There have been responses to the EiD discussion paper published last week, most of them directly by email. The number of downloads of the report and the responses to the related tweets were most encouraging. There is a great concern about implementation and many mention the number of infringement procedures underway that indicate the level of commitment at the member state level. Some call for a new recast of the Energy Performance of Buildings Directive (EPBD) sooner than later. Interestingly, last week I moderated a Commission/JRC workshop on split incentives for Article 19 of the EED and the energy performance certificate of the EPBD came up. I was shocked by how many of the participants were so negative about the energy performance certificate. The last recast was to have solved a lot of issues. Well, it obviously didn’t. One speaker was concerned about the lack of impact of the energy performance label in Denmark yet Denmark had the first label back in the 1980s and have revised it several times. They still haven’t got it right.
There is a lot of good underway. For one, I’m impressed how the Buildings Performance Institute Europe is working with member states on nearly zero energy buildings and on long-term renovation strategies. And to BPIE we can add Concerted Action and BUILD UP to start with. Intelligent Energy Europe has supported some good projects related to implementation.
All I’m calling for is greater attention to monitoring the progress of implementation to avoid slippage and to ensure good impact. This means working with the Commission to make sure it stays focused. This means working more closely with national and regional governments. This means ensuring that there is better compliance.
Some of you mentioned that there are too many loopholes in the current recast of the buildings directive, leaving too much interpretation to member states. We certainly see that in the definition of nearly zero energy buildings. Yet, nearly zero energy buildings is so complex that I feel giving some flexibility for innovation is not a bad idea as long as member states treat it seriously and ambitiously.
I am reminded of a section in the book, The Blunders of our Governments, by Anthony King and Ivor Crewe, on “operational disconnect.” There is an excellent quote: “No feature of the blunders we have studied stands out more prominently – or more frequently – than the divorce between policy making and implementation and in human terms, between those who made policies and those charged with implementing them.” Compound that with the directives approved at the EU level and yet implemented at the national or regional levels and you see the problems. I’m reminded of my first Director at the International Energy Agency, when I mentioned that the energy efficiency committee needed to put some emphasis on implementation. He said: “We do POLICY, we do not do implementation.” I rest my case.
All stakeholders have a vested interest in ensuring the greatest impact and that will only happen through effective implementation. All of us must take this very seriously.
My discussion paper can be downloaded here.

Hi Rod,
I had the chance to take be asked as a consultant in developing some part of the implementing policy and – to say it mildly – the overall picture is at least inconsistent. For certain administrative and office buildings there are some requirements, for schools and hospitals totally diferent ones, and some of these requirements do not respect the minimum requirements of the existing laws in the construction field.
The existing buildings energy certificate system cannot be used in the policy as a prerequisite as there is no confidence of its accuracy.
On the other hand respecting the 1.5% energy cut won’t lead to investments in the first round, but only to a cut in comfort, which at least in our country is already poor enough (especially in schools and hospitals).
So without a coherent implementation that would need to update and corelate several laws and regulations – there is little to no hope that the incentives will produce the results expected.
Hi Iza
Thanks for these words. Well, we have our work cut out to ensure there is hope.
Regards
Rod