Orgalime contribution to the public consultation on Sustainable Buildings
Published: 1 October 2013
Policies & Issues: Energy & Climate
Orgalime supports the development and construction of sustainable buildings. In particular, our industry has been actively supporting the EU´s activities on improving energy efficiency of buildings considering the sheer energy savings potentials of this sector and its relevance for putting the EU´s energy and climate change targets into practice.
We thank the Commission for giving to stakeholders the opportunity to comment on the EU´s policy on sustainable buildings. However, we are somewhat concerned about its focus and pursued objective:
The aspect of energy efficiency of buildings, which we consider of overriding importance, is excluded from this consultation. This may be for the good reason that this aspect has already been regulated in the Energy Efficiency of Buildings and Energy Efficiency Directives (EPBD and EED). However, when analysing improvement potentials and discussing policy options for further improving the environmental performance of buildings and their overall sustainability, we feel that the aspect of energy efficiency cannot be left aside. Any policy action potentially following up this consultation therefore requires a careful assessment in terms of costs and benefits and to not hinder or disturb the ongoing implementation of energy efficiency.
Uncertainties also result from the use of the term 'building component' in the consultation document, which appears a vague concept to us. Indeed, the term 'building components' is not used in existing legislation related to buildings, such as the Energy Performance of Building Directive (2010/31/EU) or the Construction Product Regulation (305/2011/EU). The consultation document does not clarify what this term should include for the purpose of this consultation.
Our industries cover a wide range of products, technical installations and systems installed in buildings, such as heating, ventilation and air-conditioning systems, or (hot) water and lighting systems. In case the Commission understood 'building components' to include such equipment, we ask the Commission to take the following comments into account [read the position]