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Making EPBD work for blocks of flats

The European Energy Performance of Buildings Directive (EPBD) is currently up for review, with a deadline for responses to the official consultation at the end of the week.

The EPBD led to the introduction of Energy Performance Certificates across Europe. It also helps ensure that countries introduce ambitious building regulations that promote energy efficiency.

But at Future Climate we don’t think EPBD is doing enough to promote energy efficiency in flats. It simply doesn’t take into account  that many buildings have multiple owners and occupiers – and getting them to work together on energy refurbishment is a challenge that national law makers need to tackle.

Here’s our ideas that we’re finalising – we’d be keen to know your views:

  • In very broad summary, the current EPBD (recast in 2010) promotes action on energy efficiency retrofit through building regulations when a building or building unit goes through a major renovation or at construction. The EPBD also requires the provision of information on energy efficiency measures, particularly at the point of sale or rental of a building or building unit
  • We believe the EPBD does not pay sufficient attention to consents barriers in energy efficient retrofit. Building ownership and tenure arrangements are increasingly complex. The directive talks in simplistic terms about building owners and tenants; it does not address how multiple different parties with a title to the whole or part of a building – all of whom can facilitate or prevent energy upgrades – can be persuaded to work together to carry out renovations.
  • We focus particularly on private buildings in residential multi-occupancy. We are concerned about these properties because evidence that Future Climate has collated shows that energy renovation of apartment blocks in England is much less common than of houses. National housing data shows that one type of apartment block – houses converted in apartments – are by far the coldest and least energy efficient homes in England.
  • EPBD does not effectively promote or allow consideration of the comparative costs and benefits of taking action on the whole building as opposed to taking action on the individual building unit. Comparative information is very important and useful particularly for owners of private apartments who (depending on different MS property law) may have the opportunity to collaborate to make energy efficiency upgrades at the building level rather than just in their individual units.
  • We would also suggest that EPBD could be strengthened to encourage MS to make it easier for apartment owners to collaborate on energy efficiency and to provide information and financing for them to do so. We  do not believe the current requirements (for example in Article 20) have been effective in this regard. We note some requirements in the Directive to provide information on block/district heating but point out that insulation or window upgrades are also often much more cost-effectively undertaken as building level action.
  • Though data is limited, multi-occupancy buildings  that have a single owner may be sold more rarely than other types of building*. We believe owners and residents of multi-occupancy buildings would benefit much more from EPBD if building owners were required to undertake an EPC-type assessment on a regular basis (ie not just at the point of sale or rental).
  • Finally, as an absolute minimum we believe it is essential that EPBD should specify some minimum information that all EPCs for building units should contain about the building within which they are located. In England and Wales EPCs for apartments do not even contain the basic address information to allow easy identification of the block where they are based –this is a major barrier for example to Local Authorities who wish to use EPC data to promote energy efficiency programmes.

*In England and Wales this problem is particularly acute due to freehold/leasehold arrangements: freeholders own the ultimate title to the building and can limit what energy improvements are made – but they often have a limited financial interest in the building despite maintaining their interest over many decades or even centuries.