ACE welcomes the strengthened vision advanced by the Parliament for the building stock by 2050: setting the ambition to transform “the national stock of residential and commercial buildings, both public and private, into a highly energy efficient and decarbonised building stock by 2050” is a prerequisite to boost investment and accelerate the transition to a more efficient, more comfortable and healthier building stock.
ACE welcomes also the call on the Commission to assess the feasibility of the introduction of a Building Renovation Passport – a roadmap, based on quality criteria that would outline relevant measures to improve the energy performance of a building.
ACE is also pleased to see a greater recognition of health, safety and air quality aspects and the emphasis put on the worst performing segments of the building stock. It also supports the proposed changes regarding the deployment of dedicated infrastructures for electro-mobility.
ACE is however concerned about the possible exemption from inspection of heating and air-conditioning systems (article 14 and 15). ACE points out that automation of these systems actually increases the risks of performance shortfalls. Regular maintenance, or at least remote inspection, of such systems is essential to ensure their proper functioning.
ACE also regrets that the ITRE committee does not require from Member States to track the actual energy consumption in the EPCs databases (article 10). ACE campaigns for the aggregation of such data for all non-residential buildings and their disclosure for statistical and research purposes.
While ACE welcomes the addition of a new annex regarding the 'smartness indicator', it recalls that smart devices and automation carry a significant risk of underperformance and added cost, and should therefore not be seen as a panacea for improving building performance. ACE advocates that the language of the EPBD should give priority to the architectural means of improving long term building performance, including better prioritisation of passive, low-tech, locally tested solutions that do not consume energy in operation and carry a lower risk of under-performance.