KEF, Alm.del - 2020-21 - Bilag 368: Orientering vedr. regeringshøringssvar om revision af Bygningsdirektivet, fra klima-, energi- og forsyningsministeren

Klima-, Energi- og Forsyningsudvalget 2020-21
KEF Alm.del Bilag 368
Offentligt

Danish response to the public consultation on the revision of the Energy Per-

formance of Buildings Directive

Center

Centre for Global Climate Ac-

tion

Team

EU Green Transition

Date

29 June 2021

Case No

2021 - 1707

/ NABBE

Danish key priorities for the revision of the Energy Performance of Buildings Directive



Buldings in the EU play an important role in achieving the EU energy effeciency target

of the EU’s final consumption by 2030. The Danish Government welcomes the revision

of the EPBD along with the Renovation Wave strategy, to ensure cost-effective energy

efficiency along with the decarbonisation of the existing building stock.

The direcive should support the phase out of fossil fuels for individual heating and

cooling of buildings.

General support for updating the framework for Energy Performance Certificates, in-

cluding a focus on the use of data and digitalization.

The Commission is encouraged

to ensure comprehensive alignment with the “Fit for

package”, especially regarding the ETS

and the inclusion of buildings.

When revising the EPBD, the Commission is encouraged to take into account the

national circumstances of the various member states in order to incentivize least-cost

paths for emission reductions and energy efficiency.



General remarks

The Commission strategy for a Renovation Wave for Europe will be an important

step towards the green transition and the EU target of climate neutrality by 2050.

The Danish Government therefore welcomes the revision of the Energy Perfor-

mance of Buildings Directive (EPBD) as part of the Renovation Wave strategy.

The Danish Government seeks an ambitious approach to the renovation of the

building stock and emphasises the need for a continued focus on a cost-effective-

ness approach in this regard. When proposing new measures the Commission is

encouraged to maintain a guiding principle on cost-optimality, as it will ensure

sound implementation in Member States and keep support from the building own-

ers.

Furthermore, the Commission is encouraged to ensure that cost-effectiveness

guides EU spending on the Renovation Wave to ensure that buildings most in need

of energy renovations are prioritised and in order to reduce greenhouse gas emis-

sions and deliver higher energy efficiency along with the decarbonisation of the ex-

isting building stock.

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KEF, Alm.del - 2020-21 - Bilag 368: Orientering vedr. regeringshøringssvar om revision af Bygningsdirektivet, fra klima-, energi- og forsyningsministeren

There is a particular challenge related to the poor energy performance of the EU

building stock, which should be addressed to achieve the ambitious EU climate tar-

gets. There is a huge potential for energy efficiency in the European building stock

through cost-effective improvements of the building shell, transition to electric and

efficient heat pumps as well as the promotion of district heating and energy efficient

equipment and smart buildings through smart lighting and advanced buildings en-

ergy management systems.

Consequently, the Commission is encouraged to ensure that the principle of energy

efficiency first will continuously be a key objective in the Fit for 55 package as well

as the revision of the EPBD. Here, the Danish Government encourages the Com-

mission to raise the present energy efficiency target at EU level to 40 pct. of the

EU’s final energy consumption by 2030.

In addition, the Commission should ensure

full alignment between the revised EPBD and other relevant legislation highlighted

in the Commission’s

2021 Work Programme.

Energy efficiency also provides huge employment opportunities in green sectors

and industries, which is a high priority for a green recovery and the Next-Genera-

tion EU package. Here, Denmark has important competences and expertise on

green technological solutions and products in the building sector.

The Danish Government fully supports efforts focused on exploring effective ways

to target public buildings. Denmark’s Climate Action Plan for energy and industry

introduces ambitious initiatives on energy efficiency in buildings both owned and

used by government institutions.

In addition, the Danish Government finds that a potential proposal on increasing the

rate of renovation should focus on developing a framework that provides a more

consistent and equal saving obligations across Member States. The Commission is

encouraged to consider specific national circumstances and enable flexibility for

Member States in the revision of the EPBD. In addition, the emission reduction and

energy efficiency potential should be main drivers of energy renovations.

Remarks on key elements

In accordance with the above, the Danish Government

supports the Commission’s

overall approach regarding the Renovation Wave with the following detailed re-

marks for the revision of the EPBD:

Phasing out fossil fuels in individual heating and cooling

The Danish Government seeks to phase out the use of fossil fuels for heating and

cooling purposes. Here, it is necessary to consider all available options to phase

out the fossil fuels for individual heating and cooling of buildings, as mentioned in

the Council conclusions on a renovation wave that repairs the economy now, and

creates green buildings for the future. This could be achieved through for example

common European rules or by introducing flexibility measures for Member States to

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KEF, Alm.del - 2020-21 - Bilag 368: Orientering vedr. regeringshøringssvar om revision af Bygningsdirektivet, fra klima-, energi- og forsyningsministeren

obtain more ambitious policies nationally. The general Fit for 55 package is going to

be crucial for the 2030 target of 55 pct. CO

e reductions to 2030. The revisions

must, as a result, enable member states to meet those targets. The Commission is

encouraged to work with the Member States to find solutions and available options,

which at a national level should provide Members States with the opportunity to

phase out fossil fuels in individual heating in compliance with EU regulation.

Sustainable buildings

The Danish Government welcomes the focus on sustainable buildings in a life cycle

performance perspective with an internal market for recycled materials. Here, de-

mands for management of non-recyclable waste from buildings should be intro-

duced to avoid harmful substances being recirculated back into the material flow. It

should be considered whether the EPBD is the right place to implement sustainable

buildings or whether this is better implemented under other relevant EU regulation.

Deep renovations

The Danish Government supports the introduction of a legal definition of deep reno-

vations to support the use of investment mechanisms. This definition could be cou-

pled with the EU taxonomy for sustainable activities and should be based on the

prerequisite of cost-effective renovations, which should also deliver on the quality

demands set by the building code. This will help achieve the highest potential for

energy savings. For example, this would entail that it would always be cost-effec-

tive to renovate while conducting the running maintenance of a building while also

gaining the highest potential, when energy renovations are of a high quality.

Financial incentives and market barriers

The Danish Government suggests that financial schemes for renovations with the

purpose of supporting CO

reductions are included under the requirements for pub-

lic financial schemes to be coupled with the achieved level of energy savings. Cur-

rently, only energy efficient renovations are subject to these requirements. This is

deemed inappropriate, since some projects, such as the conversion of gas supply

to district heating, do not achieve energy savings but do achieve CO

reductions

and are therefore not covered by the quality requirements under this scheme.

Recharging points for electric vehicles

The Danish Government suggest that the current requirements for recharging

points for electric vehicles may be adjusted based on the experiences from imple-

mentation. As an example, it could be considered if a lesser number of fast re-

charging points could replace a larger number of preparations of recharging point,

and thereby targeting the specific needs of the specific building, providing more

flexibility in the requirement. This could be for buildings such as grocery stores,

malls or hospitals.

Increased use of data and digitalization

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KEF, Alm.del - 2020-21 - Bilag 368: Orientering vedr. regeringshøringssvar om revision af Bygningsdirektivet, fra klima-, energi- og forsyningsministeren

There is a huge potential for increasing the use of digital tools in order to ensure

optimal operation of buildings and maintenance of building systems as well as inte-

gration of renewables in buildings. The Danish Government welcomes an increase

in the use of data and digitalization.

Smart Readiness Indicator

The Smart Readiness Indicator (SRI) is a useful scheme to describe the ability of

buildings to adapt the operation to the needs of users, describe the energy effi-

ciency of buildings, as well as the ability of buildings to provide flexibility for the

grid. The Danish Government welcomes the use of the SRI to promote the energy

efficiency of buildings but encourages the Commission to continue the current

framework of the SRI as a voluntary instrument or to, at least, await results and ex-

periences from the 2021 test run.

Update and extended use of Energy Performance Certificates

The Danish Government supports the update of the framework for Energy Perfor-

mance Certificates (EPCs) (energy labelling) to improve the quality of the instru-

ment. In this regard, focus should be on the use of data as a prerequisite for the

digitalization of the instrument.

The Danish Government sees a great potential for increased use of data in the

EPCs both to increase the quality of the labels and to contribute to more energy

renovations. This is why the updated framework should focus on the use of data-

bases, initially adapted to national implementation.

Furthermore, the Commission is encouraged to ensure a coherence between the

updated and the current framework to ensure that the potential of the EPCs are not

limited by the strengthening of the instrument across the EU. In addition, the Dan-

ish Government supports the use of a building renovation passport as a supple-

ment to the EPC, where Member States should be able to choose which measures

should be part of it as well as be able to adjust the layout to the national context.

In addition, specific measures of adjustment to the framework are presented below:

1) The requirement of compulsory EPCs should, in some instances, be able

to be removed when implementing certified energy management systems

2) Increase the number of buildings with EPCs by setting requirements for

EPCs in all advertising. Additionally, compulsory EPCs for public buildings

should not be limited to buildings “frequently visited by the public”.

3) In some instances, there should be a possibility to grant exemptions from

the compulsory EPCs to be able to conduct innovative experiments of

EPCs to improve benefits, widening possibilities and use of the instrument,

including data and digitalization efforts.

A strengthened EU Emissions Trading System - include the building sector

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KEF, Alm.del - 2020-21 - Bilag 368: Orientering vedr. regeringshøringssvar om revision af Bygningsdirektivet, fra klima-, energi- og forsyningsministeren

Finally, it is clear that CO

reductions need to come from the building sector where

there is still a large untapped potential across sectors and Member States. The

Commission is therefore encouraged to strengthen and extend the use of the EU

Emission Trading System (ETS) to include emissions from buildings. Extending the

scope of the ETS will support a cost-efficient approach by setting a price on carbon

emissions that will incentivize investments in renovation of both public and private

buildings in combination with strong sectoral legislation. Here, the inclusion of build-

ings under the ETS should be seen as complementary to the EPBD. The EPBD is

still a driver for reaching energy saving potentials in buildings.

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