In its answer to the Commission’s public consultation on EPBD, EFIEES emphasised the necessary coherence that should exist between the Energy Efficiency Directive and the EPBD. Indeed, both directives have the same goal, namely to establish the conditions and rules leading to improved energy efficiency in the economy, for the first Directive, and more specifically in the buildings, for the second one. It is also at the level of neighborhoods and even cities that action must be taken. To improve consistency, readability and impact of these directives one can even put to question the need to maintain two separate texts, rather than one.

In any event, the measures dedicated to buildings are and must remain the key elements of the future EU Strategy for Heating and Cooling, provided further strengthening their impact. Our response to the questionnaire of the public consultation on the EPBD was constructed in order to contribute to the real improvement of energy efficiency (not theoretical one).

Our contribution to the public consultation on the EPBD may be summarised in six points:

  1. Energy Efficiency First
  2. It’s a market
  3. “Real not Theoritical” – closing the gap between designed and actual energy performance of buildings
  4. Nothing but renovation
  5. A vision at district scale
  6. No discrimination
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