Energy Performance of Buildings Directive (EPBD): Contribution to the EC Roadmap

As an association active in the liquid heating fuels industry, we would like first to remind the many benefits they bring: easy to store and easy to transport, they have a high energy density, which means they are very efficient, and an excellent supply infrastructure. They are necessary for 20 million households in Europe, often in off-grid areas with limited options for heating. Liquid fuels are more than conventional fossil fuels like heating oil. They also include the new generation of renewable and/or low-carbon liquid products.

Our approach proposes to switch to a condensing boiler, with an hybrid system, lowering significantly the consumption of liquid fuel (thus reducing the greenhouse gas emissions), while avoiding major renovation work. At a later stage, incorporating low-carbon liquid fuels progressively will ensure a smooth transition for these households, in line with the EU 2050 climate target. As such, consumers increase their energy performance while keeping the renovation work affordable.

Consumers should be able to decide between the widest range of options possible, adopting a technology-open approach. We therefore strongly encourage the European Commission to carefully assess in its preparatory work the following elements:

  • The impact of banning existing technologies that will support the deployment of carbon-neutral liquid fuels in the near future, and in particular in relation to alleviating energy poverty;
  • The contribution of carbon-neutral liquid fuels to the EU decarbonization objectives, in addition to other solutions.

We believe that a phased approach to the likely introduction of mandatory minimum energy performance standards for different types of buildings will be critical to ensure social acceptance. We support future initiatives that will facilitate regular upgrades of obsolete and/or inefficient heating systems. Given the high costs of buildings refurbishment, such upgrades often constitute at the time being the first and sometimes only affordable step towards increased energy efficiency for EU consumers.

EU/Governments need to understand the role and benefit that new low carbon liquid fuel can play in reducing emissions from heating using current infrastructure and at low cost to the consumer which should be a key element to considered.  We therefore would strongly advise against banning specific types of appliances. Unlocking fiscal and policy incentives, together with private investments will allow the necessary upgrades to happen. The gains will go beyond decarbonisation, contributing to put energy poverty at bay.