ANNEX

1. INTRODUCTION

Directive 2010/31/EU (‘EPBD’) requires Member States to adopt long-term renovation strategies and establish minimum requirements for the energy performance of newly constructed buildings and existing buildings undergoing major renovation.

Directive 2012/27/EU (‘EED’) contained provisions on building renovation and long-term strategies for mobilising investment in the renovation of national building stocks.

The EPBD and the EED have been amended by Directive (EU) 2018/844, which entered into force on 9 July 2018. The EPBD, in its Article 2a, sets out a framework for long-term renovation strategies (‘LTRSs’) to support the renovation of national building stocks into highly energy-efficient and decarbonised buildings by 2050, facilitating the cost-effective transformation of existing buildings into nearly zero-energy buildings (‘NZEBs’). In accordance with the Directive, the strategies will be supported by financial mechanisms for the mobilisation of investment in building renovation needed to achieve these goals.

In accordance with Article 10 of the EPBD, policies and measures are required to:

(a) link financial measures for energy efficiency improvements in the renovation of buildings to the targeted or achieved energy savings;

(b) allow data to be gathered on the measured or calculated energy consumption of certain buildings; and

(c) make available aggregated anonymised data.

Pursuant to Article 20 of the EPBD, information must be provided to owners or tenants of buildings or building units through accessible and transparent advisory tools.

The EPBD sets out a common general framework for determining buildings' energy performance, including the indicators and calculations to be used. These guidelines support correct implementation in national and regional regulatory frameworks. They reflect the views of the Commission. They do not alter the legal effects of the EPBD and are without prejudice to the binding interpretation of its Articles 2a, 10 and 20 and its Annex I, as provided by the Court of Justice of the European Union.

2. LONG-TERM RENOVATION STRATEGIES

2.1. Aim

The obligation for Member States to establish an LTRS of their national building stock has been moved to the EPBD from the EED. Article 1 of Directive (EU) 2018/844 introduced into the EPBD a new Article 2a on LTRSs and repealed Article 4 of the EED, which required Member States to establish a long-term strategy for mobilising investment in the renovation of national building stocks.

The EPBD now includes:

(a) a stronger reference to energy poverty; and

(b) new references to: (i) health, safety and air quality; (ii) initiatives to promote smart technologies, skills and education; (iii) policies targeting the worst-performing segments of national building stocks; (iv) ‘split-incentive’ dilemmas (1); (v) market failures; and (vi) public buildings.

Strong LTRSs are expected to accelerate the cost-effective renovation of existing buildings, which are currently subject to a low renovation rate, and ensure an increase in deep renovations. A strategy is not an end in itself, but a starting Point for stronger action.

2.2. Scope

The EPBD expands the scope of Member States' LTRSs. Like for the strategies established under Article 4 EED, LTRSs apply to the national stock of public and private, residential and non-residential buildings. However, the amended EPBD introduces new and broader obligations and identifies new areas of policy and action to be covered in the LTRSs.

Pursuant to Article 2a of the EPBD, Member States must, inter alia:

(a) establish a comprehensive strategy aimed at achieving a highly efficient and decarbonised building stock by 2050 and cost-effective transformation of existing buildings into NZEBs;

(b) set out a roadmap with measures, measurable progress indicators and indicative milestones for 2030, 2040 and 2050;

(c) carry out a public consultation on their strategy before submitting it to the Commission and set out arrangements for further inclusive consultation during implementation;

(d) facilitate access to mechanisms through smart financing to support the mobilisation of investment; and

(e) submit their strategy as part of their final (2) integrated national energy and climate plan (NECP) (3) and provide information on implementation in their integrated national energy and climate progress reports.

2.3. Obligation to establish a comprehensive strategy to achieve a highly decarbonised building stock by 2050

2.3.1. Mandatory elements of the LTRS

Member States' LTRSs should cover existing elements (see Article 4 of the EED) and new elements (see Article 2a of the EPBD). Each LTRS must now encompass the elements below.

2.3.1.1. Overview of the national building stock — Article 2a(1)(a) of the EPBD

Article 4(a) of the EED already provided that the starting point of the LTRSs was an overview of the national building stock.

Article 2a(1)(a) of the EPBD provides that each LTRS ‘shall encompass an overview of the national building stock, based, as appropriate, on statistical sampling and expected share of renovated buildings in 2020’.

The expected share of renovated buildings may be expressed in various ways, for example:

(a) as a percentage (%);

(b) as an absolute number; or

(c) in m2 of renovated space per type of building.

Renovation depth (e.g. ‘light’, ‘medium’ and ‘deep’) could also be used for greater accuracy. Transformation into NZEBs could be another indicator (4) More generally, ‘deep renovation’ should result in both energy and greenhouse gas efficiency.

The ‘expected share’ is not intended to be a binding target, but rather a figure that realistically represents the likely rate of completed building renovation in 2020. Member States can also mention the expected share of completed renovation for 2030, 2040 and 2050, in line with the requirement to provide indicative milestones for those years.

2.3.1.2. Cost-effective approaches to renovation — Article 2a(1)(b) of the EPBD

Article 4(b) of the EED already required Member States to identify in their LTRSs cost-effective approaches to renovation relevant to building type and climatic zone.

Article 2a(1)(b) of the EPBD provides that each LTRS ‘shall encompass the identification of cost-effective approaches to renovation relevant to the building type and climatic zone, considering potential relevant trigger points, where applicable, in the life-cycle of the building;’.

Recital 12 of Directive (EU) 2018/844 clarifies that a ‘trigger point’ is ‘an opportune moment in the life-cycle of a building, for example from a cost-effectiveness or disruption perspective, for carrying out energy efficiency renovations’.

A trigger point could be:

(a) a transaction (e.g. the sale, rental (5) or lease of a building, its refinancing, or a change in its use);

(b) renovation (e.g. an already planned wider non-energy-related renovation) (6); or

Certain buildings may not be subject to trigger points, hence the qualification ‘where applicable’.

Linking energy-efficiency renovation with trigger points should ensure that energy-related measures are not neglected or omitted at a later stage in the life-cycle of the building. Focusing on energy efficiency at trigger points should limit the risk of missing opportunities to renovate and increase possible synergies with other action.

Trigger points may lead to cost-effective renovation due to the economies of scale that can be achieved if energy-related renovation is carried out at the same time as other necessary work or planned renovation.

2.3.1.3. Policies and action on deep renovation — Article 2a(1)(c) of the EPBD

Article 4(c) of the EED already required Member States to ensure that LTRSs encompass policies and actions to stimulate cost-effective deep renovation of buildings, including staged deep renovation.

Article 2a(1)(c) of the EPBD provides that each LTRS ‘shall encompass policies and actions to stimulate cost-effective deep renovation of buildings, including staged deep renovation, and to support targeted cost-effective measures and renovation for example by introducing an optional scheme for building renovation passports’.

Deep renovations are those leading to refurbishment that reduces both the delivered and final energy consumption of a building by a significant percentage compared with pre-renovation levels, leading to very high energy performance (8). According to the staff working document accompanying the Commission's 2013 report on Financial support for energy efficiency in buildings (9), ‘deep renovation’ can be considered as renovation that leads to significant (typically more than 60 %) efficiency improvements.

The EPBD refers to building renovation passports (BRPs) as an example of a measure whereby Member States can support targeted cost-effective renovation and staged deep renovation. The EPBD does not specify in detail what constitutes a BRP, but a number of common elements have been identified elsewhere (10), which may be used as examples: it is an electronic or paper document outlining a long-term (15-20 year) step-by-step renovation roadmap (with ideally as few steps as possible) for a specific building which may result from an on-site energy audit fulfilling specific quality criteria and outlining relevant measures and renovations that could improve its energy performance (11).

2.3.1.4. Policies and action on worst-performing buildings and energy poverty — Article 2a(1)(d) of the EPBD

In accordance to Article 2a(1)(d) of the EPBD, each LTRS must encompass ‘an overview of policies and actions to target the worst-performing segments of the national building stock, split-incentive dilemmas, and market failures, and an outline of relevant national actions that contribute to the alleviation of energy poverty’.

This is a new element which did not exist under Article 4 of the EED. Member States' LTRSs will now have to give an overview of policies and actions that target:

(a) worst-performing segments of the national building stock;

(c) market failures; and

(d) the alleviation of energy poverty.

The overview should include at least a short description of each policy and action, its scope and duration, the allocated budget and the expected impact.

Member States are to determine the worst-performing segments of their national building stock, for example by:

(a) setting a specific threshold, such as an energy performance category (e.g. below ‘D’);

(b) using a primary energy consumption figure (expressed in kWh/m2 per year); or even

(c) targeting buildings built before a specific date (e.g. before 1980).

On ‘split-incentive dilemmas', Member States are encouraged to consult the Joint Research Centre (JRC) 2014 report Overcoming the split-incentive barrier in the building sector’ (13).

The term ‘market failures’ refers to a range of problems that tend to delay the transformation of the building stock and the tapping of cost-effective energy savings potential. These may include, for example:

(a) a lack of understanding of energy use and potential savings;

(b) limited renovation and construction activity in a post-crisis context;

(c) a lack of attractive financing products;

(d) limited information on building stock; and

(e) limited uptake of efficient and smart technologies (14).

The reference to ‘energy poverty’ in the amended EPBD is not new. The EED refers to ‘energy poverty’ (Article 7 and Recital 53 of the EED) and ‘fuel poverty’ (Recital 49 of the EED). Energy poverty is a result of a combination of low income, high energy expenditure and dwellings' poor energy performance — effective action to alleviate energy poverty should therefore include energy efficiency measures alongside social policy measures. While several Member States' LTRSs already address energy poverty, the EPBD now requires that LTRSs outline ‘relevant national actions that contribute to the alleviation of energy poverty’ (15).

Article 2a(1)(d) of the EPBD, together with Recital 11 of Directive (EU) 2018/844, provides Member States with sufficient flexibility to implement the legislation in the light of national conditions, without interfering with their social policy competencies (16).

2.3.1.5. Policies and action on public buildings — Article 2a(1)(e) of the EPBD

Pursuant to Article 2a(1)(e) of the EPBD, each LTRSs must encompass ‘policies and actions to target all public buildings’.

The scope of LTRSs under Article 4 of the EED already included certain public buildings. However, Article 2a of the EPBD now requires LTRSs to include specific policies and actions that target all public buildings. This should include ongoing initiatives by Member States to fulfil their obligations under the EPBD and the EED (17).

Both the EED and the EPBD require public authorities to lead by example by becoming early adopters of energy efficiency improvements; see, in particular, Articles 5 and 6 of the EED, which apply to ‘public bodies' buildings’.

However, Article 2a(1)(e) of the EPBD is broader in scope than Articles 5 and 6 of the EED, as it concerns all public buildings and not just ‘public bodies' buildings’ (18) that are owned and occupied by central government. Policies and actions under Article 2a(1)(e) should include, for example, buildings that are occupied (e.g. leased or rented) by local or regional authorities and buildings that are owned by central government and regional or local authorities, but not necessarily occupied by them.

Unlike Article 5(2) of the EED (19), Article 2a of the EPBD does not exempt any categories of public building. It thus in principle applies to buildings that may be exempt, in a certain Member State, from the renovation obligation pursuant to Article 5(2) of the EED. Many of the buildings listed in Article 5(2) of the EED can make a significant contribution to the achievement of national objectives.

Financial mechanisms and incentives should promote public authorities' investments in an energy-efficient building stock, for example by means of public-private partnerships or optional energy performance contracts (20) through off balance sheet financing in line with Eurostat accounting rules and guidance (21).

2.3.1.6. Incentives to use smart technologies and skills — Article 2a(1)(f) of the EPBD

One of the objectives of the revision of the EPBD was to bring it up to date with technological developments such as smart building technologies and to facilitate the uptake of electric vehicles and other technologies, both through specific installation requirements and by ensuring that building professionals can deliver the requisite skills and know-how.

Article 2a(1)(f) of the EPBD provides that LTRSs ‘shall encompass an overview of national initiatives to promote smart technologies and well-connected buildings and communities, as well as skills and education in the construction and energy efficiency sectors’.

This is a new element which did not exist under Article 4 of the EED. Member States' LTRSs will now have to give an overview of national initiatives that promote:

(a) smart technologies and well-connected buildings and communities; and

(b) skills and education in the construction and energy efficiency sectors.

The overview should include at least a short description of each initiative, its scope and duration, the allocated budget and the expected impact.

Smartness in buildings is an essential part of a decarbonised, renewable-intensive and more dynamic energy system geared to achieving the 2030 EU targets on energy efficiency and renewable energy, and a decarbonised EU building stock by 2050. Pursuant to Article 2a(f) of the EPBD, LTRSs must describe national initiatives on smart technologies and well-connected buildings and communities that may, for example, aim to:

(a) achieve high energy efficiency by optimal operation of the building and facilitate the maintenance of technical building systems;

(b) strengthen the role of demand-side flexibility in increasing the share of renewables in the energy system and making sure that the benefits are cascaded down to consumers;

(c) ensure that the building users' needs are covered and they can effectively interact with the building; and

(d) contribute to the establishment of well-connected buildings (22), and smart communities also supporting citizen-centric and open standard based solutions for smart cities.

Member States may consider adopting measures that encourage the deployment of recharging points and ducting infrastructure for electric vehicles in the context of building renovation projects, even if the renovation is not considered to be a ‘major renovation’ within the meaning of Article 2(10) of the EPBD.

The training of energy experts is essential in ensuring the transfer of knowledge on issues related to EPBD implementation. According to Article 17 of the EPBD, Member States must already ensure the independent energy performance certification of buildings and inspection of heating and air-conditioning systems by qualified and/or accredited experts. LTRSs should present an overview of national initiatives promoting the skills that building professionals need to apply new techniques and technologies in the field of NZEBs and energy renovation.

2.3.1.7. Estimate of energy savings and wider benefits — Article 2a(1)(g) of the EPBD

Article 4(e) of the EED already required that LTRSs give an evidence-based estimate of expected energy savings and wider benefits.

Pursuant to Article 2a(1)(g) of the EPBD, each LTRSs must encompass ‘an evidence-based estimate of expected energy savings and wider benefits, such as those related to health, safety and air quality’.

The amendment provides a non-exhaustive list of the type of wider benefits that LTRSs should evaluate. Certain measures to address energy performance can also contribute to a healthy indoor environment. Measures should for instance aim to:

(a) prevent the illegal removal of harmful substances such as asbestos (23);

(b) facilitate compliance with legislation on working conditions, health and safety, and emissions (24); and

(c) promote higher levels of comfort and well-being for occupants, e.g. by ensuring complete and homogenous insulation (25), coupled with the appropriate installation and adjustment of technical building systems (in particular, heating and air-conditioning, ventilation and building automation and control).

Wider benefits may also include lower illness and health costs, greater labour productivity from better working and living conditions, more jobs in the building sector, and reduced emissions and whole life carbon (26).

The evaluation of potential wider benefits associated with energy efficiency measures may enable a more holistic and integrated approach at national level, highlighting synergies that can be achieved with other policy areas and ideally involving other government departments, e.g. those responsible for health, environment, finance and infrastructure.

In connection with these elements, it is generally recognised that efforts to reduce operational energy usage typically have embodied consequences, in terms of the carbon emissions linked to manufacturing of construction products and to construction. Therefore, reducing day-to-day energy use ideally should not be looked at in isolation, as there will inevitably be a carbon cost/benefit trade-off. Although something not explored in the EPBD, a whole life carbon approach would help identifying the overall best combined opportunities for reducing lifetime carbon emissions, and helps avoid any unintended consequences. It furthermore helps find the most cost-effective solution. Ultimately, a low carbon building is one that optimises the use of resources and thereby limits carbon emissions during construction and use, over its lifetime.

Renovation can be conducted in such a way that when the building reaches the end of its life or undergoes another major renovation, different construction products or materials can be separated from each other. This allows for reuse or recycling, which can substantially reduce the volume of demolition waste going to landfill. The possibilities for circularity in the future depend directly on how renovation is conducted, which materials are chosen and how they are assembled. The recycling of materials can have a positive impact on energy consumption, as manufacturing primary construction products normally requires more energy than using secondary ones.

Benefits may also include measures to adapt buildings to climate change (27), in particular measures such as shading devices that protect buildings against overheating during heat waves that have a direct impact on a building's energy consumption by reducing the need for active cooling (28). In addition, for new buildings and buildings undergoing major renovations, it is recommended that efforts are undertaken to avoid the creation of accessibility barriers for persons with disabilities and, where possible, existing accessibility barriers should be removed (29).

Finally, in their evidence-based estimate of benefits relating to health, safety and air quality, Member States may include the effects of action they take under Article 7(5) of the EPBD (30). In addition, they may include the effects of action under Article 2a(7) of the EPBD, which refers to fire safety and risks related to intense seismic activity.

2.3.2. Roadmap — Article 2a(2) of the EPBD

Pursuant to Article 2a(2) of the EPBD,

‘In its long-term renovation strategy, each Member State shall set out a roadmap with measures and domestically established measurable progress indicators, with a view to the long-term 2050 goal of reducing greenhouse gas emissions in the Union by 80-95 % compared to 1990, in order to ensure a highly energy-efficient and decarbonised national building stock and in order to facilitate the cost-effective transformation of existing buildings into nearly zero-energy buildings. The roadmap shall include indicative milestones for 2030, 2040 and 2050, and specify how they contribute to achieving the Union's energy efficiency targets in accordance with Directive 2012/27/EU.’

This is a new element which did not exist under Article 4 of the EED.

The underlying objective is to achieve a highly energy-efficient and fully decarbonised building stock; this is essential to delivering on the EU's goal of reducing greenhouse gas emissions. A ‘decarbonised’ building stock is not defined in EU legislation, but it can be considered as one whose carbon emissions have been reduced to zero, by reducing energy needs and ensuring that remaining needs are met to the extent possible from zero-carbon sources. This approach allows for various routes to decarbonisation, taking into account the Member State's national energy mix, preferences, potential and characteristics.

As the strategies are to set out a long-term vision to deliver on a 2050 decarbonisation goal, Member States should go beyond a simple inventory of existing measures (which provide the near-term elements) and provide a long-term view of the development of future policies and measures. The roadmap framework in the new Article 2a seeks to achieve this.

According to Article 2a(2), roadmaps must include:

(a) measurable progress indicators — these can be quantitative or qualitative variables to measure progress towards the long-term 2050 goal of reducing greenhouse gas emissions in the Union and ensuring a highly energy-efficient and decarbonised national building stock. They can be revised if necessary; and

(b) indicative milestones — these can be quantitative or qualitative objectives. Member States must ‘include indicative milestones for 2030, 2040 and 2050 and specify how they will contribute to achieving the Union's energy efficiency targets in accordance with [the EED]’.

Member States can tailor their milestones and indicators to national specificities. The intention is not to introduce a sectoral target for the building sector, nor to establish legally binding targets. It is for Member States to define the specific milestones and to decide whether to make such objectives binding for the building sector (thus going beyond obligations in the EPBD). However, Member States should keep in mind that the setting of ambitious and clear milestones is key to reducing investor risks and uncertainties, and engaging stakeholders and business. The availability of consistent and reliable data is a major factor in determining measurable indicators.

In accordance with Article 2a paragraph 2, the LTRS must specify how the milestones for 2030, 2040 and 2050 contribute to the indicative headline target defined by Member States in accordance with Article 3 of the EED, since buildings are a key pillar of energy efficiency policy. This information can help policymakers shape future energy efficiency policies and design appropriate measures.

The following table presents a possible framework for defining indicators and milestones:

EPBD Article 2a Indicators (with a view to reduction of GHG emissions + decarbonisation of building stock + facilitation of cost-effective transformation) Milestones (which contribute to EU energy efficiency targets) Paragraph 1 (a) overview of the national building stock, based, as appropriate, on statistical sampling and expected share of renovated buildings in 2020; — No of buildings/dwellings/m2: — per building type — per building age — per building size — per climatic zone — Annual energy consumption: — per building type — per end use — Annual % of renovated buildings: — per renovation type — per building sector — residential/non-residential — Renovated m2: — per building type — per building size, — per building age — Number of EPCs: — per building type — per energy class — Number/m2 of NZEBs: — per building sector — Energy savings (in absolute and relative % terms) per building sector (residential, non-residential, etc.) — % of renovated buildings (per renovation type) — CO2 emissions reduction in the building sector (renovation/new buildings) — % of NZEBs (per building sector) (b) identification of cost-effective approaches to renovation relevant to the building type and climatic zone, considering potential relevant trigger points, where applicable, in the life-cycle of the building; — Cost-effectiveness of main renovation measures (e.g. net present values, payback period, investment costs per annual savings): — per building type — per climatic zone — Total energy saving potential: — per building sector (c) policies and actions to stimulate cost-effective deep renovation of buildings, including staged deep renovation, and to support targeted cost-effective measures and renovation, for example by introducing an optional scheme for building renovation passports; — Total and annual proportion of buildings undergoing deep and NZEB renovation — Public incentives for deep renovation — Public and private investments in deep renovations — Energy savings from deep renovations (d) overview of policies and actions to target the worst-performing segments of the national building stock, split-incentive dilemmas and market failures, and an outline of relevant national actions that contribute to the alleviation of energy poverty; — Public investments in policy addressing the issues mentioned (split incentives, energy poverty, etc.) — % of rented houses with EPCs below a certain performance level — Energy poverty indicators: — % of people affected by energy poverty — proportion of disposable household income spent on energy — arrears on utility bills — population living in inadequate dwelling conditions (e.g. leaking roof) or with inadequate heating and cooling — % of buildings in lowest energy classes — % reduction of people affected by energy poverty — % reduction of buildings in the lowest energy classes (e) policies and actions to target all public buildings; — m2 of renovated public buildings: — per building type — per building size — per climatic zone — Energy savings in public buildings (f) overview of national initiatives to promote smart technologies and well-connected buildings and communities, as well as skills and education in the construction and energy efficiency sectors; — No of buildings equipped with building energy management systems (BEMSs) or similar smart systems: — per building type (focus on non-residential) — Public and private investments in smart technologies (including smart grids) — Citizens participating in energy communities — No of graduated students — university courses with focus on energy efficiency and related smart technologies — professional/technical training (EPC certifiers, HVAC inspectors, etc.) — No of installers skilled in new technologies and working practices — Budget of national research programmes in the field of building energy efficiency — Participation of national universities in international scientific research projects (e.g. H2020) on energy efficiency in buildings-related topics — Percentage of buildings equipped with BEMSs or similar smart systems: — per building type (g) evidence-based estimate of expected energy savings and wider benefits, such as those related to health, safety and air quality. — Reduction in energy costs per household (average)/decrease in energy poverty — Actual energy savings achieved — Average/aggregate indoor air quality indices (IAQIs) and thermal comfort index (TCI) — Cost of avoided illnesses/reduction in health costs attributable to energy efficiency measures — Reduction of whole life carbon — Disability Adjusted Life Year (DALY)/Quality Adjusted Life Year (QALY) improvements attributable to the improvement of building stock and living conditions — Labour productivity gains from better working environment and improved living conditions — Reduction of emissions — Employment in the building sector (No of jobs created per EUR million invested in the sector) — GDP increase in the building sector — % energy imports for the Member State (energy security measures) — Removal/prevention of accessibility barriers for persons with disabilities Paragraph 3 (a) the aggregation of projects, including by investment platforms or groups, and by consortia of small and medium-sized enterprises, to enable investor access as well as packaged solutions for potential clients; No of integrated/aggregated projects (b) reduction of the perceived risk of energy efficiency operations for investors and the private sector; Perceived risk of energy efficiency operation (survey-based) (c) use of public funding to leverage additional private-sector investment or address specific market failures; Public investments as percentage of total investments in energy saving Public-private partnership initiatives (d) guiding investments into an energy efficient public building stock, in line with Eurostat guidance; and Investment in energy efficiency renovation on the public building stock (e) accessible and transparent advisory tools, such as one-stop shops for consumers and energy advisory services, on relevant energy efficiency renovations and financing instruments. One-stop shop initiatives in place Awareness-raising initiatives (number, target audience reached, target audience taking action) — No of one-stop shop initiatives — Awareness is raised and leads to concrete action

2.3.3. Public consultation and monitoring

Article 2a(5) of the EPBD provides that:

‘[t]o support the development of its long-term renovation strategy, each Member State shall carry out a public consultation on its long-term renovation strategy prior to submitting it to the Commission. Each Member State shall annex a summary of the results of its public consultation to its long-term renovation strategy. Each Member State shall establish the modalities for consultation in an inclusive way during the implementation of its long-term renovation strategy.’

This is a new element which did not exist under Article 4 of the EED. The consultation relates to the complete LTRS, including the financing mechanisms to mobilise investment, to which Member States are to facilitate access.

As public consultations can improve policy results, the EPBD makes them mandatory, but leaves each Member State to determine the consultation format (e.g. open or targeted) and method (e.g. face-to-face meetings/events, written submissions or online questionnaire). Member States may already have procedures for consultation on major policy or legislative initiatives that could be applied in the case of an LTRS (31).

According to Article 2a(5) of the EPBD, Member States must carry out a public consultation before submitting their LTRS to the Commission, regardless of whether this is already required by national legislation. Public consultation during implementation of the LTRS, which is also required under Article 2a(5) of the EPBD, is an opportunity for Member States to respond to progress and address gaps.

Member States may also consider setting up a stakeholder platform (32). The identification and consultation of stakeholders can contribute significantly to the successful implementation of the LTRS. The direct or indirect involvement of stakeholders associated with the energy upgrade of buildings is essential for the dissemination of the LTRS and the collection of data, and can promote consensus and acceptance of the LTRS (33).

Member States may take the above factors into account when planning their public consultations. In accordance with Article 2a paragraph 5, Member States must establish the modalities for consultation in an inclusive way during the implementation of its long-term renovation strategy. Member States should allow sufficient time to consult on the LTRS before submitting it to the Commission.

Pursuant to Article 2a(5) of the EPBD, a summary of the consultation must be annexed to the LTRS. It could outline, for example, the duration, period, type (open or targeted), method (face-to-face meetings/events, written comments or online), number of participants, type of participant (associations, private individuals, architects, regional and city administrations, other relevant local authorities, etc.), main comments and conclusions.

2.3.4. Safety issues

Article 2a(7) of the EPBD provides that Member States may use LTRSs to address fire safety and risks related to intense seismic activity that affect energy efficiency renovations and the lifetime of buildings. The provision should be read in conjunction with Article 7 (34), which requires Member States to address those issues in buildings undergoing major renovation.

Safety is an area of national competence and the relevant national regulations should be applied in view of the building use (e.g. residential, non-residential, school, hospital), the occupants (e.g. vulnerable occupants such as children, persons with disabilities, or seniors) and building typology (e.g. low-rise, high-rise) (35).

The trigger points (see Section 2.3.1.2. above) may also be opportune moments for assessing safety aspects in a building and conversely, safety upgrades may be good moments to address energy efficiency performance.

Less expensive housing tends to be older with obsolete electrical installations, making energy-poor consumers particularly vulnerable (36). Measures such as regular inspections (in particular before a renovation) and upgrades to bring electrical installations up to safety standards can dramatically improve electrical safety. The safety inspection of electrical and gas installations and appliances is also to be encouraged.

European standards (‘eurocodes’) provide a comprehensive, up-to-date tool for structurally designing buildings and executing other civil engineering works with a view to seismic safety (37) and structural fire design (38).

Member States are expected to apply the common methods developed under EU legislation to assess and classify construction products' reaction to fire performance (39), resistance to fire (40) and performance when used in rooves (41), keeping in mind fire-spread and safe escape.

Member States can encourage the installation of appropriate ventilation and sprinkler systems, and the safe and correct installation of equipment that could have a fire-safety impact, such as photovoltaic (PV) panels and recharging points for electric vehicles.

Fire-prevention measures and policies such as fire-safety inspections, awareness-raising through home visits and mitigating measures such as the installation of smoke detectors can also play an important role.

Member States and interested stakeholders may benefit from the work of the Fire Information Exchange Platform (FIEP) (42), which the Commission set up to facilitate the exchange of information between competent national authorities and other stakeholders so that they can benefit from lessons learned and best practices on fire safety. This should enhance regulatory authorities' ability to fulfil their tasks in full knowledge of the advantages and disadvantages of the regulatory choices they have to make.

2.4. Obligation to facilitate access to mechanisms to support the mobilisation of investments — Article 2a(3) of the EPBD

Article 2a(3) of the EPBD requires Member States to facilitate access to financial mechanisms to support the mobilisation of investments in the renovation needed to achieve the goals in Article 2a(1), i.e. a highly energy-efficient and decarbonised building stock by 2050 and the cost-effective transformation of existing buildings into NZEBs. Article 2a(3) of the EPBD sets out possible mechanisms and builds on Article 20 of the EED, which requires Member States to facilitate the establishment of financing facilities, or the use of existing ones, for energy efficiency improvement measures.

Article 2a(3) of the EPBD provides that:

‘To support the mobilisation of investments into the renovation needed to achieve the goals referred to in paragraph 1, Member States shall facilitate access to appropriate mechanisms for:

(a) the aggregation of projects, including by investment platforms or groups, and by consortia of small and medium-sized enterprises, to enable investor access as well as packaged solutions for potential clients;

(b) the reduction of the perceived risk of energy efficiency operations for investors and the private sector;

(c) the use of public funding to leverage additional private-sector investment or address specific market failures;

(d) guiding investments into an energy efficient public building stock, in line with Eurostat guidance; and

(e) accessible and transparent advisory tools, such as one-stop-shops for consumers and energy advisory services, on relevant energy efficiency renovations and financing instruments.’

This provision did not exist under Article 4 of the EED.

To drive their LTRSs, Member States will need to create access to a range of financial mechanisms to support the mobilisation of investments, in particular considering how to use innovative financing to effectively enable small clients and small providers.

The following is a non-exhaustive list of generic examples of types of financial mechanism:

(a) aggregation of projects (i) procurement by a municipality of an energy-service contract (43) for retrofitting multi-family buildings (financed through energy savings); (ii) capacity-building and stakeholder dialogue to improve relevant entities' ability to offer aggregation services; (iii) procurement by a group of municipalities of an energy-service contract for some of their public buildings; and (iv) offering integrated renovation services — an entity (e.g. energy agency, local or regional authority, energy service company (‘ESCO’), financial institution) could create a one-stop shop offering renovation services and financing, in quite a standardised way, making it possible to refinance the aggregated projects. (v) See also section 7.2 of the Commission Staff Working Document Good practice in energy efficiency (44).

(b) reduction of perceived risk (i) standardisation (e.g. through protocols, certification, standards) to reduce performance risks ex post; (ii) mortgages/loans that take account of the positive impact of the energy efficiency component of a project on the value of the asset and on default risk; (iii) refinancing (funds, bonds, factoring) to provide ESCOs and financial investors with long-term financing; (iv) on-tax financing — i.e. the money lent for investment in building improvements is repaid through property tax; (v) on-bill financing — i.e. the loan is repaid through the utility bill, with the energy savings covering the investment costs; (vi) support for collecting evidence of the real technical and financial performance of energy efficiency investments, e.g. contributing to the European de-risking energy efficiency platform (DEEP) database (see below), or creating similar national databases; (vii) encouraging the development and use of guidance on how to assess the risk for energy efficiency investments; and (viii) guarantees for beneficiaries and guarantee facilities for financial intermediaries.

See also section 7.3 of the Good practice in energy efficiency mentioned above.

(c) public funding (45) (i) loan schemes co-financed by public funds; (ii) risk-sharing instruments (e.g. loans, guarantee facilities and technical assistance); (iii) grants targeting vulnerable consumers; (iv) grants for technical assistance and to cover the costs of energy performance certificates (EPCs) and energy audits, and (where these are not mandatory) to encourage their use and raise awareness of investment opportunities; and (v) energy efficiency funds. See also section 7.1 of the Commission's 2016 good practice document.

(d) guiding investment in an energy-efficient public building stock (i) assistance for the use of energy performance contracts (market facilitators, framework contracts, practical guides, etc.); (ii) a legislative framework conducive to the development of ESCOs and the energy services market in general; (iii) capacity-building through project development assistance, training, peer-to-peer assistance, etc.; and (iv) facilitating the aggregation of small projects in public buildings (e.g. similar projects from different municipalities or public owners).

(e) accessible and transparent advisory tools and energy advisory services (i) one-stop shop or integrated service for financing and renovation; (ii) advisory services; (iii) technical guidance on financing and renovation; and (iv) financial education to improve the understanding of different financial instruments.

Examples of financing mechanisms are set out in sub-section 2.6.

These provisions are in line with the Commission's Smart Finance for Smart Buildings (SFSB) initiative (46) the first pillar of which concerns the more effective use of public funds through:

(a) capacity-building to promote the deployment of financial instruments (e.g. sustainable energy investment fora (47));

(b) the development of flexible energy efficiency and renewable financing platforms; and

(c) clarification of the accounting treatment of energy performance contracts.

This will make it possible to channel and combine public funds more effectively and speed up the deployment of financial instruments. Flexible financing platforms will offer final beneficiaries more attractive financing options through the sharing of risk and the best use of public funds, including European Structural and Investment Funds and the European Fund for Strategic Investments.

The second SFSB pillar (aggregation and project development assistance) includes:

(a) making more project development assistance available at EU level; and

(b) encouraging the development of local/regional one-stop shops for energy efficiency services.

This will help project developers bring good project ideas to maturity and facilitate building owners', households' and companies' access to information and energy efficiency services, enabling the development of large-scale investment programmes. The dedicated local or regional one-stop shops will facilitate the aggregation of projects, making them more attractive for the financial market.

The third pillar (de-risking) is implemented by the Energy Efficiency Financial Institutions Group (EEFIG) through the following initiatives:

(a) the open-source DEEP database, which provides evidence on the real technical and financial performance of energy efficiency investments (48); and

(b) the EEFIG underwriting tool (49), a consensual framework for underwriting energy efficiency investments — this is intended to provide guidance on assessing the risks and benefits associated with such investments.

These initiatives can help the market correctly assess the risks and benefits associated with energy efficiency investments, thus building trust in them and making them more attractive to project promoters, investors and financial institutions.

Pursuant to Article 7 of and Annex I to Regulation (EU) 2018/1999 of the European Parliament and of the Council (50) Member States' NECPs must include a general overview of the investments required to meet the various objectives, targets and contributions. This must include information on existing investment flows and forward investment assumptions with regard to planned policies and measures, and risk factors, barriers and public finance support or resources to address them.

2.5. Financial incentives, market barriers and information — Articles 10 and 20 of the EPBD

A number of other EPBD articles relevant to the provisions of Article 2a were also amended.

2.5.1. Financial measures linked to savings — Article 10(6) of the EPBD

2.5.1.1. Obligations

The EPBD acknowledges the role of financial initiatives and information campaigns in implementing the regulatory framework properly and achieving the EPBD's objectives. Article 10(6) of the EPBD provides that:

‘Member States shall link their financial measures for energy efficiency improvements in the renovation of buildings to the targeted or achieved energy savings, as determined by one or more of the following criteria:

(a) the energy performance of the equipment or material used for the renovation; in which case, the equipment or material used for the renovation is to be installed by an installer with the relevant level of certification or qualification;

(b) standard values for calculation of energy savings in buildings (51);

(c) the improvement achieved due to such renovation by comparing energy performance certificates issued before and after renovation (52);

(d) the results of an energy audit;

(e) the results of another relevant, transparent and proportionate method that shows the improvement in energy performance.’

This is a new paragraph. Its requirements apply as from its entry into force via national legislation (i.e. by the transposition deadline at the latest). It applies to all types of financial measure, including tax measures. It is recommended that, where possible, it also be applied to existing measures (e.g. in the case of support schemes, Member States are encouraged to consider and introduce amendments applicable to future financial support) (53).

It is already common for financial measures for energy efficiency to be accompanied by conditions or obligations requiring final beneficiaries to prove project performance and the effective use of public money. The requirement applies irrespective of whether the renovation in question constitutes a ‘major renovation’ within the meaning of Article 2(10) of the EPBD.

Article 10(6) of the EPBD allows for different approaches to linking financial support to the quality of energy renovation, but it provides flexibility to the Member States as to its implementation according to national or regional conditions. However, the provision provides that Member States must use one or more of the abovementioned criteria (a) to (e).

Competencies and skills are central to ensuring the quality of a renovation, so financial measures for energy efficiency should require that renovation measures are implemented by qualified or certified installers. This is particularly relevant in the case of criterion (a) above, according to which — a qualified and certified installer is to be involved in order to install the equipment or material used for the renovation and verify the improvements. However, this requirement has to take into consideration national regulations regarding relevant professions.

In addition to appropriate installation, an assessment of the results of the renovation by qualified or certified inspectors is encouraged in order to ensure quality assurance.

2.5.1.2. Transposition and implementation of Article 10(6) of the EPBD

Having chosen the quality criteria to be applied, Member States should disseminate and communicate the national measures transposing Article 10(6) of the EPBD to all appropriate authorities/agencies (i.e. operational authorities) responsible for designing and implementing financial measures. This is important to ensure that the design and implementation of the measures are linked to one or more of the criteria.

Member States should review their national regulation regarding relevant professions of installers in order to ensure that only qualified and certified installers are involved in the renovation process.

2.5.2. Databases for EPCs — Article 10(6a) of the EPBD

2.5.2.1. Obligations

Article 10(6a) of the EPBD provides that:

‘[d]atabases for energy performance certificates shall allow data to be gathered on the measured or calculated energy consumption of the buildings covered, including at least public buildings for which an energy performance certificate, as referred to in Article 13, has been issued in accordance with Article 12.’

EPC registers and databases can:

(a) be a key instrument for greater compliance;

(b) improve knowledge of the building stock;

(c) provide policymakers with better information; and

(d) support operators' decisions (54).

Member States do not have to establish a database or register. Where such a database exists or is introduced, Member States must comply with this new provision (55). It is for them to determine the frequency with which the database should be updated with new (actual or calculated) energy consumption data.

Article 10(6a) of the EPBD requires that EPC databases allow for the gathering of consumption data (measured or calculated) of the buildings covered. These must include at least public buildings for which an EPC has been issued on the basis of Article 13 of the EPBD, i.e. buildings occupied by public authorities that are frequently visited by the public and have a total useful floor area of over 250 m2 (i.e. buildings for which an EPC is required under Article 12(1) of the EPBD.

Member States are free to determine what ‘frequently visited’ means, but the interpretation used in transposing Article 10(6a) of the EPBD should be consistent with that for Articles 12 and 13 of the EPBD (which have already been transposed).

Member States are free to find the data from other sources and register it in EPC databases.

2.5.2.2. Transposition and implementation of Article 10(6a) of the EPBD

If they have an EPC database, Member States should:

(a) examine whether the arrangements allow for the gathering of measured or calculated energy consumption data and amend them if necessary to comply with the obligation in Article 10(6a);

(b) ensure that at least the data for public buildings with an EPC that are visited frequently by the public is fed into the database; and

(c) update the data, ideally at least once a year.

2.5.3. Aggregated anonymised data — Article 10(6b) of the EPBD

Article 10(6b) of the EPBD provides that:

‘[a]t least aggregated anonymised data compliant with Union and national data protection requirements shall be made available on request for statistical and research purposes and to the building owner.’

Member States have to take the necessary action to ensure that this requirement is met. This provision does not require them to make changes to existing databases, but to ensure that the legislative framework allows the data to be made available in accordance with obligations in the Article.

2.5.4. Information — Article 20(2) of the EPBD

Article 20(2) of the EPBD provides that:

‘Member States shall in particular provide information to the owners or tenants of buildings on EPCs, including their purpose and objectives, on cost-effective measures and, where appropriate, financial instruments, to improve the energy performance of the building, and on replacing fossil fuel boilers with more sustainable alternatives. Member States shall provide the information through accessible and transparent advisory tools such as renovation advice and one-stop shops. At the request of the Member States, the Commission shall assist Member States in staging information campaigns for the purposes of paragraph 1 and the first subparagraph of this paragraph, which may be dealt with in Union programmes.’

Article 20 of the EPBD was amended to clarify Member States' obligation to provide information to tenants or owners. The (non-exhaustive) list of cases now includes an obligation to provide information on replacing fossil fuel boilers (56) with more sustainable alternatives.

Article 20(2) of the EPBD requires that ‘Member States shall provide the information through accessible and transparent advisory tools such as renovation advice and one-stop shops’.

2.6. Submission of LTRS and progress reporting

2.6.1. Submission of LTRS

According to Article 2a(8) of the EPBD (57), the LTRS must be submitted to the Commission ‘as part of’ each Member State's final NECP. The LTRS should be submitted as an annex to the NECP.

According to Article 3(1) of Regulation (EU) 2018/1999, the deadline for submission of the final NECP is 31 December 2019 and every 10 years thereafter.

However, by way of derogation set out in Article 2a(8) of the EPBD, the deadline for submission of the first LTRS is at the latest 10 March 2020, three months after the deadline for the final NECP. Member States are nevertheless advised to aim to have their LTRS finalised at the same time as their final NECP so that the LTRS can be fully taken into account in, and shape the NECP.

According to Article 4(b)(3) of Regulation (EU) 2018/1999, as part of their NECPs Member States must set out the objectives, targets and contributions for each of the five dimensions of the Energy Union. The mandatory elements to be included in the draft and final NECP are:

(a) indicative milestones (58);

(b) roadmap with domestically established measurable progress indicators (59);

(c) evidence-based estimate of expected energy savings and wider benefits (60); and

(d) contributions to the Union's energy efficiency targets (61) pursuant to the EED in accordance with Article 2a of the EPBD.

These key elements were to be included in the draft NECP that was due by the end of 2018 and must feature in the final NECP to be submitted by the end of 2019. The key elements are central to the objectives in the NECPs and underpin the reinforced, fully fledged LTRSs.

2.6.2. Progress reporting

Chapter 4 of Regulation (EU) 2018/1999 sets out reporting obligations related to NECPs, including reporting related to LTRS.

Article 17 of the Regulation (EU) 2018/1999 requires Member States to submit integrated national energy and climate progress reports (‘Progress Reports’) by 15 March 2023 and every two years thereafter.

Pursuant to Article 17(2)(c) of Regulation (EU) 2018/1999, these Progress Reports must include mandatory information on energy efficiency which is defined in Article 21 of Regulation (EU) 2018/1999.

2.6.2.1. Reporting on national trajectories, objectives and targets

According to Article 21(a) of Regulation (EU) 2018/1999, Progress Reports must include information on the implementation of national trajectories, objectives, and targets. In relation to buildings and long-term renovation strategies, this includes:

(a) indicative milestones of the LTRS; and

(b) contributions to the Union's energy efficiency targets pursuant to the EED in accordance with Article 2a of the EPBD;

(c) where applicable, an update of other national objectives set out in the NECP.

2.6.2.2. Reporting on policies and measures

Pursuant to Article 21(b) of Regulation (EU) 2018/1999, Progress Reports must include information on the implementation of policies and measures, includingLTRS in accordance with Article 2a of the EPBD.

2.6.2.3. National objectives

Finally, in accordance with Article 21(c) of Regulation (EU) 2018/1999, which refers to Part 2 of Annex IX to Regulation (EU) 2018/1999, Progress Reports must also include additional information relating to national objectives, including major legislative and non-legislative policies, measures, financing measures and programmes implemented in the preceding 2 years to achieve the objectives referred to in Article 4(b) of Regulation (EU) 2018/1999 including those which improve the energy performance of buildings (Paragraph (a) of Part 2 of Annex IX to Regulation (EU) 2018/1999).

2.7. Good practice for complying with Article 2a of the EPBD

This section sets out guidance on good practice which will be useful for the Member States in the implementation of the requirements of Article 2a. It follows the structure of the previous section.

The building renovation strategies submitted by Member States in 2014 and 2017 under Article 4 of the EED will be the building blocks for the future LTRSs. The National energy efficiency action plan (NEEAP) guidance (62) includes detailed instructions for the inclusion of certain elements in those strategies — relevant sections are referred to below. This is a useful starting point, as Directive (EU) 2018/844 builds on the obligations as regards building renovation strategies.

2.7.1. Overview of national building stock — Article 2a(1)(a) of the EPBD

Details of items to be covered in the overview of national building stock are set out in Annex B, section 1, guidance 57 of the NEEAP guidance.

Member States are encouraged to take into consideration the requirements of the INSPIRE Directive (63) when preparing their overview. Buildings are one of the 34 data themes addressed by that Directive and national and local public administrations are expected, by 2020, to make large datasets containing relevant information (e.g. dates of construction, current use and condition) discoverable and downloadable. The JRC's 2016 technical report on Buildings-related datasets accessible through the INSPIRE geoportal (64) may be useful in this respect.

The 2017 LTRSs from Wallonia (Belgium), France and Malta are examples of good practice in presenting an overview of the national building stock (65).

2.7.2. Cost-effective approaches to renovation — Article 2a(1)(b) of the EPBD

Annex B, section 2 of the NEEAP guidance provides detailed indications on how to identify cost-effective approaches to renovation.

The 2014 LTRS from the Brussels Capital Region and the 2017 LTRSs from Wallonia (Belgium) and Bulgaria have been identified as examples of good practice in cost-effective approaches (66).

See also the Buildings Performance Institute Europe (BPIE) 2016 factsheet Trigger points as a must in national renovation strategies (67).

Industrialised retrofitting

Industrialised retrofitting by way of serial prefabrication off-site of insulating facade and roof elements including cabling, tubing and glazing can result in more cost-effective renovation and low-disturbance of residents during the renovation.

The E2ReBuild (68) project investigated, promoted, and demonstrated cost-effective and advanced energy-efficient retrofit strategies for two-storey residential buildings that create added value.

The 2ndskin (69) project brought different stakeholders from the building industry together, aiming at integrating their expertise and objectives into an innovative building retrofitting for multi-storey residential buildings concept that achieves zero energy use while offering up-scaling possibilities. The hypothesis of the project is that zero-energy refurbishment can be promoted and its rate can increase by the application of prefabricated façade modules, which increase installation speed and minimise disturbance for the occupants.

Rental and energy performance

To further support the necessary improvements in their national rental stock, Member States should consider introducing or continuing to apply requirements for rental properties' EPCs to demonstrate a certain level of energy performance (see Recital 9 of Directive (EU) 2018/844). In doing so, Member States should consider establishing financial mechanisms that will ease any burden on property owners in financing the necessary renovations.

The Dutch government has announced that, from 2023, buildings should have an energy rating of at least ‘C’ in order to be rented out as office space (70).

In England and Wales, the Energy Efficiency (Private Rented Property) Regulations 2015 establish a minimum level of energy efficiency for privately rented domestic and non-domestic properties. Since April 2018, landlords of such properties have had to ensure that they have an EPC rating of at least ‘E’ before concluding a new tenancy agreement with new or existing tenants. From 1 April 2020 (for domestic properties) and 1 April 2023 (for non-domestic properties), the requirement will apply to all private rented properties even where there has been no change in tenancy arrangements (71).

Scotland has introduced a measure requiring the renovation of low-performing social housing. In Greece, a similar approach applies, according to which, in order to be leased to or acquired by the public sector, buildings should have an EPC rating of at least ‘C’. This obligation will apply to all existing lease contracts by 2020.

2.7.3. Policies and action on deep renovation — Article 2a(1)(c) of the EPBD

Annex B, Section 3 of the NEEAP guidance sets out the information to be provided with regard to policies and measures to promote cost-effective deep renovation.

The 2017 LTRSs from the Brussels Capital Region and France are examples of good practice as regards measures to promote deep renovation (72).

Roadmaps

The iBRoad project (73) is working on an individual building renovation roadmap for single-family houses. The tool looks at the building as a whole and produces a customised renovation (iBRoad) plan over the long term (15-20 years), combined with a building logbook or passport as a record of energy-related interventions. iBRoad found that homeowners and purchasers need more user-friendly and trustworthy advice on the best way of carrying out energy renovations.

iBRoad's report The concept of the individual building renovation roadmap — an in-depth case study of four frontrunner projects (74) addresses the process of producing and implementing such a roadmap and covers the key issues to be addressed. It also presents real-life examples from Denmark (BetterHome (75)), Flanders (Woningpas and EPC+), France (Passeport efficacité énergétique) and Germany (Individueller Sanierungsfahrplan).

The Alliance for Deep Renovation in Building (ALDREN) (76) also proposes building passports for step-by-step renovation and provides harmonised energy performance ratings via a common European voluntary certification scheme.

Building-related information

The Intelligent Energy Europe (IEE) project Request2Action (77) worked on EPCs and how to improve uptake of their recommendations. The proposed solution, which in some cases comes close to a passport, is a ‘hub’ or one-stop shop for buildings-related information. One example of the approach is the Casa+ hub in Portugal, which is designed for storing EPCs and related data for all residential dwellings, so that offers can be made for renovating them, the outcomes of which would also be registered. Further details can be found in the report on Recommendations on building hubs (78).

2.7.4. Policies and actions on worst-performing buildings and energy poverty — Article 2a(1)(d) of the EPBD

2.7.4.1. Worst-performing segments of the national building stock

The Horizon 2020 ENERFUND project (79) addresses the need for easy-to-access and reliable assessments of the energy savings to be obtained through deep energy retrofits, by encouraging more such projects in Europe. The project is developing a decision-making tool rating deep renovation opportunities against a set of parameters — like the credit scores used by banks to rate clients. The tool is presented as an online map displaying the energy performance of individual buildings.

In Denmark, all social housing associations contribute every month to a common ‘solidarity fund’ which is used to renovate the worst-performing buildings.

Rental property restrictions related to energy performance (as referred to in section 6.2) are also an effective measure to encourage the renovation of worst-performing buildings.

Tax mechanisms are another means by which Member States can encourage the renovation of energy-inefficient buildings; examples include:

(a) income tax deductibility for certain energy efficiency renovation costs (Denmark); and

(b) a tax on energy consumption (Netherlands) (80).

2.7.4.2. Split-incentive dilemmas

Rental property restrictions related to energy performance are also an effective measure to encourage the renovation of energy-inefficient buildings. Examples include:

(a) forcing landlords to make improvements (UK (81)); and

(b) minimum performance levels for rented units, e.g.: (i) obligatory roof insulation (Flemish Housing Code); and (ii) minimum EPC levels for offices (Netherlands).

2.7.4.3. Market failures

Annex B, section 3(b) of the NEEAP guidance includes an analysis of barriers to renovation in the list of the information items to be provided. Section 3(d) suggests that new policy measures should address such barriers.

The impact assessment that accompanied the proposal to revise the EPBD (82) also addresses barriers to the uptake of energy efficiency investments in buildings.

2.7.4.4. Alleviation of energy poverty

The JRC's assessment of the 2017 LTRSs gives an overview of Member States' direct (specific policies and measures) and indirect references (general strategies or initiatives) to ongoing or planned efforts to alleviate energy poverty. Many of the measures take the form of financial incentives targeting segments of the population considered to be under the energy poverty line, low-income households or social housing units. Some countries introduced specific actions targeting energy poverty under their energy efficiency schemes, while others set up dedicated awareness-raising and advisory services.

The EU Energy Poverty Observatory is a valuable source of data and statistics. It has developed energy poverty indicators, gathered an extensive catalogue of policy measures and compiled a comprehensive repository of research. It helps stakeholders involved in designing or implementing energy poverty policy (policymakers, NGOs, public authorities at different levels, researchers and practitioners) to define and measure the phenomenon. It also facilitates the exchange of good practice and provides training materials. It can be of direct assistance to Member States in providing advice and expertise — both ad hoc and via its extensive advisory board, which is made up of experienced experts in all aspects of energy poverty.

In France, the national housing agency addresses fuel poverty, inter alia, through its Habiter mieux (‘Living better’) programme. France's energy savings certificates scheme imposes a new obligation specifically aimed at combating fuel poverty. The scheme will fund action among low-income households. France has also set up a ‘fuel poverty observatory’ to measure fuel poverty situations more accurately and monitor public and private financial aid to disadvantaged households, together with action under local and national initiatives.

Under the Irish government's strategy to combat energy poverty and the Healthy Ireland framework, national authorities have set up the Warmth and Wellbeing scheme, a pilot initiative that aims to validate, in the Irish context, international evidence that making homes warmer and more energy-efficient can have a positive effect on the health and wellbeing of people in energy poverty who are also suffering from conditions such as chronic obstructive pulmonary disease and asthma. Under Ireland's social housing investment programme, local authorities are allocated capital funding each year for a range of measures to improve the standard and overall quality of their social housing stock, including retrofitting for greater energy efficiency.

In partnership with the EU Episcope project, Irish Energy Action has developed an EPC mapping tool (83). An interactive map illustrates various building characteristics (including energy poverty indicators) in different neighbourhoods in Dublin. The data is aggregated within small areas and electoral divisions. This mapping facilitates a district approach to local policymaking and the formulation of strategies to alleviate energy poverty.

Austria's energy efficiency obligation scheme applies a bonus factor whereby savings achieved in low-income households are weighted with a factor of 1,5. In addition, energy suppliers must run centres that provide information and advice, inter alia, on energy poverty. Other examples of dedicated regional/local programmes in Austria include an energy advice scheme in Vienna and an electricity-saving project for low-income households in the Braunau, Freistadt and Linz-Land districts.

The Netherlands' energy saving agreement for the social rental sector sets housing associations the objective of achieving energy label B (equivalent to energy index 1,25) on average by 2020.

Other examples include:

(a) the PLAGE SISP programme in the Brussels Capital Region;

(b) subsidies for individual energy efficiency measures in vulnerable households in Croatia;

(c) Cohesion policy JESSICA programmes in Lithuania and the Czech Republic;

(d) personalised advisory services for energy efficiency for low-income households in Luxembourg and elsewhere; and

(e) social bonuses or discounts on energy bills for low-income families in Italy and France.

The REACH project (84) addressed energy poverty by training vocational school teachers and students as energy advisors. REACH partners made about 1 600 household visits to implement basic energy efficiency measures. In Slovenia, the project helped to trigger a nationwide scheme addressing energy poverty in households. Training packages and the final impact report are available on the project website.

The ASSIST project (85) aims to tackle energy poverty and provide specialised services through a network of vulnerable consumer energy advisors (‘VCEAs’). VCEAs are to be selected from people with direct experience of vulnerability and/or energy poverty, who will be trained so as to improve their future employability and maximise peer-to-peer benefits. Action includes:

(a) working with feedback systems;

(b) energy audits;

(c) community-based initiatives;

(d) support in obtaining funds for energy efficiency; and

testing innovative funding mechanisms. The Urban Agenda for the EU (86) was initiated within the framework of intergovernmental cooperation in 2016 with the overall objective of including the urban dimension in policies in view of achieving better regulation, better funding and better knowledge for cities in Europe. The Agenda is implemented through Partnerships in a multi-level governance format. One of the Partnerships is focused on Energy Transition. This Partnership aims, inter alia, to improve energy efficiency at a building level through retrofitting for energy efficiency and management including advice provision, also for the benefit of alleviating energy poverty. Moreover, the Partnership for Housing addresses the need to increase affordable housing, among which actions to monitor affordable housing investment, recommendations for preventing evictions by energy efficiency renovation, fostering integrated district-level energy efficiency renovation approaches, and improvement of EU gender-poverty-energy nexus data.

Other projects addressing energy-efficient renovation with a focus on social housing

While the FIESTA project (87) did not specifically address energy-poor households, a good proportion of the households involved were in social housing. The project tackled heating and cooling efficiency in families, with a particular focus on the more vulnerable. Free energy helpdesks in 14 cities advised individuals (either face-to-face or online) and carried out door-to-door energy audits. At least 39 other European cities have officially undertaken to replicate the FIESTA model. The project developed user-friendly energy-saving guidance materials for households, such as the FIESTA energy efficiency guide (88) and short animated films (89) in Bulgarian, Croatian, English, Greek, Italian and Spanish.

The Horizon 2020 EnerSHIFT project (February 2016 to January 2019) (90) targets the social housing sector in the Liguria region (Italy). It provides technical assistance for the preparation of feasibility studies, with the ultimate objective of launching a tender for investments by ESCOs through an energy performance contract. The project also involves the use of cohesion policy funds to trigger investment. The target is a programme for investing nearly EUR 15 million, resulting in primary energy savings of 14,5 GWh/year.

In September 2018, the award procedure for the first EnerSHIFT tender was concluded, targeting 44 social housing buildings in the province of Genoa (Italy), and the contract should be signed by the end of the year. An agreement with the Liguria banking system is aimed at facilitating ESCOs' access to credit. Regional Law No 10/2004 on the social housing sector was amended to facilitate the implementation of energy performance contracts. As a result, proposed contracts are no longer subject to the formal approval of the tenants.

The Transition Zero project (91) aims to improve the spread of NZEBs across Europe, looking specifically at refurbishment in social housing. Building on the success of Energiesprong in the Netherlands, Transition Zero is expanding net-zero energy refurbishment in the UK and France, using the social housing sector as a catalyst. Energiesprong delivers fully integrated refurbishment packages with long-term guarantees that make the solution commercially financeable and scalable. Transition Zero is not limited to the alleviation of energy poverty — it also applies to non-energy-poor housing stock. However, its business model offers viable solutions whereby social housing companies can alleviate problems of affordable housing and energy poverty. Relevant reports have focused on structural finance products for social housing, energy performance guarantees and refurbishment package delivery protocols, tender specifications, the national and regional regulatory context for refurbishment, and market assessment.

2.7.5. Policies and action on public buildings — Article 2a(1)(e) of the EPBD

In Croatia, two projects launched in 2015 to facilitate the combined use of European Regional Development Fund (ERDF) and Cohesion Fund investment for the renovation of public buildings have involved:

(a) the preparation of detailed design documentation for energy efficiency and renewable energy system (RES) measures in buildings; and

(b) investment in the energy renovation of school buildings.

From 240 applications, 12 pilot projects were selected for funding (five for design documentation and seven for investments in schools) (92).

Slovenia has many heritage public buildings and major energy savings potential. However, such buildings are usually treated as exceptions under the EPBD. Slovenia's policy package includes guidelines (technical recommendations) for the energy renovation of heritage buildings and involves positive criteria to facilitate the application of heritage buildings to qualify for EU cohesion policy funding (93).

The Horizon 2020 Premium Light Pro project (94) has been working to support the uptake of LED lighting systems among public authorities and private companies across nine EU countries. The aim is to help public authorities develop effective policies to facilitate the implementation of efficient new-generation LED lighting systems in the service sector. Green procurement criteria and guidelines for indoor and outdoor LED lighting systems have been published on the project website.

The EmBuild coordination and support project (95) seeks to:

(a) improve regional/municipal authorities' capacity to collect the necessary data to prepare ambitious, sustainable and realistic renovation strategies for public buildings;

(b) identify and analyse cost-effective approaches to renovation;

(c) make policy recommendations to stimulate cost-effective deep renovations of buildings and identify best practices;

(d) guide public investment decisions and facilitate private sector involvement; and

(e) measure and communicate expected energy savings and wider benefits.

2.7.6. Incentives for smart technologies and skills — Article 2a(1)(f) of the EPBD

2.7.6.1. Smart technologies

The Horizon 2020 Smart-up project (March 2015 to July 2018) (96) aimed to encourage the active use of smart meters and in-house displays by vulnerable consumers in France, Italy, Malta, Spain and the UK. There was a strong engagement strategy in training stakeholders who are in particularly close contact with vulnerable households. More than 550 frontline staff (mainly social workers) were trained in 46 training sessions and went on to advise over 4 460 vulnerable households on:

(a) how to use energy more efficiently;

(b) how to read and understand electricity and/or gas meters; and

(c) how to reduce their energy bills.

In Spain, the project inspired a social programme funded by the municipality of Barcelona to combat energy poverty. As a result, 100 unemployed people were trained and more than 1 800 vulnerable households received advice. Another positive outcome is that 32 % of the trainees are now working in Barcelona's fuel poverty information points. Training packages and the final impact report are available on the project website.

The PEAKapp (97) project encourages energy saving based on competitive human nature while also facilitating the consumption of clean and low-priced electricity from the spot market for household customers. Using data from already installed electricity smart-meters, PEAKapp solution creates incentives not only to use energy more efficiently, but also to shift loads towards times of increased production from renewable resources, thus enabling residents of the social housing sector to participate actively in the electricity market and benefit from monetary savings. PEAKapp is currently validating this ICT-solution under real life conditions in more than 2 500 households in Austria, Estonia, Latvia, and Sweden.

The aim of the MOBISTYLE (98) project is to motivate behavioural change by raising consumer awareness through a provision of attractive personalized information on user's energy use, indoor environment and health, through information and communication technology (ICT) based services. Behaviour change is achieved through awareness campaigns during which end-users are encouraged to be pro-active about their energy consumption and to simultaneously improve health and well-being. The MOBISTYLE solution and tailor-made services are being validated in real life operating conditions, in five countries (99).

Eco-Bot (100) aims to utilize recent advances in chat-bot tools and advanced signal processing (i.e. energy disaggregation) using low-resolution smart meter-type data with the goal of changing their behaviour towards energy efficiency behaviours. Eco-Bot targets to a personalized virtual energy assistant to deliver information on itemized (appliance-level) energy usage through a chat-bot tool.

2.7.6.2. Skills development schemes

The BUILD UP Skills (101) initiative aims to unite the building workforce in Europe and increase the number of qualified workers. It focuses on the in-work education and training of craftspeople and other on-site workers in the field of energy efficiency and renewable energy in buildings, and has three main components:

(a) establishing national qualification platforms and qualification roadmaps to 2020 (pillar I: 2011-2013);

(b) developing and upgrading qualification and training schemes (pillar II: from 2013); and

(c) Europe-wide coordinated support activities (EU exchanges).

The BUILD UP Skills Construye2020 project (Spain) (102) developed an app for mobile devices which can be used as a training tool on good practices for various activities in the renovation of buildings, in particular aluminium carpentry, insulation, RESs, energy efficiency and efficient installations. The project is working with the national qualification institute to develop a new qualification for the installation of ground-source heat pumps.

BUILD UP Skills Netherlands@Work (103) has produced eight blue-collar professional competence profiles, covering skills required for constructing energy-neutral buildings. An app enables blue-collar workers to choose a suitable course on the basis of their previous knowledge.

The partners in BUILD UP Skills BEEP (Finland) (104) have developed an innovative training approach (for trainers and workers) feeding best practice in energy-efficient construction into a comprehensive toolbox including:

(a) sets of slides and teaching videos in five languages;

(b) self-learning material for workers;

(c) a pilot training course for ‘change agents’ (experienced workers/mentors who can set an example and explain how to improve the quality of the work); and

(d) an on-site training ambassador who plays a critical role in persuading workers to take the pilot training.

The BUILD UP Skills Qualishell project (Romania) (105) supported the implementation of national qualification schemes for installers of thermal insulating systems and high-efficiency window systems to ensure high-performance building envelopes and support the move to NZEBs.

2.7.6.3. Training and certification for experts

In Germany, a national list of energy efficiency experts for the federal government's support programmes in the field of energy efficiency is kept in order to improve local energy consulting services by means of:

(a) uniform qualification criteria;

(b) proof of regular advanced training; and

(c) random checking of results.

Slovenia has a common training/certification article in its legislation transposing the EED, the EPBD and the Renewable Energy Directive (106), and is achieving synergies through a coordinated modular training approach.

In Croatia, energy efficiency training programmes for architecture, construction and building services professionals have been running since 2009. The objective is also to improve knowledge among engineers, whose competencies enable them to approach construction work and buildings as a whole in terms of energy characteristics.

Member States could consider incorporating energy efficiency into curricula and programmes for the training of building sector professionals (e.g. engineers and architects) as part of their national educational policy.

2.7.7. Estimate of energy savings and wider benefits — Article 2a(1)(g) of the EPBD

Annex B, section 5 of the NEEAP guidance lists points that should be evaluated to produce an evidence-based estimate of expected energy savings and wider benefits.

The 2017 LTRSs from Cyprus, the Czech Republic, Finland, Lithuania, Romania and Sweden are good practice examples of efforts to quantify the wider benefits of building renovation (107).

The Horizon 2020 COMBI project (108) was aimed at quantifying the multiple non-energy benefits of energy efficiency in order to incorporate them into decision-support frameworks for policymaking. The project developed an online tool (109) able to visualise and where possible monetise the wider benefits of energy efficiency improvements. Eight of the 21 end-use energy efficiency improvement actions cover buildings (110).

There are several ongoing initiatives that aim to reduce whole life carbon. The French E+C- initiative is aiming at an energy carbon regulation for 2020. Finland has set out a roadmap towards low carbon construction. The aim is to implement regulatory life cycle CO2 threshold limits for different building types by 2025. The impact analysis conducted by VTT, concludes that a total reduction 0,5 millions of tons of CO2 could be reached in new building annually. It includes additional savings (on top of the revised NZEB energy-efficiency norms) based on the implementation of a full life cycle concept. This is close to 10 % of the overall shortage towards Finland's EU 2030 commitments. In Germany, on the federal level (‘Bundesbauten’), new buildings owned by the federal governments have to follow sustainability guidelines. These guidelines are defined in the sustainability rating scheme ‘BNB’ (Bewertungssystem Nachhaltiges Bauen) and contains LCA calculation and benchmarks for new buildings. A good example on the local level is the London Mayors Environmental Policy, which refers to whole life carbon. Discussions are ongoing how to include the concept in London's central planning reference, due in 2019.

Other resources

— Promoting healthy and highly energy performing buildings in the European Union (111), JRC report (2017);

— World Health Organisation ‘WHO housing and health guidelines’ (112);

— BPIE study on EU-wide modelling focusing on health, wellbeing and productivity in schools, offices and hospitals (113).

2.7.8. Mechanisms to support the mobilisation of investments — Article 2a(3) of the EPBD

The following guidance relates to the types of financial mechanism to which Member States must facilitate access.

Another source of examples of successful schemes is Chapter 7 of Good practice in energy efficiency (referred to in Section 2.4).

2.7.8.1. Aggregation of projects

(a) The PadovaFIT! project (114) aims to retrofit multi-family buildings through energy performance contracting. It aggregates demand within a municipality by grouping all associated buildings to generate a critical mass, ensure favourable economic conditions and guarantee the quality of the work to be carried out by the bidders. Since 2014, the consortium has been engaging condominiums throughout the city of Padua (Italy) to build demand for energy retrofits. In the meantime, the municipality has procured a private ESCO, which will conclude a contract with each condominium, and then finance the energy retrofit, which will be paid for through the energy savings.

(b) The MARTE project (115) developed deep energy retrofit investments in buildings in the healthcare sector in the Marche region (Italy). It involved a complex financing structure integrating public (ERDF) and private (ESCO/Energy Performance Contract) resources in a target-oriented way. It also laid the foundation for larger-scale replication in other healthcare structures (in the region and elsewhere in Italy) and in other sectors, such as social housing and waste management, in particular by capacity-building and promoting the Energy Performance Contract model.

(c) The ZagEE project (116) provided tailored project development assistance for an aggregated portfolio of energy efficiency and renewable energy investments in Zagreb (Croatia). It targeted the retrofitting of public buildings (city office buildings, primary and high schools, kindergartens, health centres, retirement homes, etc.) and public lighting. The funding scheme used budgetary resources, bank loans, and national and EU grants.

(d) Under the ESCOLimburg2020 (117) project, the public energy grid operator Infrax has developed an integrated service to accelerate the energy renovation of municipal buildings, covering all steps from audits to works implementation and finance. Over EUR 20 million has been invested in the refurbishment of public buildings.

(e) The PARIDE project is an excellent example of ‘bundling’ (in this case, for the renewal of public street lighting) without upfront investment costs for the municipalities concerned and with reduced transaction costs due to joint procurement procedures, for a EUR 25 million energy performance contracting programme for 33 municipalities in the province of Teramo (Italy).

(f) The CITYNVEST (118) project compared and produced guidance on innovative finance models for building renovation in Europe (119) in A review of local authority innovative large scale retrofit financing and operational models and How to launch ambitious energy retrofitting projects in your region (120), which focuses on ‘one-stop shop’ approaches to refurbishing public buildings.

2.7.8.2. Reducing the perceived risk of energy efficiency operations

(a) Standardising energy efficiency operations increases investor confidence. Protocols can be deployed to reduce performance risks and training can be organised on implementing the protocols and certifying projects. The Investor Confidence Project (ICP) Europe (121), supported by two Horizon 2020 projects (ICPEU and I3CP), develops standardised protocols and associated tools such as project development specifications. Through its stakeholder network, it provides project developers with technical assistance to certify projects and programmes as ‘investor-ready energy efficiency’ (IREE). It also works with financial institutions to help them incorporate IREE into their investment and lending procedures.

(b) The ‘Standardisation and communication of sustainable energy asset evaluation framework’ (SEAF) project (122) developed a holistic, IT-based platform for the valuation and benchmarking of smaller sustainable energy projects (on energy efficiency, demand response, distributed renewable energy generation, energy storage, etc.), thus bridging the gap between project developers and investors. It developed a tool (eQuad) (123) that integrates ICP protocols and includes valuation and optimisation, and risk assessment and transfer (insurance) components.

(c) The Energy-Efficient Mortgage Initiative aims to create a standardised, European-level ‘energy-efficient mortgage’. The idea is to give preferential mortgages to building owners seeking to improve the energy efficiency of their buildings by taking account of the positive impact of energy efficiency on the building's value and on payment defaults. The pilot phase started in June 2018, with more than 35 banks committed to participating.

(d) There are ways of making energy efficiency attractive for institutional investors and supporting the refinancing of energy efficiency related assets. The Latvian Baltic Energy Efficiency Fund (LABEEF) provides ESCOs with long-term financing by forfaiting EPC contracts (124) and issuing green bonds for energy efficiency.

(e) The EUROPACE project (125) is developing a scalable on-tax financing mechanism, whereby the long-term repayment obligation relates to a property rather than its owner, and municipalities ensure repayment via a special levy collected with the property tax bill. On-tax financing mechanisms build on municipalities' existing relationships with their citizens (the property tax system) and have great potential to boost home renovation across income levels.

2.7.8.3. Public funding to leverage private-sector investment or address market failures

(a) Examples of loan schemes co-financed by public funds include: (i) multi-apartment building modernisation funds (Lithuania) (126); (ii) a combination of loans, technical assistance and grants for the renovation of multi-apartment buildings (Estonia) (127); (iii) Kreditanstalt für Wiederaufbau (KfW) grants and loans for energy renovation (Germany) (128); and (iv) SlovSEFF (Slovakia) (129).

(b) Examples of risk-sharing instruments (e.g. loans, guarantees and technical assistance) include: (i) Private Finance for Energy Efficiency (PF4EE) (130); and (ii) the Smart Finance for Smart Buildings guarantee facility (under development).

(c) Work is ongoing to produce an online EU mapping tool, to understand how public funds can be used to support energy efficiency in Europe.

(d) Examples of support for citizens' finance for energy efficiency through cooperation between local authorities and energy cooperatives include the Horizon 2020 REScoop PLUS (131) and REScoop MECISE (132) projects with partners from across the EU. The latter aims to channel at least EUR 30 million of renewable and energy efficiency investment, including co-investment by citizens and local authorities. It has established a revolving fund to enable the flexible pooling of project finance by cooperatives. REScoop — municipality approach (133) sets out guidance for public authorities on how to support citizens' investment in local sustainable energy projects.The German CF4EE platform Bettervest (134) is the world's first crowd-funding platform for energy-efficiency. It funds projects of companies, NGOs and local authorities and enables high returns in the cost savings. A defined percentage of the savings is distributed to the crowd until the investment plus a previously agreed upon profit has been paid back. SMEs, NGOs and local authorities can finance their energy saving projects and reduce their CO2 emissions. The platform Bettervest gets a percentage of the overall funding.

(e) The QualitEE project (135) (an example of work on EU-wide quality standards on energy efficiency services) aims to scale up investment in building energy efficiency by establishing quality certification frameworks that go beyond the presentation of model contracts. It comprises standardised quality criteria, institutionalisation of the quality assurance process and active promotion schemes. Ultimately, it aims to build trust in energy efficiency services and providers by fostering a common understanding of ‘good quality’ services, and thus improve the financeability of investment programmes.

2.7.8.4. Guiding investments into an energy efficient public building stock

(a) Examples of assistance to facilitate the use of energy performance contracts include: (i) contract market facilitators; (ii) a framework contract to simplify contract procurement (UK); (iii) practical guides on energy performance contracting; (iv) projects such as TRUST-EPC-South, which set up a standardised approach allowing for the risk assessment and benchmarking of energy efficiency investments on an established real-estate assessment tool (Green Rating™); and (v) the GuarantEE project (136), which aims to broaden innovative business and financing models for performance-based ESCO projects, addressing more complex environments, e.g. by making energy performance contracting more flexible so as to serve private-sector clients better or addressing rented facilities in 14 European countries.

(b) Examples of initiatives to use energy performance contracts and ESCOs for the renovation of public buildings include: (i) RE:FIT (UK) (137); (ii) EoL (Slovenia) (138); (iii) 2020TOGETHER (Italy) (139); (iv) PRODESA (Greece) (140); and (v) RenoWatt (Belgium) (a partner of the H2020 Citynvest project) (141).

2.7.8.5. Accessible and transparent advisory tools

(a) Examples of the ‘one-stop shop’ approach or integrated service for the energy renovation of buildings include: (i) Energie Posit'If (France) (142) for the refurbishment of condominiums; (ii) Picardie Pass Rénovation (143) and Oktave (144) (France) for the deep renovation of detached houses; and (iii) REFURB (145), REIMARKT (Netherlands) and the BetterHome initiative (Denmark) for building refurbishment.

The Innovate (146) project has carried out an analysis (147) of some of the best pilot models in Europe and the services they offer to homeowners.

(b) Member States can set up national sustainable energy investment platforms (e.g. ENERINVEST (Spain) (148)) to: (i) organise dialogue with and between key stakeholders; (ii) develop roadmaps; (iii) propose improvements to legal frameworks; and (iv) develop and validate template documents and contracts, etc., to improve understanding of the market.

(c) General advisory services (e.g. FI-Compass (149), the European Investment Advisory Hub) can be set up and technical guidance can be produced on financing the energy renovation of buildings with Cohesion Policy funding (150).

(d) Smart Finance for Smart Buildings includes several Union-level initiatives to help Member States set up, and facilitate access to, appropriate mechanisms to support the mobilisation of investments in building renovation: (i) Sustainable Energy Investments Forums initiative (151); (ii) the ManagEnergy initiative (152); (iii) European Local ENergy Assistance (ELENA) (153); (iv) Horizon 2020: financing energy efficiency calls (154); and (v) general advisory services, e.g. FI-Compass (155), the European Investment Advisory Hub (156).

2.7.9. Indicators and milestones

The renovation strategy impact framework being developed by Build Upon (157) may be helpful in illustrating how an integrated set of targets, milestones and indicators can frame an LTRS (158).

2.7.10. Public consultation

In developing policy and legislation, the Commission relies on a transparent process involving stakeholders (e.g. businesses, public administrations and researchers) and the general public. Its guidelines may be useful for Member States conducting their own consultations (159).

The EPBD requirements for consultation on the LTRS (in particular on its development) do not override any existing national obligations. Implementation of the EPBD will rely to a great extent on local initiatives and private financing, so civil society, local governments and the financial and investment sectors will play a valuable role, as will the building and construction industries. The EPBD also requires that Member States consult in an inclusive way during the implementation of the strategy.

The following broad principles, which are adapted from the UK government's guidance on consultation (and presuppose a questionnaire-based approach) (160), could be useful in the context of public consultation on the LTRSs and for monitoring their implementation (161):

(a) Consultations should be clear and concise Be clear what questions you are asking and limit the number of questions to those that are necessary. Make them easy to understand and easy to answer. Avoid lengthy documents.

(b) Consultations should have a purpose Take responses into account when taking policy forward. Consult on policies or implementation plans when their development is at a formative stage. Do not ask questions about issues on which you already have a final view.

(c) Consultations should be informative Give enough information to ensure that those consulted understand the issues and can give informed responses. Where possible, include validated impact assessments of the costs and benefits of the options under consideration.

(d) Consultations are only part of a process Consider whether informal iterative consultation is appropriate, using new digital tools and open, collaborative approaches. Consultation is not just about formal documents and responses. It is an ongoing process.

(e) Consultations should last for a proportionate amount of time The length of the consultation should reflect the nature and impact of the propo