FEANTSA's position on the Energy Performance of Buildings Directive recast

For a socially ambitious EPBD recast: Dedicated funding, monitoring and regulation to target unfit housing of energy-poor households

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The EPBD recast is a praiseworthy intent but lacks adequate tools to deliver for the needs of the most vulnerable. A core element of the energy transition is to achieve a massive improvement in the energy efficiency of buildings, reflected in current EU policy such as the revision of the EPBD. This revision also has the potential to bring significant social, health, and economic benefits to lower-income and vulnerable households, through improved housing conditions. These multiple benefits and ‘win-win-win’ outcomes, cannot, however, always be assumed. The risk of unintended negative consequences has been raised by some early experiences of renovation programmes, such as increased overall housing costs. The European Commission proposal for a revised EPBD directive claims its focus on the worst-performing buildings will help fight energy poverty. It sets EU-level minimum energy performance standards that require worst-performing residential buildings of each Member State to be upgraded from an Energy Performance Certificate's Grade G to at least Grade F by 2030, and to Grade E by 2033. The focus on the very lowest-performing building is framed as an effort to renovate buildings with the highest potential for decarbonisation, as well as to address energy poverty and increased social impact.

FEANTSA believes that prioritizing renovation for households that face energy poverty and poor housing conditions is the cornerstone of a just transition. FEANTSA argues the text as it currently stands, in association with other related EU initiatives such as the extension of the ETS to building and transport, and the Social Climate fund is far from being sufficient to address the housing deprivation and energy poverty and could contribute to the rise in living costs, particularly housing costs. This could lead to a deepening and broadening of housing exclusion. The introduction of mandatory energy performance standards, as they currently stand, might well be counterproductive and fail to bring the social acceptability needed for the policy changes needed to reach the EU’s climate target.

FEANTSA welcomes a strong call for Member States to address energy poverty through the implementation of mandatory energy performance standards but highlights a dramatic lack of financial support. FEANTSA welcomes the recognition of energy poverty and the requirement for the Member States to roll out enabling and financing tools and monitor social impact and welcomes the right analysis of a potential impact of renovation on rent levels, and the consequent call to Member States to address it. However, FEANTSA claims that the EPBD reform lacks dedicated financial instruments.

In this position paper, FEANTSA presents recommendations for a more realistic and just EPBD revision. FEANTSA proposes a set of measures to enable the EPBD revision to rethink its funding and target more energy-poor households, and support ambitious national policies that can prevent the minimum energy performance from contributing to further rent increases.