FEDARENE Position Paper – Energy Efficiency and Energy Performance of Buildings Directives Revisions

This position paper is based on consultation with the members of FEDARENE and is in response to the proposals of revision of the Energy Efficiency and Energy Performance of Buildings Directives, presented by the European Commission on November 30th 2016.


  • To raise the energy saving target proposed in the Energy Efficiency Directive to 40% by 2030;
  • To specifically require that efficiency be considered before supply, and that this principle is consistently applied;
  • To provide a clearer statement of the process to ensure that national contributions add up to the EU total targets, and that these national contributions are binding on Member States;
  • To embed multi-level governance throughout the Clean Energy for all Europeansproposals;
  • To provide a more detailed requirement to enable and facilitate the participation of citizens, industry and civil society in the development and delivery of National Climate and Energy Plans, clarifying that participation is more than just consultation;
  • To amend Article 7 to ensure additionality, for example as regards new buildings, the replacement of measures that reach the end of their useful life, and the leverage of other
    sources of finance;
  • To include a specific and quantifiable requirement to address energy poverty, relative to the proportion of customers considered to be at risk, within Article 7;
  • To require monitoring of the real impact of measures undertaken under Article 7, and publication of the results;
  • To move the requirement for energy renovation of public buildings from EED Article 5 to the EPBD, and extend it to cover all public buildings, together with clear plans for supporting
    finance and within the limitations provided for under Article 4 regarding historic buildings etc.;
  • That the ‘decarbonisation of the building stock’ be defined, and that clear targets be set out in national renovation strategies, not only for 2030, 2040 and 2050, but also for interim phases;
  • That the definition of decarbonisation of the building stock includes a specific requirement to avoid the reintroduction of fossil-fuel based heating systems post major renovation, unless all other alternatives can be shown to be technically inadequate, together with clear plans for supporting finance where there is significant additional cost – and similarly that no new
    buildings should contain fossil-fuel-based heating systems;
  • To strengthen the EPBD and the requirement for long term national building renovationstrategies by requiring Member States to:
  • Support and ensure the establishment of regional or local funding programmes for building (energy) renovation;
  • Require the inclusion of energy efficiency improvements and renewable technologies in all repair and renovation work, where technically and economically feasible;
  • Ensure that energy efficiency and renewable energy knowledge and skills are integrated into the standard (mainstream) training for all building trades and professionals.
  • To set out (for example in Article 20 of the Energy Performance of Buildings Directive), a clear requirement for effective energy advice (and not just information) to support building owners throughout the process of deep renovation.