Interview with Jana Bendžalová (ENBEE, Slovakia)
In the context of the last C4E Forum, we interviewed various of the speakers at the event on the three main areas of focus that we had in this past edition: energy security, the rebuilding of Ukraine and EU policy (REPowerEU and Fit-for-55 package).
To take at look at the current state of EU Policy, we conducted a written interview focusing on the main file concerning energy efficiency in buildings, the Energy Performance of Buildings Directive EPBD, with Jana Bendžalová.
Jana Bendžalová is the Executive Manager at ENBEE (Environment & Building Energy Efficiency), a Slovak private consulting company that brings together experts with years of experience in the field of energy performance of buildings and has with vast experience in the technical and legal implementation of the Energy Performance of Buildings Directive in EU and non-EU countries. Besides having work for many years on the implementation of EPBD, Jana is also the task leader in several EU projects and has participated in EU Member States standby committees for the transposition of the EPBD.
How do you rate the revision of the Energy Performance of Buildings Directive? Does it look to you that the final version will be an improvement on the previous iteration?
Good in intention, improvable in technical details, for example some definitions are missing, or some definitions are contradictory (ZEB on a net annual basis and the phase out of fossil fuels, “total” primary energy by excluding renewables).
Version from Parliament improved several technical issues and also improved an ambition level especially towards EU harmonisation in energy performance assessment for key performance indicators. The version from the Council will leave more final decisions to the Member States which does not go towards a European level playing field.
But we do not know now what will be a final version, if the attempt for more harmonisation and ambition will be accepted.
Is the inclusion of minimum energy performance standards (MEPS) a game-changer for the sector?
Yes it is, but the problem is that the requirements will not be the same in all countries, as the assessment methods are different. EU harmonisation on the quality of the assessment methods is urgently needed.
MEPS have a potential to be a game changer if this instrument is properly implemented. Important is how the worst preforming buildings will be identified and what support will be available.
We should be aware that the worst energy performing buildings are often connected with the energy poverty. Energy poverty should not be treated separately from MEPS. MEPS could be instrument for solving energy poverty problem.
Important is a social justice. The performance of building, when the deep renovation brings the energy cost reduction that is higher than paying the loan for investment, is the margin when owner can be forced to renovation if appropriate financial instruments are in place ( e.g. loans with 0% interest rate).
This level should be correctly estimated by MSs and the methodology should be provided by Commission.
There should be also a commitment from the designer on the results, so that the energy and cost savings are really achieved. This also shows importance of quality of the assessment method for energy performance so that it takes into account all building technologies correctly.
Problem is sometimes an unfortunate wording that buildings have to achieve by renovation, e.g. min. class “E”. It’s a big misunderstanding and a potential for lock-in effect. Buildings must be renovated based on minimum requirements for existing buildings and in line with national building renovation plans. However, it is rather a problem of communication towards the public, this problem has been fixed and made clear in the draft EPBD.
Is the EPBD flexible enough to take into account the diverse needs of different EU countries and regions?
There are no requirements set in the EPBD, except the MEPS energy class and the values for the ZEB definition. But setting values and classes without defining the assessment methods makes no sense.
The EPBD mostly defines general principles, as for example that the IEQ should be taken into account. Then each country defines its own methods, sometimes fragmenting the EU market and creating barriers for the free circulation of services. This is a big problem for professionals and the industry.
At least the energy calculation method, which is physics, should be common in the EU as properly proposed in the version from Parliament (art. 7, 4b). We should take care that this paragraph remains.
Do you believe that the EU has prioritised the EPBD, as well as the Renovation Wave, as part of its REPowerEU plan to phase out Russian fossil fuel imports? Or has an opportunity been lost?
I do not see the harmonisation and the EU added value, if the opportunity for a common technical transposition, for example by establishing a European calculation method as it has been done in the US, will be missed.
What are the main challenges when it comes to implementing legislation like the EPBD?
Quality, transparency, harmonisation. The technical transposition should not be made by national regulations but by European standards developed under CEN.
By setting specific “means” (for example: no fossil fuel boilers) instead of fixing only the objectives (for example; carbon neutrality) the EPBD limits the possibilities of the designer to optimise the solutions for each building.
There is no “one fits all” solution.
It seems that the shift from gas to electrification in the heating sector, and the shift from the boiler to the heat pump seems to be the only solution. Other solutions, such as biogas, seem to be forgotten or made impossible to implement.