Green package - possition paper
Aktualizováno: 4. 9. 2019
Strategy - there is no discrepancy with strategy, milestones etc. It´s a political question and the trackto decarbonization is right. What should be discussed is a share of renewable energy because decarbonization still contains gas and atom where first one presents a dependency on imports from the third World. What I understand as problematic in the strategy are concrete measurements in relation to the end consumer. A goal of EPBD should be mainly solved at a state´s level by policy of energy sources. The current experience of EPBD shows problematic results on the side of consumers.
First of all it is evident that we must distinguish some parameters between renovations and new buildings. Old buildings can´t tackle the strong requirements existing today and financial support on principle - the more reductions the more money - causing much harm on existing building stock. The possibility of the “holistic” approaches stay at a theoretical level and from new EPBD amendments I don’t see that it could change. Such assessments are not clearly defined, expensive, too complex and if not forced by-law, than useless for the public investor. These assessments for renovations are hardly applicable because renovated buildings have been “non-holisticaly” already proposed in past and just “hard” isolation usually stays as one solution. With new buildings it is different situation however problems with complexity of holistic approach stays the same. Because in the amendments I don´t see any provision which could provide some “elasticity” but flatly applied measurements without any diversification, it is problematic support the law. References concerning the possibility to use an LCA or any other holistic approach are just formal and in practice won´t find larger application. For such an ambitious strategy we should first define applicable and available methodology. That could be a real improvement of the law. On the contrary, targeting measurements are now more or less cosmetic. It goes by the way of control, raising obligatory provisions, cost for new technology, project and service but without the possibility to substantially hit consumption. Moreover, beside harms to the cultural environment, it has an obstructive potential to frustrate public in terms of sustainability.
Following selection of concrete provisions :
The validation of EPC credibility - how it will be done – to measure consumption after some period of operation? By whom it will be validated, by on-line energy provider or another special
assessment? Could validation be influenced by consumer´s behavior for the period of exercise?
Gathering of harmonized EPC´s metrics data – for what purpose ? To compare countries among
themselves is problematic. There are different norms of indoor heating, diverse customs to heat
indoor, various outdoor conditions and construction customs.
Smartness index – Requirements to be connected to the smart grid will be solved over time by
proper technical requirements because smart grid is inevitable due to diversity of energy sources. Smart overview and monitoring of consumer´s consumption of energy can´t be obligatory. It is available already today and there is not a remarkable demand for that solution because of price, complexity and mainly the nature of humans prefering some conformity ahead of energy monitoring. Current experience of buildings equipped by smart regulation and on-line management is problematic when any small problem at HVAC system can´t be solved on site by operation manager.
Renovation passport –Maybe some facilitation of building management but it is problematic to
agree with any kind of mandatory by-law. Otherwise – by whom it will be checked, how complex and what data will be there? Changes of existing buildings are done by a project which is complex documentation and usually approved by the building authority. Emphasis on digitalism by ACE – in terms of BIM – should cause BIM to become mandatory by different means what is not ACE´s BIM policy
Electro-mobility – however in one recital we support the technology neutrality of buildings, but at
another recital we agree with the Council´s opinion concerning obligatory charging for parking
places. Today is not clear whether electro-mobility is such a green solution as is promoted. The
impact of mining and fracking of lithium, cadmium and other externalities must be taken into
account. We should stay just at a technology neutral position. Experience with wrong predictions
presented for example by yellow fields should be a warning.