Extract from the EHH, ELO, EPF, TEGOVA representations:


The Directive creates an obligation on owners of the worst-performing building stock to renovate their homes, workshops and shops, whether they were intending to or not, whether they could afford to or not, and whether they were able to secure financing or not, and if they don’t, their governments will be under EU legal obligation to apply “effective, proportionate and dissuasive penalties”.

This underscores the Proposal’s gravest flaw: the extraordinary inadequacy of its financial incentives provisions, stuck at the level of ambition of the existing Directive. The Proposal retains the ‘old EU’ approach of simply legislating without providing for the EU financial support essential to palliating the most socially damaging impacts of the legislation.

If Commission, Council and Parliament truly aim to legislate a step-change to building and renovation not seen since the reconstruction following World War II – which they must, and which we support – then the public support has to be at a level that has some relation to the scale of the challenge, and a significant proportion of it must be European.

On top of government grants for the most vulnerable, the text of the EPBD must lay down an obligation on the Commission to see to the following:

  1. There has to be an EU solution guaranteeing access for all EPC ‘G’ and ‘F’ level EU homeowners and microenterprises to affordable long-term funding for deep home and microenterprise renovations. The EU political and financial authorities must find a way of working with retail banks to offer millions of unified EU Renovation Loans backed with public guarantees and linked to the buildings’ value. (see suggested amendment to Art. 15(1)(a), p.3)
  1. Existing Structural Funding will have to be given – quickly – a much greater renovation focus at the expense of expenditure that is far less essential for European climate policy and energy sovereignty. (see suggested amendment to Art. 15(1)(b), p.3)

Full text of representations and specific suggestions for amendments under epf22-38 of 04.07.2022