The European Commission (EC) is currently evaluating the Energy Performance of Buildings Directive through a consultation with all member states. Currently, about 35% of Europe’s buildings are over 50 years old. Buildings are responsible for 40% of energy usage and 36% of CO2 emissions in Europe.

When introduced, the Energy Performance of Buildings Directive (EPBD) aimed to:

  • improve the energy performance of buildings in the EU;
  • require Member States to set energy performance standards for buildings;
  • require Member States to issue buildings with energy performance certificates; and
  • require Member States to ensure that, by the end of 2020, all new builds are ‘nearly zero energy’ buildings.

It set out tangible ways of achieving energy savings in buildings and reducing the large differences in results that exist in energy saving outcomes between Member States. The recent consultation sought feedback from stakeholders on the effectiveness of the directive to evaluate whether the directive has met its aims.

Whilst the Directive has the potential to achieve its goals, UK legislation is currently driving forward a requirement to measure and report with no obligation to change behaviour or energy use. Whilst the burden of measuring, reporting and paying for energy costs is increasing there is no requirement to demonstrate actual energy reduction.

The current regime of certification includes the requirement for tailor-made recommendations for the improvement of the energy performance of buildings. The concern with this is that, as long as these remain recommendations and not requirements, it is unlikely that investment will ever be made to achieve these on a wide scale.

The use of the Energy Performance Certificate (EPC) as a platform on which to drive change is fundamentally flawed. EPCs only measure the fabric of the building, not the actual performance, and provide no reward to those that actively drive efficient use of the building regardless its capability. Where the UK Government has adopted the requirement for Display Energy Certificates (DEC) in some buildings, actual usage data is the focus of performance measurement and therefore there is the potential for energy use to be affected. The disappointing news is that a recent consultation by the UK Government gave consideration to scrapping DECs altogether as they were seen to be ‘gold plating’ the EC Directive. The result of adopting such a policy would be a backward step.  We run the risk of having energy efficient capability in building stock having not addressed behavioural change and therefore not reduced energy usage.

As the requirement for EPCs at an ‘E’ rating or above for private rented properties is fast approaching, without renovation or capital investment, many buildings will become unleasable which will be hugely damaging to asset value and therefore should drive change. This however only affects privately rented space and therefore building owner/occupiers have yet to see any negative affect of a poorly performing or badly maintained building.

The directive also outlines the requirement of regular inspections of heating and air conditioning systems however as enforcement rests with Local Authorities in the UK where compliance is seldom monitored, it is frequently that case that air-conditioning inspections are not carried out at all.

With regard to the standards for new buildings, the current practice in the UK with regard to energy performance is not effective. Many local authorities are not ensuring that an EPC has been issued before signing off the property through building control. A number of schools, offices and even hospitals have not had an EPC issued despite being operational. Simple steps can be taken to ensure that there is a link between planning applications and the issuing of the first EPC to ensure this is completed prior to the property being released for occupancy.

The aim of the directive was to introduce minimum energy efficiency standards across Europe however different Governments have varying priorities and commitments to the energy efficiency agenda. This concern is not just associated to different countries but, as Governments change within member states, priorities change and therefore a consistent approach will always be difficult to achieve. There will always be those that are committed to reducing emissions and those that will implement the minimum changes required to simply comply with the requirements.

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