Fit for 55: Why ‘aligning’ the EPBD with the renovation wave is not enough

Greenhouse gas emissions must decrease as soon, as quickly and as deeply as possible. It is time to deliver on the announced targets by taking forwarding actions and deliver results. Earlier this month, BPIE (Buildings Performance Institute Europe) published a wake-up call in order to achieve a much needed revision of the EPBD, expected before the end of this year.  

The Energy Performance of Buildings Directive (EPBD) is set for a revision before the end of this year, as part of the European Commission’s Fit for 55 legislative package. In its announcement to launch an early revision of the EPBD, four years ahead of the planned review, the European Commission set the aim to align legislation with the Renovation Wave objectives, meaning to at least double the annual energy renovation rate by 2030 and to foster deep energy renovations. BPIE’s most recent publication The make-or-break decade: Making the EPBD fit for 2030 argues that the European Commission should use this opportunity to ensure a comprehensive legislative review, as opposed to a targeted, ‘cherry picking’ revision approach. Published in the wake of the IPCC’s Sixth Assessment Report on climate change, the report stresses that any legislative revisions taken now must be fit to respond to the climate emergency.  

The EPBD is a keystone piece of legislation that should ensure the building sector contributes to the achievement of the EU’s updated 2030 and 2050 climate targets. This means reaching an annual 3% deep renovation rate and a 60% reduction in GHG emissions by 2030. In parallel to renovation rate and depth, the social aspects of European housing should also be given priority. Particular attention should be given to alleviating energy poverty and achieving a just and fair transition towards carbon neutrality. 

While a continuous effort to thoroughly implement and enforce current legislative provisions must be taken by both the EU institutions and Member States, the revision this year should nonetheless go well beyond this. First, the EPBD should ensure a clarified and more ambitious 2050 vision for the building stock that integrates whole-life carbon (WLC) considerations. Even though the EPBD Article 2A, that sets the objective of a “highly energy efficient and decarbonised building stock” by 2050, has been a major positive addition during the last revision, the concept remains vague. The EU building stock should become net zero energy and carbon over the whole life cycle. This includes achieving a very high energy performance (putting energy efficiency first) as well as undergoing a full decarbonization at operational phase (energy supply by renewables only). Additionally, low embodied carbon emissions in building and construction materials and processes need to be ensured. Beyond continuing to promote and implement the energy efficiency first principle, the EPBD revision should be directed into integrating WLC as an additional operating principle. Gathering more data is a first and necessary step before setting requirements, which must be announced well before they come into force to provide the market with sufficient lead time to prepare. In order to contribute to the establishment of a whole-life carbon roadmap, the EPBD should improve the understanding of WLC accounting by introducing clear operational and embodied carbon metrics as add-ons to energy performance metrics. The contribution also needs to include requiring new constructions, public buildings and large non-residential buildings to assess and disclose information on embodied carbon emissions, using those established metrics. 

Secondly, climate-neutral compatible standards must be in place for all buildings. In particular, this means updating building standards for new buildings, going beyond current nZEB definitions, as these will not fully contribute to the decarbonization of the building stock up to the level required to achieve climate-neutrality by 2050. To achieve Europe’s climate goals, new buildings should be net zero energy and carbon over their lifecycle as of 2030.  

The cost-optimal methodology, which sets requirements for buildings, should also mainstream deep renovation and make it standard practice. This methodology has not been revised since 2010 and was initially introduced to guide Member States when setting energy performance requirements for existing and new buildings. However, given the state of the climate emergency, as well as the urgent need to combat energy poverty and the economic and societal benefits we know that building renovation brings, the principle of climate-neutrality, rather than cost-optimality, should be core to setting building performance requirements and decision making.  

The revision of the EPBD should also bring with it an ecosystem of transformative policies and measures for the whole building stock. Minimum Performance Standards should be introduced to drive action on both renovation rate and depth, and financial instruments should be leveraged and supported by a strengthened technical assistance framework. Finally, strategic policy planning must be underpinned by reliable data. Owners and tenants should have easy access to information and guidance facilitating their investment decisions.   

Ultimately, the revision of the EPBD must be undertaken in light of the urgency to address climate change, while addressing societal challenges such as affordability of housing and energy poverty. The EPBD must be revised with a perspective to 2050, so the building sector can fully contribute to the achievement of our collective climate targets. Europe has the means to get its climate and buildings policy. This decade is a make-or-break opportunity, and we  cannot waste it.  The time is now.