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Document 52009AR0008
Opinion of the Committee of the Regions on the energy performance of buildings and the second strategic energy review
Opinion of the Committee of the Regions on the energy performance of buildings and the second strategic energy review
Opinion of the Committee of the Regions on the energy performance of buildings and the second strategic energy review
OJ C 200, 25.8.2009, p. 41–50
(BG, ES, CS, DA, DE, ET, EL, EN, FR, IT, LV, LT, HU, MT, NL, PL, PT, RO, SK, SL, FI, SV)
25.8.2009 |
EN |
Official Journal of the European Union |
C 200/41 |
Opinion of the Committee of the Regions on the energy performance of buildings and the second strategic energy review
(2009/C 200/09)
THE COMMITTEE OF THE REGIONS
— |
regrets that no proposal has been tabled to introduce a binding legislative instrument specifically designed to help attain the 20 % energy efficiency improvement objective; |
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stresses the potential of those methods which combine industrial activity with energy production (waste heat recovery, cooling, energy generation, co- and polygeneration, etc.); |
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highlights the importance of the work undertaken by the local and regional energy agencies across the EU. These institutions are strategic partners for Europe's energy policy and the EU should give greater support to and take greater account of their action; |
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stresses the importance of providing swifter access to the Structural Funds for energy efficiency investment in buildings; |
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supports the European Commission's initiative which would allow the permanent application of reduced VAT rates in the housing sector, including in the case of renovation work; |
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supports the European Commission's efforts, in partnership with the EIB and EBRD, to develop financial instruments geared towards improving energy efficiency. It notes that one of the most important issues when creating such financial instruments is to make them accessible to local and regional authorities with a view to supporting them in their role as key actors in the implementation of the Directive on the Energy Performance of Buildings. |
Rapporteur |
: |
Mr Jean-Louis Joseph (FR/PES), Mayor of Bastidonne |
Reference document
Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions — Second Strategic Energy Review. An EU Energy Security and Solidarity Action Plan — COM(2008) 781 final
Recasting of Directive 2002/91/EC of 16 December 2002 on the Energy Performance of Buildings
COM(2008) 780 final — 2008/0223 (COD)
I. POLICY RECOMMENDATIONS
THE COMMITTEE OF THE REGIONS
A. Second Strategic Energy Review of the European Union
1. |
believes that the challenges addressed by the European Union's energy policy are of fundamental importance both for the present and the future of the EU and its citizens, and for climate issues at global level. It draws attention to the key role played by local and regional stakeholders as partners in the successful definition, formulation and implementation of European energy policy. Accordingly, it regrets that the role of local and regional stakeholders has been given only cursory consideration by the second strategic review; |
2. |
recognises the importance of the security of supply, a key focus of the Second Strategic Review and of extreme political sensitivity. It further recognises that the situation of each Member State is different in this respect. These differences, due in part to historical reasons, call for coordinated action at European level to redress imbalances, forge closer links between partners and to limit the risks for the European Union as a whole; |
3. |
acknowledges the important progress made after the first strategic review, particularly the formulation of the 20-20-20 objectives and the initial legislative developments, culminating in the recent agreement between the Parliament and the Council on the ‘Energy and Climate Package’; |
4. |
considers that these developments, while highly important, represent only a first step. It is therefore vital that the 20-20-20 objectives continue to be the main priority of the EU's energy policy, thereby ensuring the coherence and continuity required for its successful implementation; |
5. |
emphasises the need to identify energy efficiency as one of the principal focal points of the EU's energy policy. It draws attention to the trias energetica (energy triad) model, which sets out, in ascending order of importance, the three policies capable of limiting the impact of energy use on climate change: energy efficiency, the promotion of renewable energy and optimising fossil fuel use. Energy efficiency is not only the cornerstone of the 20-20-20 objectives but also plays a vital role in terms of security of supply. However, it is regrettable that energy efficiency remains the only 20-20-20 objective which has yet to be translated into a binding legislative instrument; |
6. |
Against this background, it warmly welcomes the energy efficiency measures put forward by the European Commission in the second strategic energy review (particularly the revision of the Directive on the Energy Performance of Buildings — see below), but regrets that:
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7. |
stresses the crucial role played by local and regional authorities in the field of energy efficiency. In this context:
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8. |
as regards the six priority projects identified as essential for the European Union, it notes, without commenting on the substance of the proposed projects, that:
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9. |
still on the question of investment, it emphasises that the transformation of the European energy system into a more decentralised system will require significant investment, dialogue with local and regional stakeholders, and increased recognition of their role in the field of energy policy; |
10. |
Regarding the chapter on indigenous energy reserves, it emphasises that:
|
11. |
welcomes the intention to table a Communication on Financing Low Carbon Technologies. Given that this communication will take into account the revenue generated as a result of the revision of the Emissions Trading Directive, the CoR draws attention to its opinion on this matter, which ‘recommends that at least 30 % of revenues generated from the auctioning of allowances should be earmarked by Member States for local and regional authorities in order to promote the use of renewable energies and energy efficiency in end uses (3).’ |
Furthermore, it also stresses that if we are to make the most effective use possible of the budgetary resources available, carbon capture and storage technologies, which are still very much at the developmental stage and are in themselves incapable of solving the problems of energy production or the security of supply, should not receive more funding than other technologies specialising in energy efficiency or renewable energy;
12. |
welcomes the proposal to chart a policy agenda for 2030 and a vision for 2050. Real strategic orientations, investment decisions and infrastructure projects can only feasibly be contemplated over the longterm. The Committee expresses its surprise that the issue of decarbonising the EU electricity supply by 2050 appears to have been given priority over the other areas outlined in the 2050 vision, as suggested by the recommendation to tackle this issue as soon as the strategic plan for energy technologies has been established. While this topic is undoubtedly of importance and has much potential, there are numerous other issues which are equally, if not more, urgent. The process of defining a vision for 2050 should take the form of a broad strategy, and not concentrate on a restricted number of thematic priorities. |
B. Recast of the Directive on the Energy Performance of Buildings
I. Policy recommendations
13. |
welcomes the recast of the Directive on the Energy Performance of Buildings; |
14. |
stresses the urgent need for large-scale action to improve the energy performance of buildings given the related benefits
|
15. |
highlights the urgency of these issues, and calls on the Council and the Parliament to ensure that swift and ambitious decisions are taken on this matter; it also calls on the Member States to avoid any repeat of the implementation delays which occurred with the first version of this directive; |
16. |
in order to facilitate the implementation of energy declarations, the Commission should introduce a programme for the exchange between Member States and their local and regional authorities, of best practice and information on the use of technical solutions and the use of public contracts to promote the development of energy efficiency; |
17. |
recalls the key role played by local and regional authorities in implementing this directive, through:
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Local and regional authorities across Europe have undertaken numerous voluntary initiatives addressing the energy performance of buildings, including action aimed at cutting down on energy use in public buildings and housing and as part of the regeneration of urban areas. Member States need to fully incorporate local and regional authorities and stakeholders as strategic partners in the implementation of this directive, seek to benefit from their experience and ensure the promotion and replication of best practice. The Committee therefore calls for Local and Regional Authorities to be involved in the drawing up of National Action Plans;
18. |
believes that the proposed recast strengthens the Directive in a number of respects. It particularly welcomes:
|
19. |
wishes to highlight the importance of developing the Directive on the basis of the experience gained of its practical implementation, which should be duly analysed and assessed. The importance of energy performance certificates and the way they are drawn up should be evaluated, among other things. A flexible approach could help resolve the problems posed by a lack of skills, in cases where this has been an issue; |
20. |
considers that the proposed ‘comparative methodology for calculating cost-optimal levels of minimum energy performance requirements’ could represent an effective benchmarking instrument at European level. However, it calls on the Commission to take account of all external factors when drawing up such methodology, especially the costs of inaction (environmental degradation, deteriorating health and competitiveness, all prompted by underinvestment in the area of energy efficiency) as well as the positive impact of investments in energy efficiency (in terms of job and wealth creation, support for research, energy autonomy, quality and sustainability of buildings, etc.); |
21. |
It is also important to make use of the possibility to improve the energy efficiency of buildings without investment, for example by optimising functioning and user participation. Many local and regional authorities are already working successfully in this area; |
22. |
stresses the need to keep the public fully informed about the parameters used to calculate the cost-effectiveness of the recommendations provided on the energy performance certificate in order to enable a clear understanding of the calculation and to make it possible for the public to re-evaluate the cost-effectiveness of energy efficiency measures, based on new factors (changes in energy prices, subsidies granted by public authorities, useful life of equipment etc.); |
23. |
emphasises the usefulness of the reports which the Member States have been asked to prepare (inter alia in Article 5 (2) and Article 9 (3)). To ensure the accuracy of these reports, the directive should require local and regional authorities to take part in their preparation; |
24. |
draws attention to its opinion on the Promotion of Renewable Energy (4) and welcomes the introduction of an element of coordination between this directive and other important items of European legislation in this area, in particular the Directive on Energy End-Use Efficiency and Energy Services (2006/32/EC) as well as with regard to the existing and future EU Green Public Procurement proposals. This coordination strengthens the coherence of the legislation as a whole and reduces the burden on the Member States by grouping together the various reports which they need to prepare; |
25. |
welcomes the objective to increase the number of ‘buildings of which both carbon dioxide emissions and primary energy consumption are low or equal to zero’, and the need for the public sector to lead by example in this area; |
26. |
notes that the directive's guiding principle is to save energy to minimise the impact on the environment. Establishing a definition for ‘Buildings of which both carbon dioxide emissions and primary energy consumption are low or equal to zero’ cannot therefore lead to buildings with low carbon dioxide emissions being favoured over those with low energy consumption. What is more, a global vision of environmental impact must always take precedence over the criterion of carbon dioxide emissions alone; |
27. |
also emphasises the benefits and challenges arising from the introduction of a requirement to monitor quality in connection with energy performance certificates and inspection reports. This measure will be vital if there is to be any significant improvement in the quality of buildings in Europe; |
28. |
emphasises that the question of when work is carried out will have an important bearing on the global impact of the directive. Accordingly, it:
|
29. |
emphasises that implementing the directive will require substantial efforts in the training field. With this in mind, it proposes introducing a provision establishing:
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30. |
on the issue of vocational training, it stresses the success of a number of initiatives at local and regional level that have focused on the construction process by establishing discussion groups bringing together the various trades involved (plumbers, bricklayers, electricians, etc.) and discussing the interaction between their various roles in the process of constructing a building. Such schemes have had a positive impact on the quality of the construction process in general and, as a result, on the quality of the buildings themselves. In those groups, where energy efficiency was identified as a key objective, effective and innovative solutions were developed thanks to the interaction between the various trades. |
31. |
emphasises the need to properly assess the actual upfront costs that this Directive would entail in order to provide adequate financial incentives to support and speed up the implementation of the directive. Accordingly, it
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II. PROPOSED AMENDMENTS
Amendment 1
Article 5 (1)
Text proposed by the Commission |
CoR amendment |
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Reason
Technical amendment to correct an obvious mistake (concerns an internal reference).
Amendment 2
Article 5 (2)
Text proposed by the Commission |
CoR amendment |
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Reason
In order to ensure the accuracy of the reports which the Member States are asked to prepare under the current directive, it is important that they are drawn up in close cooperation with local and regional authorities and stakeholders.
Amendment 3
Article 9 (3)
Text proposed by the Commission |
CoR amendment |
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|
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Reason
In order to ensure the accuracy of the reports which the Member States are asked to prepare under the current directive, it is important that they are drawn up in close cooperation with local and regional authorities and stakeholders.
Amendment 4
Article 10 (3)
Text proposed by the Commission |
CoR amendment |
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Reason
The energy performance certificate should provide the public with clear and easy to understand recommendations making it possible to compare the cost-effectiveness evaluation, as calculated when drawing up the energy performance certificate, with the actual conditions encountered, taking into account the changes in the overall situation (fluctuations in energy price, interest rates, equipment costs, etc.) and/or other new factors (subsidies granted by public authorities, programme utilisation period etc.).
Amendment 5
Article 12 (2)
Text proposed by the Commission |
CoR amendment |
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Reason
Displaying energy performance certificates in buildings which are frequently visited by the public can play an important role in raising public awareness of the importance of issues related to the energy efficiency of buildings.
Amendment 6
Article 15 (2b)
Text proposed by the Commission |
CoR amendment |
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Reason
The energy performance certificate should provide the public with clear and easy to understand recommendations making it possible to compare the cost-effectiveness evaluation, as calculated when drawing up the energy performance certificate, with the actual conditions encountered, taking into account the changes in the overall situation (fluctuations in energy price, interest rates, equipment costs, etc.) and/or other new factors (subsidies granted by public authorities, programme utilisation period etc.).
Amendment 7
New Article 17 (a)
Text proposed by the Commission |
CoR amendment |
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Reason
The successful implementation of the directive will require significant efforts in the area of training, which should be defined and made compulsory under the Directive, including establishing reporting objectives and obligations.
Amendment 8
Article 19
Text proposed by the Commission |
CoR amendment |
Member States shall take the necessary measures to inform the owners or tenants of buildings or parts thereof as to the different methods and practices that serve to enhance energy performance. Member States shall in particular provide information to the owners or tenants of buildings on energy performance certificates and inspection reports, their purpose and objectives, on cost-effective ways to improve the energy performance of the building and on mid- and long-term financial consequences if no action is taken to improve the energy performance of the building. |
Member States shall take the necessary measures to inform the owners or tenants of buildings or parts thereof as to the different methods and practices that serve to enhance energy performance. Member States shall in particular provide information to the owners or tenants of buildings on energy performance certificates and inspection reports, their purpose and objectives, on cost-effective ways to improve the energy performance of the building and on mid- and long-term financial consequences if no action is taken to improve the energy performance of the building. Member states shall be required to engage and consult with local authorities at an early stage to develop information and awareness raising programmes. |
Reason
The provisions of the recast impact local authorities in many ways given their responsibilities for planning, and as owners and managers of a broad and diverse range of property including social housing stock. Local government’s proximity to the citizen also gives it a key role in providing information and incentives to encourage tenants and owners to improve the energy performance of their building, and to change their energy consumption behaviour. Local authorities also have a wealth of experience and expertise.
Brussels, 21 April 2009
The President of the Committee of the Regions
Luc VAN DEN BRANDE
(1) CdR 241/2008 fin.
(2) CdR 160/2008 fin.
(3) CdR 161/2008 fin.
(4) CdR 160/2008.
(5) COM (2008) 838/3 final.
(6) COM (2008) 428 final.