EHH, ELO, EPF, TEGOVA TO ENERGY COMMISSIONER KADRI SIMSON

In January, in the run-up to revision later this year of all EU energy legislation targeting buildings so as to adapt it to higher EU GHG emission reduction targets, European Historic Houses, European Landowners' Organization, EPF and The European Group of Valuers' Associations wrote to the Energy Commissioner and the President of the Council of Energy Ministers that:

  1. The EU 2030 target of at least 55% GHG emissions reduction by 2030 will never be met without at least doubling the rate of renovation.
  2. The rate of renovation will never double without EU regulation.
  3. Regulation means

(1) Phasing out of fossil fuels

(2) An EU framework for the renovation of the worst- performing building stock

And that such a framework won't work without:

(a) Cut-off dates for sale or rental of unrenovated buildings

(b) Higher renovation requirements for all public buildings and not just for those owned and occupied by central government as is the case now

The Coalition warned against Commission overemphasis on 'deep renovation', supposedly so as to avoid carbon 'lock-in', until the next renovation. They found this reasoning simplistic, static and Malthusian, and stressed that new technical solutions are appearing at great speed and the prices of old ones are dropping quickly.

They insisted that the absolute priority should be to reduce carbon emissions substantially by 2030 so as to head off climate impacts that will be caused by our current behavior no matter how much emissions are reduced after 2030. In the building sector, that means renovation at scale, even if it is not all 'deep' or 'near-zero'. Furthermore, renovation at scale will have the side-effect of increasing the rate of 'deep' renovation anyway.

The letter