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Dear Deputy Permanent Representative,
The current review of the Energy Performance of Buildings Directive (EPBD) offers a unique opportunity to strengthen the impact of Technical Buildings Systems (TBS), as a way to drive the much needed improvements in the existing and future building stock and promote systems and solutions that result in low energy consumption, high Indoor Air Quality (IAQ), increased safety and consumer empowerment while significantly reducing energy costs for building owners and occupants.
Today, despite their obvious benefits, basic building automation and control functionalities of heating, cooling, ventilation systems, lighting and blind integration as well as regular service and maintenance are often missing or being neglected.
In view of the next trilogue meeting, our associations – active in the heating, cooling, refrigeration, air- conditioning, and ventilation industries – jointly renew their call for an ambitious EPBD and a strengthened focus on TBS for the sake of citizens’ health, comfort and productivity. We specifically urge EU Member States to align their position to the forward looking report adopted by the European Parliament:
- We support mandatory inspections requirements for large buildings and building automation and Controls requirements for large non-residential buildings for heating, air-conditioning and ventilation systems (Articles 14 and 15);
- We caution that programmes for stand-alone “adequate advice” cannot replace inspections and will generally not lead to any improvement and maintenance of the heating, ventilation and cooling systems;
- We support the introduction of a smartness indicator, as a useful tool to assess the technological readiness of the building to control its own energy consumption, indoor air quality, and comfort levels, and to interact with the grid to balance energy demand;
- We support a more efficient and effective framework for Technical Building Systems, which refers to both energy efficiency and indoor air quality (under actual usage conditions); and
- We support the application of harmonized energy performance calculation methods in all EU Member States (Annex I).
We trust that you will be able to take our considerations into account, and we are at your disposal to discuss the subject further.
Thomas Nowak, Secretary General, EHPA
Andrea Voigt, Director General, EPEE
Simone Alessandri, Director Governmental Relations, Eu.bac Lasse Alsterberg, Chairman, EUHA
Felix Van Eyken, Secretary General, Eurovent
Russell Patten, Secretary General, EVIA
Anita Derjanecz, Managing Director, RHEVA