buildings to improve energy
performance. This can support the development of a possible Indoor
Environmental Quality declaration as part of the EPCs.
The Council
has agreed on the establishment of a voluntary Smart Readiness Indicator (SRI)
promoting digitalisation and smart technologies. The Commission shall adopt a delegated act by 31 December 2019 establishing
an optional common European Union scheme for rating the smart readiness of
buildings. This rating shall be based on assessment of the buildings’ or
building units’ capabilities to adapt its operation to the needs of the
occupant, and the grid, and to improve its energy efficiency and overall
performance, including indoor comfort and heath.
The SRI
shall cover features for enhanced energy savings, benchmarking and flexibility,
enhanced functionalities and capabilities resulting from more interconnected
and intelligent devices. The methodology shall consider features such as smart
meters, building automation and control systems, self-regulating devices for
indoor temperature, built-in home appliances, recharging points for electric
vehicles, energy storage and detailed functionalities and the interoperability
of these features, as well as benefits for the indoor climate condition, energy
efficiency, performance levels and enabled flexibility.
Three key
functionalities are listed:
·
the
ability to use energy from renewable sources in a flexible way,
·
the
ability to adapt its operation mode in response to the needs of the occupant in
a user-friendly way, to maintaining healthy indoor climate conditions and to
report on energy use,
·
the
flexibility of a building's overall electricity demand, including
demand-response in relation to the grid.
The
methodology shall not negatively affect existing EPC schemes and build on
related national initiatives, while considering occupant ownership, data
protection, privacy and security. Is shall set out the most appropriate format
of the SRI parameter, be simple, transparent, and easily understandable for
consumers, owners, investors, and demand response market participants.
Currently a
consortium of consultants contracted by DG Energy is working on a study
defining the criteria and a calculation methodology based on related
international and European standards, and a feasibility study about the SRI
indicator. REHVA follows the process and provides inputs to the work of the
experts.
REHVA has
been advocating for strengthened IEQ requirements and health aspects in the
EPBD, supported also by the European Parliament. The compromise legislation
contains some improvements, although it doesn’t set binding European IEQ
criteria. The IEQ related relevant point of the directive are the following:
·
For
new buildings and buildings undergoing major renovations, MS should encourage
high-efficiency alternatives while also addressing healthy indoor climate
conditions. MS should support that energy performance upgrades of existing
buildings contribute to achieving a healthy indoor environment.
·
The
directive refers to the 2009 WHO guidelines concerning indoor air quality, and
better performing buildings that provide higher comfort levels and wellbeing
and improve health.
·
The
Annex I of the directive indirectly mandates MS-s to define comfort and indoor
air quality levels to safeguard the health of the building users by requiring
that the energy needs for space heating, space cooling, domestic hot water,
lighting, ventilation and other technical building systems shall be calculated
in order to optimise health, indoor air quality and comfort levels defined by
Member States at national or regional level.
·
Long-term
renovation strategies shall contain evidence-based estimate of expected energy
savings and wider benefits, such as those related to health, safety, and air
quality.
·
The
feasibility study on the inspection of stand-alone ventilation systems that
shall be carried out by the EC before 2020 can support the development of a
possible Indoor Environmental Quality declaration as part of the EPCs.
The energy
performance of a building shall be determined based on calculated or actual
energy use reflecting the typical energy use for heating, cooling, domestic hot
water, ventilation and built-in lighting and other technical building systems.
The energy performance shall be expressed by the numeric indicator of primary
energy use in kWh/(m².y). The calculation methodology
shall be transparent and open to innovation. MS shall describe their national
calculation methodology following the national annexes of the overarching
standards (EN- ISO 52000-1, 52003-1, 52010-1, 52016-1, and 52018-1.)
developed by CEN under mandate M/480. However, this doesn’t constitute any
legal codification of standards in the MS.
Member
States have the competence to define primary energy factors or
weighting factors to calculate primary energy be energy carrier, which may be
based on national, regional or local annual, and possibly also seasonal or
monthly weighted averages, or on more specific information made available for
an individual district system. In the application of these factors MS shall
ensure that the optimal energy performance of the building envelope is pursued.
MS may consider renewable energy sources supplied through the energy carrier
and generated on-site when calculating the primary energy factors if the
methodology applies on a non-discriminatory basis. MS may also define
additional numeric indicators of total, non-renewable and renewable primary
energy use, and greenhouse gas emission produced in kg of CO2 equivalent per m² per year.’
CENTC371 is
currently developing the standard “Energy performance of buildings —
Determination and reporting of Primary Energy Factors (PEF) and CO2 emission factors procedure — Part 1: General
Principles and Methodological approach”. This standard could become a good
basis for the harmonisation of these procedures throughout Europe in the
future.
The new set
of EPB standards should be implemented in all EU member states. Using the same
energy performance assessment procedures throughout Europe would stimulate
innovative energy saving solutions that can be applied everywhere in Europe,
because they will be awarded according to the same principles in a transparent
way. Sticking to separate national procedures in the EU countries crates and a
market barrier for energy saving products, systems and technologies.
REHVA has
been advocating for the harmonised and ambitious application of EPB standards
in MS-s and promotes the harmonization of national calculation methodologies to
ensure the reliability and transparency of the energy performance assessment.
REHVA is committed to further actions to convince and support national
regulators to follow this route.
Jaap
Hogeling, EPB
Center, jaap.hogeling@epb.center
Anita
Derjanecz, REHVA Managing Director
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