Assessment of European and national policies related to energy ...

ENERGY EFFICIENCY FOR EU HISTORIC DISTRICTS SUSTAINABILITY

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Deliverable D1.3:

Assessment of European and national policies relate d to

energy efficiency and heritage conservation

Responsible Beneficiary

NTNU

Version – Date A05 – 28.05.2013

Related Work Package

Related Task

WP 1: European building and urban stock structured categorization and multiscale data management model T 1.3 Identification and evaluation of European and national policies and legislation related to energy efficiency and cultural heritage conservation

Level of Dissemination

Due Submission Date

PP

31/05/2013

Grant Agreement Number: 314678

Project Acronym: EFFESUS

Project Title: Energy Efficiency for EU Historic Districts Sustainability

Funding Scheme: Collaborative Project

Start Date of Project:

Date of latest version of Annex I:

01.09.2012

29.08.2012

Project website address: www.effesus.eu

Project funded by the European Commission under the 7th Framework Programme -

Cooperation Programme.

EFFESUS D1.3: Assessment of European and national policies related to energy efficiency and heritage

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Document History

Version Date Aut hors Notes

A01 30.04.2013 Michael Kahn, NTNU, Dennis Rodwell Sonja Jurosevic, NTNU

chapter on Conventions and Charter

Questionnaire

A02 22.05.2013 Michael Kahn, NTNU, Dennis Rodwell Sonja Jurosevic, NTNU

chapter on Conventions and Charter

Questionnaire

A03 23.05.2013 Alessandra Gandini, TECNALIA review and comments

A04 27.05.2013 Michael Kahn, NTNU revision

A05 28.05.2013 Claudia Schindler, FRAUNHOFER final review

Approved on behalf of Fraunhofer as EFFESUS Scienti fic and Technical Coordinator

Name: Britta von Rettberg

Organisation: Fraunhofer-Institut für Bauphysik

Date: 28.05.2013

Signature:

Approved on behalf of Tecnalia as EFFESUS Project C oordinator

Name: Isabel Rodriguez-Maribona

Organisation: TECNALIA

Date: 29.05.2013

Signature:

This document is property of EFFESUS Consortium. It might not be copied, reproduced, or modified in the whole or in the part for any

purpose without written permission of EFFESUS Coordinator, with acceptance of the Project Consortium. This report was completed with

the support of the European Commission under the 7th Framework Programme. The contents do not necessarily reflect the Commission’s

own position. This report is made on behalf of Tecnalia. By receiving the report and acting on it, the client - or any third party relying on it -

accepts that no individual is personally liable in contract, tort or breach of statutory duty (including negligence).


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Contents

1 Summary 5

2 Objectives 6

3 Achievements 7

3.1 Method 7

3.2 Overview 7

3.3 Previous relevant studies 13

4 International level 14

4.1 2012 Memorandum “Urban Energies – Urban Challenges” 14

4.2 2011 ICOMOS Valletta Principles for the Safeguarding and Management of Historic Cities, Towns

and Urban Areas 15

4.3 2011 UNESCO Recommendation on the Historic Urban Landscape 15

4.4 2011 Freiburg Charter for Sustainable Urbanism 15

4.5 2011 INTBAU TAG Queen Square Statement (International Network for Traditional Building

Architecture and Urbanism (INTBAU) and the Traditional Architecture Group (TAG) 15

4.6 2010 Cottbus Charta (European Architecture Dialogue) 16

4.7 2010 Toledo Declaration on Urban Development (under the Spanish Presidency of the Council of the

European Union) 16

4.8 2008 Verona Declaration for an Integrated Revitalisation of Historic Centres 16

4.9 2007 Leipzig Charter on Sustainable European Cities (European Union) 16

5 European legislation (EPBD) 17

5.1 Background – the need for an overarching legislation and the need for control of energy consumption

in the building sector 17

5.2 Legislative developments 17

5.2.1 EU EPBD2002/91 17

5.2.2 Current legislations – de lege late The Directive2010/31 (EPBD2010) 18

5.3 The requirements of existing buildings 18

5.4 The requirements of historic buildings and environments 19

5.4.1 Energy performance certification 20

5.4.2 Methodology framework 20

5.5 Conclusions 21

6 National legislations: European countries national legislation requirements for minimum energy

performance in historic buildings and historic environments 23

6.1 Systematized overview 23


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6.1.1 FRANCE 23

6.1.2 GREECE 25

6.1.3 HUNGARY 29

6.1.4 ITALY 33

6.1.5 REPUBLIC OF IRELAND (ROI), EXCLUDING NORTHERN IRELAND (NI), WHICH APPLIES AND

ADOPTS UK LEGISLATION. 36

6.1.6 NETHERLANDS 40

6.1.7 NORWAY 42

6.1.8 PORTUGAL 46

6.1.9 SPAIN 49

6.1.10 SWEDEN 52

6.1.11 TURKEY 55

6.1.12 UNITED KINGDOM OF BRITAIN AND NORTHERN IRELAND (UK) 58

6.2 Conflicts and Policy 62

6.2.1 Conflicts area 62

6.2.2 Finance situations 64

6.2.3 Compilation of the country's main practices and policies 65

7 Conclusion and Recommendations 72

8 Appendix A 73

8.1 Section 1: Blank questionnaire 74

8.2 Section 2: Completed questionnaire from participating country 80

8.3 Section 3: EU No 244/2012: Cost-optimal methodology framework 223

8.4 Section 4: 3encult 2011: Suggestions on energy performance calculations for historic buildings 252


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1 Summary

As part of the commitment of meeting EU targets for the reduction of CO2 emissions, EFFESUS (Energy

Efficiency for EU Historic Districts' Sustainability) is a four-year European Union research project addressing

the energy efficiency of individual buildings, buildings ensembles and districts, as well as their energy supply

from renewable sources.

This deliverable establishes an overview of the legal status and policies on an International, European and

national level, in situations where energy performance requirements are applied to historic buildings, groups of

buildings and urban districts, for the purposes of improving their energy efficiency and facilitating energy supply

from renewable sources. In particular, the effect of the EPB Directive on the national legislation is examined,

and whether there are any legal conflicts.

Cultural heritage conservation is a cross-disciplinary field which is affected by numerous legal regulations at the

regional, national and European level. Sometimes ideal legal requirements in one field may be detrimental to

cultural heritage values. This is especially true regarding energy efficiency. It is therefore of great importance to

get an overview of possible conflicts between different legal systems.

In the efforts of providing an overview of national legislation, the main source of collecting data was through the

use of a questionnaire. The data from participating countries are compared and systematized, in order to

provide an overview of the legal landscape in Europe relating to the energy requirements of historic buildings

and environments.

This deliverable gives an overview of relevant documents at international level, European previous directives

and a description of current legal situation, as well as a more detailed description of each country's national

legislation and policies.


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2 Objectives

Deliverable D1.3 “Assessment of European and national policies related to energy efficiency and heritage

conservation” has been developed within the framework of Task 1.3 “Identification and evaluation of European

and national policies and legislation related to energy efficiency and cultural heritage conservation”.

The activities performed in Task 1.3 are collected and summarised in the present report. Main objective of WP1

is to develop a data model for the assessment and management of energy in historic cities and will be achieved

by the identification and collection of existing data (Task 1.1), the establishment of impact indicators (Task 1.2),

the evaluation of European and national policies (Task 1.3) and the development of a structured

characterization method (Task 1.4).

Task 1.3 aims at giving an overview of current European and national legislation related to cultural heritage and

energy efficiency, including charters at the international level (ICOMOS and conventions), EU directives and

national legal systems. The task defined the relationship between heritage legislation and energy efficiency

legislation and policies in order to encourage best practice solutions. The approach was based on the collection

of data from partners’ nations and EU and on the analysis of the possible legal/political contradictions/conflicts

with regard to goals/measures. The results have been structured as a part of the overall categorization.


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3 Achievements

3.1 Method

Desk based research was carried out when collecting information on International Conventions and Charters,

and European legislation. In the efforts of providing an overview of national legislation, the main source of

collecting data is through use of a questionnaire. (Appendix: Section 1). Cross-national questionnaires have a

number of potential sources of error, both for transmitter and receiver. To minimize sources of error, we have

chosen to put the data into the delivery as presented in the answers from the participants. It impairs the

readability, but it also reduces the sources of error.

The main topics of the questionnaire can be divided into five sections:

• Management and levels.

• National goals and achievements.

• National legal requirement for minimum energy performance in existing buildings, historic buildings and

historic environments.

• Stimulating measures.

• Possible contradictions and conflicts.

3.2 Overview

The table below summarizes the responses received from the participating countries. The answers are based

on a questionnaire. The entirely questionnaire and answers is enclosed in Appendix, section 2.

The table shows a fairly uniform national legislation and practice in the countries that participated. The main

trend is that officially protected buildings and environments are excluded from the requirements, but that the

requirements are fully applicable to historic buildings and environments that are not officially protected. Some

countries points to the possibility of special adaptations for non-official protected historic buildings and

environments, and it is natural to assume that these decisions will be made after discretion, which presumably

results in varying practices in different parts of the country.

There are different practices related to when the requirements take effect; but all participants relate it to the

physical changes or changes in use.

When the requirement of energy efficiency measures are applied to historic buildings and environments the

participants points to some specific measures that would often be in direct conflict with the historical and

architectural values in buildings. Problematic areas are particularly window replacements and thermal insulation

measures.

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Official goals and achievements

Do the requirements apply for official protected historic buildings or environments

Do the requirements apply for non - official protected historic buildings or environments

Requirements apply when

Methodology Conflicts

France Reduce more than 38% the energy consumption in 2020. Reduce the energy need to 150 kWh/m²/year.

No. All buildings pre 1948 is exempt from requirements

Yes, exempted all buildings pre 1948.

- - Solar panels on the roofs. Replacing windows.

Greece 20% on final energy consumption in 2020. Achievement through taxes and other economic instruments.

No Yes, as long as it do not result in altering their characteristics or appearance in an unacceptable manner.

Renovation requires a building permit.

Under the provision of article 5 of KENAK, the methodology applied for the assessment of buildings’ energy performance is a quasi-steady monthly method in line with European Standards EN ISO 13790 (2009)

On management level

Hungary 20% on final energy consumption in 2020. Achievement through economic instruments and programs.

No Yes, if the renovation is considered significant.

Significant renovation

Decree of Minister without Portfolio No. 7/2006 based on the EPBD.

Using insulating plastering, instead of thermal insulation board. Repair of windows and LOW-E glazing, instead of window-replacement,

Instead of window-replacement, insulating glazing of inner sash,

Upper insulation of the topmost slab,

Thermal insulation is not enough, care must be taken to the waterproofing and humidity.

Italy Reduction of the 13% of Co2 emissions and the production of the 17% of energy with renewable energies sources within 2020. Achievement through legislation based on EPBD

No, not compulsorily subjected to any energy standards

Yes Major renovation for buildings with a surface >1000 m2

The UNITS 11300 define the methodology for the calculation of the minimum energy performances

Use of external insulation. Use of internal insulation for painted walls


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Ireland 20% reduction in energy use until 2020 with the public sector trying to achieve 33%. Achievement through legal and economic instruments. Programs.

No Yes, but may be exempted if necessary in order to preserve the architectural integrity of the particular building

All building works, which imply material alterations or material, or change of use

Dwelling Energy Assessment Procedure (DEAP). Calculation framework is based on IS EN 13790

Windows and doors, roof and façade features

Netherland - No, retrofitting must be approved by the local heritage authority.

Yes New buildings or existing building if owner agree

Calculation of overall energy loss through building envelope, energy use-gain by installations, standard user behaviour – climate.

Implementation of EPBD 2010 is difficult because it harms other legal rights that are set in connection with buildings and its owner.

Norway Passive house level by 2015

Zero. energy house by 2020. Achievement through legal and economic instruments.

No Yes, but it must be done in a way that preserve the architectural integrity of the particular building, as long as it do not represents a disproportionate costs.

All changes in buildings defined as "measures" except normal maintenance. When Major renovation, the hole building must meet the requirements.

NS 3031. The standard includes three calculation options:

Month calculation (stationary method) according to EN ISO 13790;

Simplified time calculation (dynamic method) according to EN ISO 13790;

Detailed calculation programs (dynamic method) validated according to EN 15265.

Insolation, density, ventilation. The main directions when it comes to ventilation, construction, etc. are based on modern technology. Older builds technical solutions and building characteristics are not used. This leads to actions with greater impact on valuable historic building parts than necessary.

Portugal Annual energy savings of at least 1% by the year 2016. Achievement through Energy Performance Certification scheme

No Yes, as long as it is not incompatibilities

Major refurbishment or alteration whose cost exceeds 25% of the building, based on a reference value per square meter of building typology

http://dre.pt/pdf1sdip/2006/04/067A00/24682513.PDF

The main concern of energy efficient measures applied to cultural heritage deal with aesthetics and ease/possibility of installation.


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Spain Ensure the reduction of emissions. Achievement through economic instruments and national plans.

No No - DB HE Energy Saving -

Sweden 40% reduction in greenhouse gas emissions, 50 percent renewable energy, 20 percent energy efficiency. Achievement through taxes and other economic instruments.

No, only if it can be done without altered it in an unacceptably way

Yes, non-protected cultural buildings and environments is not being acknowledged.

Significant change of use or that the building have a significantly extended service life

SS-EN ISO 13789:2007 (W/m2K) Thermal performance of buildings -Värmegenomgångskoefficienter –calculation BBR chapter 9:12, see 9a.

The heritage management, on all levels, is not invited in early stages of the process. Exchanging instead of maintaining. Materials that are “free of maintaining” has been a common request – people do not want to put time into maintaining and producers are trying to sell such products.

Turkey Reduce energy density 15 % by 2020, reducing electrical energy density min. 20 % by 2023

To increase the number of countrywide qualified/certified energy mangers, consulting firms and novel design and/or product based on domestic R&D results regarding energy efficiency and renewable energy resources. Achievement through economic instruments, restriction of sale of products which are not energy efficient, plans and communication.

Yes, if external appearance is not affected

Yes, if external appearance is not affected

Consolidation, liberation, reintegration, renovation, reconstruction, changed use and moving. Substantial repair of existing buildings must meet TSE 825 energy requirements

TS 825 Even though energy performance legislation came into force in Turkey, there are not many implementations concerning heritage protection and energy efficiency.


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UK Reduction of greenhouse gas emissions by 2020 and 2050 against a baseline of 1990 levels.

UK, targets are set as 34% for 2020 and 80% for 2050.

Scotland, targets are set as 42% for 2020. Achievement through legal and economic instruments.

Yes. However, for historic and traditional buildings, meeting building-regulation requirements must only be met as far as is reasonably practical.

Exception of buildings heritage-designated as scheduled monuments.

Yes. However, for historic and traditional buildings, meeting building-regulation requirements must only be met as far as is reasonably practical.

Exception of buildings heritage-designated as scheduled monuments.

When altered, extended or converted as far as is reasonably practical

RdSAP1 Over-cladding of the exterior of a building with external wall insulation is often considered unacceptable in the case of historic buildings. Installing double glazing is a contentious issue for aesthetic reasons and because of the loss of original window frames and glass.

Table 1: Summary of national legislation and policy

1 The exact procedure on how to use the legal methodologies varies between England, Northern Ireland, Scotland and Wales.


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The participating countries have initiated a number of measures to increase the stimulation of energy efficiency

measures in buildings and environments. This applies to both the financial and legal instruments and programs.

Only a few of these seem to be directly aimed at energy efficiency in historic buildings and environments. All

participants have introduced certificates as a tool.

direct subsidies

/ funding advantages /

disadvantages

through

taxation?

attractive

financing information

energy

performance

certificate

technical

assistance and

advice?

France - Yes Yes Yes Yes Yes Greece Yes - - Yes Yes Yes Hungary Yes Yes - - Yes - Italy - Yes - - Yes - Ireland Yes - - Yes Yes Yes Netherland - Yes - - Yes Yes Norway Yes - - Yes Yes Yes Portugal - - - Yes Yes Yes Spain Yes - - Yes Yes Yes Sweden Yes Yes Yes Yes Yes Yes Turkey Yes Yes Yes Yes Yes Yes UK Yes Yes2 Yes Yes Yes Yes

Table 2: national measures to stimulate energy perf ormance in historic buildings and environments

European level

The central European framework on this subject is Directive 2010/31/EU OF THE EUROPEAN PARLIAMENT

AND OF THE COUNCIL of 19 May 2010 on the energy performance of buildings (recast) (EPBD2010).

The Directive states that minimum energy requirements shall apply for all existing and new buildings, and that

this should apply when the existing building undergoes major renovation, in the sense of an energy

performance upgraded so that they satisfy the minimum requirements. Basically, this shall apply to all existing

buildings, but there are exceptions. In this context, the interesting exception is officially protected buildings as

part of a designated environment or because of their special architectural or historical merit. But the exception

applies only as long as energy saving measures cannot be implemented without unacceptably alter their

character or appearance. There is no specific protection level associated with the expression “officially

protected”. This means that it is not restricted to typically listed buildings, but also to buildings protected at a

lower level, e.g. by planning legislations.

Either way, the most central in the exception seems to be related to the expression officially protected buildings.

EU law makes a clear distinction between officially protected buildings or environments and non-officially

protected buildings or environments, where non-officially protected buildings or environments in principle shall

be treated equally with all other existing buildings and environments, when it comes to requirements for energy

efficiency. This concept is implemented in the guidance document “Cost-optimal methodology framework”.

2 No advantage for energy-efficiency retrofit; advantages for replacing existing building stock through newly constructed buildings by VAT

exemption for the latter, but not for the repair of existing buildings


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3.3 Previous relevant studies

There are a few relevant studies within the topic. From recent years, the most relevant are:

1. From the Baltic Sea Project (2007-2013): The Situation of Climate Protection and Culture

Heritage, Baseline study of Work Package 3 Policy Development, by Therese Sonehag,

Swedish National Heritage Board, Visby 2012 (Co2olbricks)

2. From the project Sustainable Historic Towns Urban Heritage – Good fo r the Climate! :

PROJECT REPORT 2011-2012, Dag Arne Reinar and Frederica Miller (Editors)

3. From the project Thresholds related to renovation of buildings , (SBi 2009:2) EPBD

definitions and rules, Kirsten Engelund Thomsen, SBi, Kim B. Wittchen, SBi, Hans Erhorn,

Fraunhofer-IBP, Heike Erhorn-Kluttig, Fraunhofer-IBP

The aforementioned studies examine the requirements of energy-saving measures in historic buildings in

different ways, but they have in common, that they used questionnaires for collecting data.

The most relevant for this project are the work done in Co2olbricks. It is pointed out four major findings of

interest in the Co2olbricks report:

- The connection between energy and cultural heritage could and should be clarified more

- There is a lack of knowledge and competence in dealing with energy efficiency in historic buildings

- The effect of building regulations on cultural heritage needs to be discussed

- There is a lack of internal communication in the national authorities regarding subsidies. Sonehag

(2012): 67-68).


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4 International level

The relevant documents as discussed below are set out in reverse chronological order, thereby prioritising the

latest thinking in what is a fast moving field with a current dearth of relevant texts.

4.1 2012 Memorandum “Urban Energies – Urban Challen ges” 3

This Memorandum, the outcome of a conference organised by the German Federal Ministry of Transport,

Building and Urban Development, in Berlin, October 2012, refers to the 2007 Leipzig Charter (see below) and

specifically notes the increased seriousness of climate change and its impacts together with the approaching

end of cheap fossil fuel energy. It states the major strategic task for the future to be the local and regional

implementation of energy transition, and the need to integrate greater energy efficiency and the use of

renewable energies into urban development strategies.

‘European cities provide good conditions to address these challenges. Cityscapes, public spaces, streets,

green spaces and buildings offer a sense of local identity and homebuilding in times of accelerated

globalisation. Their respective singularity must be considered. Thanks to their architectural and social qualities,

cities can make a significant contribution to the implementation of the energy transition.’

The Memorandum sets out four key tasks for sustainable urban development: the cautious ecological renewal

of buildings and neighbourhoods; the technological regeneration of urban infrastructures; developing a new

mobility; and social integration.

The ‘renovation and energetic retrofitting of housing buildings are […] more important than good new building.

[…] The key to a successful energy transition is the overall efficiency at neighbourhood and metropolitan level.

In addition to energy efficiency and using renewable energies, an innovative mix of sustainable, low-CO2

energy production, consumption, storage capacity and input is also essential. […] Our cities can remain fit for

the future with a need-driven adaptation of existing, and by developing new, urban utilities infrastructure

systems. This requires considerable investment, especially in developing local renewable energy production

systems. A considerable effort is needed to find suitable locations as well as a good design for these renewable

energy systems. The use of modern technology allows for a multidisciplinary optimization and linking of energy

and mobility systems. Intelligent systems and net-works can improve urban life.’

This is a useful document for setting out wide-ranging principles for the sustainable city of the future, including

priorities for historic districts of direct relevance to EFFESUS.

3 http://www.nationale-stadtentwicklungspolitik.de/cln_032/nn_1185612/Content/__Anlagen/memorandum__en,templateId=raw,property=publicationFile.pdf/memorandum_en.pdf


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4.2 2011 ICOMOS Valletta Principles for the Safegua rding and Management of

Historic Cities, Towns and Urban Areas 4

This document was conceived as an updating of the 1987 ICOMOS Washington Charter (see below). Its

principal distinction from that earlier document is to acknowledge such terms as ‘urban ecosystem’ and

‘sustainable development’, and the inclusion of a section on energy saving:

‘All interventions in historic towns and urban areas, while respecting historic heritage characteristics, should

aim to improve energy efficiency and to reduce pollutants. The use of renewable energy resources should be

enhanced. Any new construction in historic areas must be energy efficient. Urban green spaces, green

corridors and other measures should be adopted to avoid urban heat islands.’

4.3 2011 UNESCO Recommendation on the Historic Urba n Landscape 5

This Recommendation addresses new challenges to the management of urban heritage, but although it notes

vulnerability to the impacts of climate change and an increasing risk of climate-related disasters, it refers only

generally to:

‘Concern for the environment, in particular for water and energy consumption, calls for approaches and new

models for urban living, based on ecologically sensitive policies and practices aimed at strengthening

sustainability and the quality of urban life.’

4.4 2011 Freiburg Charter for Sustainable Urbanism

The City of Freiburg im Breisgau in South West Germany has been at the forefront of research in the fields of

renewable energy and in marketing these achievements. Actions within the city have been focused in new

districts, such as Vauban, rather than the historic districts. The historic city centre, in any event, is in effect a

post-war reconstruction and therefore falls outside the pre-1945 EFFESUS date limit.

4.5 2011 INTBAU TAG Queen Square Statement (Interna tional Network for Traditional

Building Architecture and Urbanism (INTBAU) and the Traditional Architecture Group

(TAG) 6

This Statement contains the following:

‘The efficient use of energy, raw materials and water are major challenges for the future of mankind. All

avenues of research and understanding should be investigated to this end. These will include scientific,

economic and social studies. An understanding of the techniques, practices and living patterns of periods

before energy became easily available can make a significant contribution to the advancement of energy

conservation today.’

4 http://www.international.icomos.org/Paris2011/GA2011_CIVVIH_text_EN_FR_final_20120110.pdf 5 http://portal.unesco.org/en/ev.php-URL_ID=48857&URL_DO=DO_TOPIC&URL_SECTION=201.html 6 http://www.intbau.org/academia/160-queensquarestatement.html


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4.6 2010 Cottbus Charta (European Architecture Dial ogue) 7

Forming part of a postgraduate research project into the European City, it simply makes passing reference to

ecological sustainability. Neither climate nor energy feature in this Charta. This document is not strictly a

Conservation document, but is included here to illustrate the degree to which climate and energy issues are not

part of mainstream architectural and urban teaching.

4.7 2010 Toledo Declaration on Urban Development (u nder the Spanish Presidency

of the Council of the European Union) 8

Described, inter alia, as the ‘Toledo reference document on integrated urban regeneration and its strategic

potential for a smarter, more sustainable and socially inclusive urban development in Europe’, the Declaration

includes a number of general references to climate change, preserving natural resources, eco-efficiency and

urban recycling.

Specifically, it reads: ‘Taking the environmental dimension first, metropolitan areas, cities and towns are key

actors for global sustainability and more specifically to combat climate change, since they are the places where

most of the resources consumption (both materials and energy) and the production of waste and emissions

(including, most significantly, greenhouse gases) are concentrated. To solve the equation of urban

sustainability, and taking into account that the Europe 2020 goals include reducing greenhouse gases by at

least 20% compared with the 1990 levels (or by 30% if the conditions are suitable), increasing the percentage

of renewable-energy sources in our final energy consumption by up to 20%, and energy efficiency also by 20%,

the eco-efficiency of the new urban developments (for example, by means of developing new ‘eco-

neighbourhoods’) is a necessary condition, but it is not enough.

The core battle for urban sustainability will lie in achieving the maximum possible eco-efficiency in the existing

urban fabrics of cities.

4.8 2008 Verona Declaration for an Integrated Revit alisation of Historic Centres

(INTERREG IIIB CADSES)9

This Declaration refers to a sustainable Europe and sustainable development but does not mention either

climate or energy.

4.9 2007 Leipzig Charter on Sustainable European Ci ties (European Union) 10

An important document of its time in the context of integrated urban development, including urban conservation

and upgrading urban environments, in the context of EFFESUS it was in effect superseded by the 2012

Memorandum “Urban Energies – Urban Challenges” referred to above.

7 http://www.architecture-dialogue.eu/charta.htm 8 http://www.mdrt.ro/userfiles/declaratie_Toledo_en.pdf 9 http://www.slideshare.net/nichr/hist-urban-declaration-en-200804

10 http://www.bmvbs.de/cae/servlet/contentblob/31234/publicationFile/10973/leipzig-charter-on-sustainable-

european-cities-agreed-on-24-may-2007.pdf


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5 European legislation (EPBD)

This chapter gives an overview of previous Directives and a description of current legal situation (de lege lata).

Directive 2010/31/EU OF THE EUROPEAN PARLIAMENT AND CONCIL of 19 May 2010 on the energy

performance of buildings (recast) will form the main theme of the chapter (EPBD2010).

5.1 Background – the need for an overarching legisl ation and the need for control of

energy consumption in the building sector

The building sector represents 40% of the European Union’s total energy consumption and is responsible for

36% of the European Union’s total CO2 emissions. Reducing energy consumption in this area is therefore a

priority. There was a need to develop guidelines and requirements that would form a common European

practice. (http://europa.eu/legislation, Official website of the European Union) A basis for the requirement of

reducing emissions can also be found in the on-going negotiations in the Kyoto Protocols, which aims to reduce

global greenhouse gases by 5%. At the United Nations Climate Change Conference in Durham in 2011, most

nations agreed to extend the agreement until 2017 and that a roadmap of measures would come into force by

2020.

5.2 Legislative developments

5.2.1 EU EPBD2002/91

The Directive was a follow-up to the measures on boilers (92/42/EEC), construction products (89/106/EEC) and

SAVE programme provisions on buildings. (http://europa.eu/legislation, Official website of the European Union)

The four key points of the Directive are:

- a common methodology for calculating the integrated energy performance of buildings;

- introduction of a minimum standards on the energy performance both of new and existing buildings

participants;

- systems for the energy certification as a tool.

The common calculation methodology was supposed to include all the aspects which determine energy

efficiency and not just the energetic performance of the building envelope.

It was necessary to take steps to simplify Directive 2002/91/EC on the energy performance of buildings, which

constitutes the current legal framework, whilst leaving some autonomy to Member States to act in this area.

The European Commission proposes that the 1000 m² threshold for existing buildings when they undergo

major renovation is eliminated and that the requirements concerning energy performance be applied to a larger

number of buildings. (http://europa.eu/legislation, Official website of the European Union)


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5.2.2 Current legislations – de lege late The Direc tive2010/31 (EPBD2010) 11

As a result of developments in the United Nations Climate Change Conference, the European Council 2007

emphasised the need to increase energy efficiency in the Union so as to achieve the objective of reducing by

20 % the Union’s energy consumption by 2020. In this context, it was developed ‘Action plan for energy

efficiency: realising the potential’. The action plan identified the significant potential for cost-effective energy

savings in the buildings sector. The European Parliament, in its resolution of 31 January 2008, called for the

strengthening of the provisions of Directive 2002/91/EC. (EPBD2010 no. 5). The action plan expressed the

overall objectives for the Directive and the individual provisions should guide the national legislation in the

European countries to reach the goal. Another goal was to get the corresponding legislation in Europe. It was

necessary to lay down more concrete actions with a view to achieving the great unrealised potential for energy

savings in buildings and reducing the large differences between Member States’ results in this sector

(EPBD2010 no 5).

5.3 The requirements of existing buildings

The requirements is stated in EPBD2010 article 3 no 1

“Member States shall take the necessary measures to ensure that minimum energy performance requirements

for buildings or building units are set with a view to achieving cost-optimal levels. The energy performance shall

be calculated in accordance with the methodology referred to in Article 3. Cost-optimal levels shall be

calculated in accordance with the comparative methodology framework referred to in Article 5 once the

framework is in place.”

Energy performance is defined in article 2 as “the calculated or measured amount of energy needed to meet

the energy demand associated with a typical use of the building, which includes, inter alia, energy used for

heating, cooling, ventilation, hot water and lighting”. The requirements will apply in basically all existing

buildings when the buildings undergo major renovation. The energy performance of the building or the

renovated part will in these cases be upgraded in order to meet minimum energy performance requirements,

set in accordance with Article 4 in so far as this is technically, functionally and economically feasible. Those

requirements shall be applied to the renovated building or building unit as a whole. Additionally or alternatively,

requirements may be applied to the renovated building elements. EN L 153/20 Official Journal of the European

Union 18.6.2010 (EPBD2010 article 7).

It was of great importance to have minor exceptions to meet the goals. But Member States may decide not to

set or apply the requirements of buildings:

“(a) buildings officially protected as part of a designated environment or because of their special architectural or

historical merit, in so far as compliance with certain minimum energy performance requirements would

unacceptably alter their character or appearance”

11 The Directive is a follow-up to the EPBD2002/91 and measures on the energy certification of buildings (Directive 93/76/EEC repealed by

Directive 2006/23/32/EC).


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5.4 The requirements of historic buildings and envi ronments

The provision in EPBD2010 article 3 (2). Litre a and b. and the use of the word “officially protected” is a so

broad wording that interpretation can basically cover all types of protections, as long as national relevant

authorities perceive that they have mentioned qualities. There is no specific protection level associated with the

expression. This means that it is not restricted to typically listed buildings, but also to buildings protected at a

lower level, e.g. by planning legislations.

“Officially protected” would be any cases where a public body has limited the rights of property owner due to

historical or architectural values in the building. This can occur both at national, regional and local levels.

To impose ideal energy standards on "officially protected" buildings and environments would create conflict with

the imposition of protection on a legal scale. The measures would be contrary to the protection. As a

consequence the energy requirements cannot be applied in the interest of the culture heritage. In most cases

official protections have not taken into account modernization in terms of energy efficiency measures. The

protection will therefore represent a legal barrier to such measures as long as energy saving measures cannot

be implemented without unacceptably alter their character or appearance. For new established protections it

will be possible to take energy requirements into account and to resolve the conflict of interest between energy

saving measures and culture heritage directly in conservation provisions.

For non-officially protected buildings the picture is opposite in a legal perspective. There are no legal barriers

which prevent the application of energy requirements on such buildings, and they will therefore be treated as

buildings without particular historical or architectural values. The EPBD2010 applies in principle to all existing

buildings. Only those who have been legally designated to hold special qualities should be able to be excluded.

There are few documents which can assist in understanding the exemption, but it is natural to assume that the

idea has been to leave it up to each member state to give special nationally legislation, adapted to local

conditions. It is interesting to note that although a large part of the European building stock consists of buildings

and environments that can be classified as historical, in understanding pre 1945, it is not develop a clear set of

rules for dealing with physical interventions in this building stock.

3ENCULT have looked into the content and consequences of EPBD2010 for historic buildings and concludes

that:

“Except for the system inspections, Member States may decide not to apply the requirements listed above to

(among other things) “buildings officially protected as part of a designated environment or because of their

special architectural or historical merit, in so far as compliance with certain minimum energy performance

requirements would unacceptably alter their character or appearance” and “buildings used as places of worship

and for religious activities”.

For all minimum requirements goes that differentiation between new and existing buildings will take place and

they are only applied in so far as they are technically, functionally and economically feasible. Individual

countries/regions need to set the requirements based on calculated cost optimal levels». (Efficient ENergy for

EU Cultural Heritage (2011): WP 7 Design Tools & Quality Assurance, deliverable 7.7 by Marleen Spiekman,

TNO).


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5.4.1 Energy performance certification

An important tool to control the energy use in buildings is the system of energy certification of buildings. This

was already developed in the earlier EPBD 2002.

It is stated in EPBD2010 article 11, that all Member States shall implement a system for the energy

performance certification of buildings. The certificate must include information on the energy performance of a

building and recommendations for cost improvements. In article 2 no 12 ‘energy performance certificate’ is

defined as a certificate recognised by a Member State or by a legal person designated by it, which indicates the

energy performance of a building or building unit, calculated according to a methodology adopted in

accordance with Article 3.

The energy performance certificate must include the energy performance of a building and reference values

such as minimum energy performance requirements in order to make it possible for owners or tenants of the

building or building unit to compare and assess its energy performance. It shall include recommendations for

the cost-optimal or cost-effective improvement of the energy performance of a building or building unit.

It is a requirement that the certificate shall be made in connection with:

(a) buildings or building units which are constructed, sold or rented out to a new tenant; and

(b) buildings where a total useful floor area over 500 m² is occupied by a public authority and frequently visited

by the public. On 9 July 2015, this threshold of 500 m² shall be lowered to 250 m² (EPBD2010 article 12 no 1).

However, Member States may exclude officially protected buildings from the application of paragraphs 1, 2, 4

and 5 of this Article. (EPBD2010 article 12 no. 5). Certification is valid for other non-official historic buildings

and environments.

5.4.2 Methodology framework

The methodology framework specifies rules for comparing energy efficiency measures, measures incorporating

renewable energy sources and packages and variants of such measures, based on the primary energy

performance and the cost attributed to their implementation. It also lays down how to apply these rules to

selected reference buildings with the aim of identifying cost-optimal levels of minimum energy performance

requirements. (EU No 244/2012 article 1).

Appendix, Section 3: EU No 244/2012: Cost-optimal methodology framework

Appendix, Section 4: 3encult 2011: Suggestions on energy performance calculations for historic

buildings

Financing

The Directive has not specified which financial instrumented is to be used to stimulate energy efficiency

measures in buildings, and it has been up to the individual countries to find suitable instruments. On 18th April

2013 the Commission published a report on financial support for energy efficiency in buildings stressing that the

EU needs to improve the financial support in this sector if it wants to meet its 2020 and 2050 targets. The

Report is accompanied by a more detailed Staff Working Document and will be the basis for a discussion at the

Informal Energy Council on 22nd April.


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The 18.4.2013: REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE

COUNCIL Financial supports for energy efficiency in buildings are discussing the topic and concludes on page

10:

- “The situation differs significantly between Member States in terms of their building stock, the financial

support measures in place and the relevant market barriers;

- Although the investments in building energy efficiency are increasing and there are many best-practice

examples of instruments that are delivering cost-effective energy savings, there is only limited

information on the effectiveness of the different financial support measures, both at EU and national

levels;

- Important barriers that hamper further uptake of energy efficiency investments in buildings continue to be

in place, including a lack of awareness and expertise regarding energy efficiency financing on the part

of all actors; high initial costs, relatively long pay-back periods and (perceived) credit risk associated

with energy efficiency investments; and competing priorities for final beneficiaries.

If the EU is to meet its 2020 energy efficiency target and its ambitions for further savings towards 2050, it is

imperative to improve the financial support for energy efficiency in buildings. For this to happen it is necessary

to ensure that the regulatory framework is properly implemented, more financing is made available and key

barriers are addressed.”

5.5 Conclusions

In this context, the interesting exception is officially protected buildings as part of a designated environment or

because of their special architectural or historical merit. But the exception applies only as long as energy saving

measures cannot be implemented without unacceptably alter their character or appearance. There is no

specific protection level associated with the expression “officially protected”. This means that it is not restricted

to typically listed buildings, but also to buildings protected at a lower level, e.g. by planning legislations.

Either way, the most central in the exception seems to be related to the expression officially protected buildings.

This means that official non-protected historic buildings and built environments are not exempt from the

requirements. In fact, a general exemption from the requirements of energy efficiency for non-official protected

historic building and environments would be in direct violence with the Directive.

However, the provisions of the Directive represent an overall framework for national legislation. This means that

each country must provide specific legislations about when and how energy requirements should be designed

and how they should be used on historic buildings, adapted to local conditions. In this, it is important to note

that the Directive does not have guidelines on how and what measures should be implemented, as long as it

leads to energy efficiency. However, there are guidelines for assessing what constitutes effective measures in

buidlings, the document: “EU No 244/2012: Cost-optimal methodology framework”12. The document provides a

suggested methodology which specifies how to compare energy efficiency measures, measures incorporating

renewable energy sources and packages of such measures in relation to their energy performance and the cost

attributed to their implementation. It also discusses how to apply these to selected reference buildings with the

aim of identifying cost-optimal levels of minimum energy performance requirements. The Guideline document

12

Appendix, section 3


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does not take into account the specific requirements that should apply on historical buildings. It is however

mentioned that Member States who have not excluded heritage protected buildings (Article 4(2) of Directive

2010/31/EU) might wish to establish subcategories that reflect the characteristics of typically protected

buildings.( EU No 244/2012: 5). Antithetical interpreted, it seems like there is no room for separate categories

for non-protected historic buildings or environments.

EU law makes a clear distinction between officially protected buildings or environments and non-

officially protected buildings or environments, whe re non-officially protected buildings or

environments in principle shall be treated equally with all other existing buildings and environments,

when it comes to requirements for energy efficiency . This concept is implemented in the guidance

document “Cost-optimal methodology framework”.


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6 National legislations: European countries nationa l legislation

requirements for minimum energy performance in hist oric buildings

and historic environments

6.1 Systematized overview

This chapter gives a more detailed description of each country’s national legislation and policies and is based

on each country's contribution through the questionnaire.13

6.1.1 FRANCE

MANAGEMENT

CULTURAL HERITAGE ENERGY

National: Architect of French building Local : Architect of French building

National : Ministry Regional/local: DREAL (regional management of environment and country planning) Local: ALE (the Municipality)

COOPERATION, IMPROVEMENTS AND CONFLICTS AT MANAGEME NT LEVEL

COOPERATION AND CONFLICTS ON MANAGEMENT LEVEL

GOALS AND ACHIEVEMENTS

The cooperation on management level seems only to be conducted on local level.

The national goals are to reduce more than 38% of the energy consumption in 2020 and. reduce the energy need to 150 kWhep/m²/year

NATIONAL LEGAL REQUIREMENTS FOR MINIMUM ENERGY PERF ORMANCE IN HISTORIC BUILDINGS AND ENVIRONMENTS


No real influence or obligation of EPBD for the historic public building.

13

See about method in chapter 3.1


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CATEGORIZATION

Histor ic environments : Conservation areas (concern the historic district, Intended to guarantee the protection and the development of these historic districts) their regulation are based on “psmv” “plan of protection and development”.

APPLICATION OF THE NATIONAL LEGISLATION ON HISTORIC BUILDINGS AND ENVIRONMENTS

All buildings pre 1948 is exempt from requirements. Comes into force : Parts : the whole building. Control : energy diagnosis (certificate)

METHODOLOGY FOR THE CALCULATION OF THE MINIMUM ENER GY PERFORMANCE OF BUILDINGS

POTENTIAL CONFLICTS

Solar panels on the roof and replacing windows.

STIMULATION

TAXATION ENERGY PERFORMANCE CERTIFICATE

A percentage reduction in tax. Varies between the type of buildings.

Yes

INFORMATION FINANCING

Through the local agency of energy and professional craftsmen.

Beneficial interest

TECHNICAL ASSISTENCE AND ADVISE

Local program for housing improvement ( thermal)


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6.1.2 GREECE

MANAGEMENT


National level Ministry of Environment, Energy & Climate Change Ministry of Education and Religious Affairs, Culture and Sports Central Architectural Committee Central Architectural Committee is an independent Public Body under the supervision of the Ministry of Environment, Energy and Climate Change, responsible for issues related to the protection of ancient monuments, archaeological sites and historical sites. Regional/local: The Commission of Planning and Architectural Control is responsible for the urban planning, issuance and application of building permits and control of arbitrary constructions in central administrative level. County or Municipality Councils handle urban planning, historic buildings, monuments and archaeological sites.

National : The Ministry of Environment, Energy and Climate Change Regional/local/private : Transmission System Operator of the Greek Electricity Transmission System (DESMIE S.A.), Centre for Renewable Energy Sources and Saving (CRES), DEPA, Hellenic Transmission System Operator (HTSO)




There are cases that Local Authorities Official Recommendations have not been approved or have been modified by the Ministry of Culture of The Ministry of Environment, Energy and Climate Change (depending the nature of the Official Recommendation) due to limitations applied by the National Legislation. For example Historic Market in the city of Chalkis has not been characterised as Grade II Historic Building having all the benefits and the limitations of an Historic Building due to constant appeals to the characterisation by some of the owners. The Historic Market will be demolished as the Supreme Court has accepted some other owners appealed as they were not consent to the Official Recommendation of the Municipality of Chalkis to the Ministry of Culture.

20% on final energy consumption in 2020 The goals will be achieved by:

Energy Saving at Home’ , addressed to house/flat owners and providing direct subsidies (up to 30%) and low rate bank loans (covering the remaining share of the investment) for the renovation-Energy Performance improvement of existing buildings.

Save Energy’ addressed to Municipalities, for buildings owned/used by municipal services, administration, schools and housing blocks (the process started in 2009


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Historic buildings Law (L. 1577/1985, amended and supplemented by L. 2831/2000) which comprises the general rules for the erection of buildings and other structures on plots and parcels of land. Law (L. 3028/2002) “New building regulation», Article 6. Historic environments Law 2300/1995 set up the Regulations for the characterization of a Settlement (village) as “Traditional”. No intervention to building shape and designed is allowed to be made, no alternation to the external design, components, materials could be executed. All materials and techniques might be used for a retrofit should be of the same result and aesthetics as the original. Presidential Decree 358/ 1986: jurisdictions for protection of natural and cultural environment are transferred from YPEKA to Ministry of Macedonia and Thrace.

Relevant national legislation: Law L 3661/2008 FEC 89/A/2010 (KENAK) Law L 3851/2010 Law L 3889/2010 Law L 3661/2008 Law L 20701-1/2010 In 2008, the Greek Law 3661/2008 ‘Measures for decreasing the energy consumption of buildings’ was voted, according to which the Energy Performance Regulation for Buildings (KENAK) is foreseen. According to the Regulation of the Energy Performance of Buildings, a set of minimum requirements are applied to new buildings. Therefore, all applications for building permits after the 1st of October 2010 must be accompanied by an Energy Study that proves that the building under planning is in compliance with these minimum requirements.

The impact of EPBD on the national requirements concerns:

- the introduction, for the first time, of the energy performance certificate,

- the definition of specific energy performance levels,

- the definition of specifications for different building systems,

- the consideration of renewables in buildings above 1.000 m2

The design of the building, taking orientation, surrounding area, passive solar systems, natural ventilation, daylight etc., into account:

• Maximum U-value for walls, windows, roofs etc., for each one of the four climatic zones in Greece. The main parameter used for the climatic zones is the annual heating degree-da

• Maximum value for the average U-value for the whole building

• At least 50% heat recovery in the central air-conditioning units

• Minimum levels of insulation of the heating and cooling distribution network

• At least 60% hot water production from solar panels.

• Minimum requirement for lighting installations in the tertiary sector buildings (55 lm/W).


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CATEGORIZATION

Historic buildings Grade I. Preservation of the building and the surrounding area, with absolute protection. Grade II. Preservation of the building and the surrounding area, with absolute protection of the building envelope. Grade III. Preservation of the volumetric contour (reconstruction).

Historic environments As Traditional Settlements (villages) are defined any areas in land or sea or lakes or rivers i) in which historical or mythical events occurred after 1830, ii) which contain or is possible to contain ancient monuments dating after 1830, iii) composite constructions of both human and nature dating after 1830 which constitute characteristic and homogeneous spaces, can be defined topographically and must be protected as a result of folk, ethnic, social, technical, architectural, industrial or general historical, artistic or scientific significance.


Under the provision of article 11 of Law 3661/2008 and as clarified in the relevant Circular ‘All buildings and monuments protected by the law due to their classification as part of a specific environment or their architectural / historical value (as in the case of historical buildings), are obliged to an assessment of energy performance in case of major renovation, given that their compliance with the Law 3661/2008 and the KENAK would not result in altering their characteristics or appearance in an unacceptable manner.

In this case, energy classification of the building under the provision of article 5 of Law 3661/2008 is carried out to the extent that this is technically, functionally and economically feasible.

The minimum requirements are not in force in the following building’ categories:

a) Monuments

b) Buildings officially protected as part of a specific environment or due to their special architectural or historic value (listed within traditional settlements, etc.), provided that their compliance with minimum energy performance requirements would not result in altering their characteristics or appearance in an unacceptable manner.

c) Buildings used as places of worship or for religious activities

d) Buildings of temporary use with duration not exceeding the period of two years according to their design, industrial facilities, craft industries, laboratories, warehouses, parking lots, gas stations, non-residential buildings for agricultural uses with low energy requirements and buildings used by a sector under a national agreement regarding buildings’ energy performance.

Comes into force when renovation requires a Building Permit or major E/M elements e.g. boilers, lifts, E/M installations, etc. are upgraded. The certificate is not detached to current or future use of the building

Parts. It applies to the whole building but is to the discretion of the owner (depending on the nature of works, cost and custom needs of each one) to apply these requirements to the whole building or at a part of it. Control : through energy inspectors and certificates. Requirement for competency: no Control : through energy inspectors and certificates. Requirement for competency: no


Under the provision of article 5 of KENAK, the methodology applied for the assessment of buildings’ energy performance is a quasi-steady monthly method in line with European Standards EN ISO 13790 (2009)


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POTENTIAL CONFLICTS

There are cases that Local Authorities Official Recommendations have not been approved or have been modified by the Ministry of Culture of The Ministry of Environment, Energy and Climate Change (depending the nature of the Official Recommendation) due to limitations applied by the National Legislation. For example Historic Market in the city of Chalkis has not been characterised as Grade II Historic Building having all the benefits and the limitations of an Historic Building due to constant appeals to the characterisation by some of the owners. The Historic Market will be demolished as the Supreme Court has accepted some other owners appealed as they were not consent to the Official Recommendation of the Municipality of Chalkis to the Ministry of Culture.

STIMULATION


A percentage reduction in tax. Varies between the type of buildings.

Yes


http://gis.ktimanet.gr/wms/ktbasemap/default.aspx

TECHNICAL ASSISTENCE AND ADVISE SUBSIDIES/FUNDING

Ministry of Education and Religious Affairs, Culture and Sports, Ministry of Environment, Energy & Climate Change, Ministry of Justice, Transparency and Human Rights, Public authorities

– Energy Saving at Home – Saving Energy – Energy Performance Improvement of Public

Buildings. – Energy Performance Improvement of School

Buildings


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6.1.3 HUNGARY

MANAGEMENT


National : Deputy State Secretariat for Regional Development and Construction (belonging to the Ministry of Interior). The Deputy State Secretariat for Regional Development and Construction is responsible for determining specialist regulations related to spatial planning in settlements, analyzing trends in spatial planning, developing legislative proposals, overseeing the implementation of subsequent decisions, directing implementation of legislation and initiating measures necessary to achieve this. Regional : Construction and Heritage Bureau of the capital's and the county capital's regional offices. The authority is responsible for the preservation, the subservience and support of the sustainable use of cultural heritage elements. For this purpose it assumes: The authority and special authority duties defined by the acts and decrees; The supervision duties of the heritage protection; The scientific duties defined by the law, and their co-ordination; and Other duties, entrusted to their competence. Local : Municipal, local protection and its enforcement is a task of a settlement. Municipal regulations are created in order to describe how protected monuments can be restored/renovated and which are the main aspects of protection.

National : The Government nominates the notary of the local government to be responsible as the primary construction authority.The Government nominates the public administration office to be responsible as the secondary construction authority.

Local : In case of the buildings, which are under heritage protection, the responsible construction authorities are nominated by special legislation. In the absence of such legislation, the public administration office and the notary of the local government are dealing with the case. If the legislation prescribes, that the primary construction authority is the public administration office, than Minister of Construction deals with the secondary cases.




Possible conflicts (since supported solutions regarding energy performance are difficult to reconcile with historical structures and the appearance of monuments):

Heat transfer coefficients of historic windows and doors (building openings) are difficult to measure. Therefore, these can’t be considered in energy performance competitions – applicants rather plan on changing these doors and windows during the restoring works.

Outer thermal insulation brings down the performance of walls of historic buildings (humidification for example) and it eventuates the disappearance of ornaments of a facade therefore it is authorized only in special cases.

The goals are in accordance with the EPBD.

The goals will be achieved by

- means of different competitions that support energetic renovations. - National Climate Change Strategy (NCCS) - National Energy Strategy :energy efficiency measures spanning the entire supply and consumption chain; - increasing the share of low CO2-intensive electricity generation based primarily on renewable sources of energy; - promoting renewable and alternative methods of heat generation; - increasing the share of low CO2-emission modes of transport.


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Installation of photovoltaic and solar panels worsens the historic appearance of monuments and historic environments.



Historic buildings / Historic environments - Act No. LXIV/2001 on the conservation of cultural heritage - Act No. LXXVII/2011 on the world heritage - Act No. LXXVII/1997 on the built environment and its conservation - Governmental Decree No. 393/2012 (XII. 20.) on the rules relating to the preservation of archeological and historic values - Governmental Decree No. 312/2012 (XI. 8.) on the procedures and controls of the constructions and construction's supervision authorities, and on the services of the construction authorities - Decree of Ministry of Interior No. 80/2012 (XII. 28.) on the registration of archeological sites and historic buildings, their declaration to be protected, and on the detailed rules of archeological excavation - Decree of Ministry of Rural Development No. 66/1999 (VIII. 13.) on professional rules of the protection of local architectural heritage. The protection is based on real estate. The local preservation aims to preserve as better and more complete the valuable architectural, landscape and built environment related to the natural characteristics of the settlement’s and its surrounding. The remaining and protectable buildings, building ensembles represent historical as well as art historical significant value, at the same time they are also important pillars of the self-determination of the community. Therefore their preservation and proper utilization is economic, cultural and eventually settlement-political interest. The large number of locally protected monuments defines the attributes of the typical characteristic of settlements, and the diversity of the local preservation’s memories requires professional, authentic renovation and preservation. The basic condition for the preservation is – beyond the moral recognition – to maintain a good technical condition, “the proper maintenance”, and the high quality of the prospective restoration, which is occasionally inevitable. Historic environments Law 2300/1995 set up the Regulations for the characterization of a Settlement (village) as “Traditional”. No intervention to building shape and

The provisions relating to the construction authorities; the nomination and operating conditions of the construction's supervision authorities are included in the Government Decree No. 343/2006 (XII. 23.). From the 9th of July, 2013 (§6 of Decree of Minister without Portfolio No. 7/2006 (V. 24.): By renovation of existing buildings, for energy saving purposes, the building components involved in the construction and assembly works shall comply with the requirements for the newly built building components. By enlargement of existing buildings, if the extension does not exceed the 100 % of the original building’s useful area, the new partition structures must comply with the requirements of the Annex I and V. Existing building’s extension bigger than determined in (2), or in case its significant renovation, the requirements for new buildings shall be applied. Before major renovation of an existing building, the application of alternative systems and the economic feasibility must be examined and documented, as determined. This don’t apply for government-owned buildings.

i) The building or the built environment is preserved by the law.In this case, it’s not necessary to fulfill the building’s energetic standards.

ii) The building or the built environment is not preserved by the law.

1. In case of smaller than “significant renovation” is not necessary to fulfill the building’s energetic standards. 2. In case of “significant renovation” the building’s energetic standards must be fulfilled.


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designed is allowed to be made, no alternation to the external design, components, materials could be executed. All materials and techniques might be used for a retrofit should be of the same result and aesthetics as the original. Presidential Decree 358/ 1986: jurisdictions for protection of natural and cultural environment are transferred from YPEKA to Ministry of Macedonia and Thrace.

CATEGORIZATION

Historic buildings

National protection : Protected real estates: monuments under national protection (protected by Ministerial Decree): the monuments are classified in three categories according to the Annex of the Government Decree No. 191/2001 (X. 18.) on the fines of heritage preservation. Examples:

- Main Cathedral (monument reg. Number: 2350) – 1. Szent István square, Esztergom (parcel number 16240) – 1st category monument

- Pálma Hotel (monument reg. Number: 10724) – Angolkert, Tata (parcel number 3306/7) – 2nd category monument

- Roman Catholic (Szent József) temple (monument reg. Number 2488) – Templom square, Dorog, (parcel number 1157) – 3rd category monument

Local protection : monuments under local protection (protected by decree of the local government, settlement-wide protection). The buildings of architectural heritage, which are under the protection of the local government, are integral parts of a national, multilevel preservation system. According to the Act No. LXXVIII/1997 on “The Built Environment and its Conservation”, the Decree No. 66/1999. (VIII.13.) states, that the “local preservation includes all the elements of the architectural heritage, which is not protected by specific legislation, and the local government’s regulation declares it to be preserved as municipal, landscape, natural, architectural, ethnographic, fine- or applied artistic, industrial historical, archeological value”. The local preservation may cover the “settlement and its surrounding or its coherent parts (local areal protection), and certain buildings, its details (local individual protection)”. Examples:

- Residential building – 5. Széchenyi square, Esztergom (parcel number 17337)

Historic environments

Historical gardens (such as monuments)

The historical garden attains historic or artistic value, independently or in connection with another monument, and is a landscape architectural creation, green area or park, which appears as part of the historical settlement structure; the highly significant historical garden can be declared as monument.

Conservation area That part of the settlement is declared as conservation area, which has significant, historically developed structure, and the overall picture, the relation to the landscape, the squares and streets, the buildings create a coherent system – which is worth for protection – and expresses the architectural culture of the establishing community, and which is declared to be preserved by the law.

Historic building environment Properties directly adjacent to monuments or conservation areas, parts of the public place and properties directly adjacent to parts of the public place – by virtue of law – are declared as historic building environment. Regulation – declaring monuments or conservation areas – under specific conditions may designate differently the historic building environment.

Historic sites The historic sites – under monumental protection – are those partially built-up areas, which are culturally (historical, monumental, artistic, scientific, technical, etc.) significant, as the result of the interaction of man and nature. By their characteristics and uniformity, they form a topographically definable unit, and are declared to be preserved by the law.


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Local preservation of monuments The buildings of architectural heritage, which are under the protection of the local government, are integral parts of a national, multilevel preservation system. According to the Act No. LXXVIII/1997 on “The Built Environment and its Conservation”, the Decree No. 66/1999. (VIII.13.) states, that the “local preservation includes all the elements of the architectural heritage, which is not protected by specific legislation, and the local government’s regulation declares it to be preserved as municipal, landscape, natural, architectural, ethnographic, fine- or applied artistic, industrial historical, archeological value”. The local preservation may cover the “settlement and its surrounding or its coherent parts (local areal protection), and certain buildings, its details (local individual protection)”.

The local preservation aims to preserve as better and more complete the valuable architectural, landscape and built environment related to the natural characteristics of the settlement’s and its surrounding. The remaining and protectable buildings, building ensembles represent historical as well as art historical significant value, at the same time they are also important pillars of the self-determination of the community. Therefore their preservation and proper utilization is economic, cultural and eventually settlement-political interest.


Comes into force when major renovation and major extension (see question 14/a) §6 of Decree of Minister without Portfolio No. 7/2006 (V. 24.)

- State-owned, public-used building, with larger than 1000 m2 of useful floor area:

◦ I. By renovation for energy saving purposes, only the involved building components. §6 of Decree of Minister without Portfolio 7/2006 (V. 24.)

◦ II. By minor extension, only the new bordering structures §6 of Decree of Minister without Portfolio 7/2006 (V. 24.)

The protected historic buildings (urban areas) are exceptions of the cases above. The cited regulation defines further exceptions. Parts: only the changed parts of the building is covered by the requirements Control : building’s authorization Requirement for competency: Only senior architect can design protected historic building.



POTENTIAL CONFLICTS

- Using insulating plastering, instead of thermal insulation board,

- Repair of windows and LOW-E glazing, instead of window-replacement,

- Instead of window-replacement, insulating glazing of inner sash,

- Upper insulation of the topmost slab,

- Thermal insulation is not enough, care must be taken to the waterproofing and humidity.

STIMULATION


Reduction of corporate tax base Yes – it is obligatory to have an energy performance certificate in case of selling or renting out an existing building or construction of a new building.


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Yes – with the help of competitions

6.1.4 ITALY

MANAGEMENT


National : The director of State Office for the Preservation of Historical Monuments determines the objects of particular artistic, historical, archaeological or ethnological value, which must be placed under monument protection. Regional : The D.Lgs.n.42 / 2004 defines that the local superintendence of the Italian provinces protects the cultural heritage. This means that the superintendence lists all the buildings subjected to specific restrictions because of their historical or cultural value. For every intervention on listed buildings the superintendence has to give an authorization.

National : At a national level the energy requirements of the below listed laws have to be reach. Regional/local : the administration can improve the energy requirements to higher standards. At a local level many types of different certification have been developed both for new or existing retrofitted buildings. Examples of local energy certifications are: CENED (Lombardia), KlimaHaus (Alto Adige/Südtirol), LEED (Trentino).




At a national level, there is not direct mandatory cooperation between the energy management and the heritage management. The local superintendence for cultural heritage has to evaluate each intervention on historic listed buildings. Only with the approval of the local superintendence is possible to do a retrofit action. Listed buildings are not subjected to any energy standards (DPR 59/09 art1). However, some regional legislations are trying to improve this cooperation trough mandatory energy certification for retrofit interventions on existing and historic buildings.

The Italian national goals within the 2020 are the reduction of the 13% of Co2 emissions and the production of the 17% of energy with renewable energies sources. Achievements by legistalition based on EPBD.


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Historic buildings : Immovable or movable objects of artistic, historic, archeological or ethnographic and ethnological interest ; Immovable or movable objects, which are of particular great interest because they are connected with the history of politics, military, literature, art, science, technics, commerce or culture or because they bear witness to identity and history of the public, the community or the religious institutions; The preservation of monuments covers outstanding buildings (examples). Where historic buildings are protected, they have a role model for other similar buildings. Within 30 days from the listing proposal, the owner has the opportunity to submit statements and objections. After this the state government decides on the conservation bond for the proposed heritage. Historic environments . The “Denkmal-Bannzone” includes the surrounding/the context of the listed building: The State Office for the Preservation of Historical Monuments has the right to declare the surrounding area/the context of the listed building into a so called “ban zone”. The State Office exercises this right not in every case of a listed building but in some outstanding cases, for example the surroundings of a cathedral, also because of administrative effort. Within this zone buildings are indirect protected (according to article 45-52, see also below) that means in case of a refurbishment project guidelines with regard the outside appearance has to be complied. The project has to be approved by the State Office for Preservation. “Protection of ensembles” includes more than the individual building like construction volume, outside appearance, courts, open spaces, streets. In this way it is also a tool for urban development. Ensembles are not individual objects but an interplay of several objects, which reflect the history and the interaction of human and nature and which contribute with their individuality to local and regional identity.

The national legislation applies the EPBD trough the DPR 59/2009. This law defines the minimum energy requirements for buildings. The 2010/31/UE was introduced in Italy thought:

Dlgs 28/2011, the achievement of target defined are under the responsibilities of regions and autonomous provinces as reported within the law: DM 2010 20 September.

Existing buildings subjected to the renovation of the whole envelope have the same requirements of new buildings. For the envelope and for the systems they must respect the minimal levels described in the DPR 59/09.

For the renewable energies they have to respect the D.Lgs. 28- 3 March 2011. This law

Introduces the mandatory use of the Renewable energies for major renovation interventions in existing buildings with a surface > 1000 m2.

For new and major renovated buildings, Renewable Energies have to provide the 50 % for hot water and from 20% to 50% of the energy request for the heating and cooling systems (depending on the time of the construction approval). If the building is connected to district heating this legislation is not applied. The regional legislation can improve these minimum percentages. For public buildings these limits are 10% higher.

CATEGORIZATION

Historic buildings: Immovable or movable objects of artistic, historic, archeological or ethnographic and ethnological interest; Immovable or movable objects, which are of particular great interest because they are connected with the history of politics, military, literature, art, science, technics, commerce or culture or because they bear witness to identity and history of the public, the community or the religious institutions.

As a prerequisite to become a listed building the object has to be at least 50 years old and may not be the work of a living artist/architect.

Historic environments: Protection of ensembles can apply when at least 2 of 10 criteria is present. Criteria: 1. Historic value; 2. Picturesque character; 3. Monumentality of the buildings to each other and to the landscape; 4. Stylistic characterization (uniform style or consciously mixing of different styles; 5. Appearance (recognisability, conspicuity, landmark); 6. Panorama (distant views, perspective views and elevation); 7. Collective memory; 8. Continuation of the urban system (recognitions of a plan or a founding act determined by the settlement morphology); 9. Continuation of the construction typology; 10. Natural characteristics, geomorphology and natural character.


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Listed buildings are not compulsorily subjected to any energy standards (DPR 59/09 art1).

Historic not listed buildings the same requirements of energetic performance as the new buildings. For interventions of major renovation, they have the same requirements as the new buildings in terms of energy performances. For interventions of minor renovation, such as partial substitution of the external walls or partial substitution of the roof, the energy performances are required only for the new components as a transmittance limits.

Comes into force when there is a major renovation for buildings with a surface >1000 m2 the building has to meet the energy requirements at national and regional level. The requirements are the same as those for new buildings.

Parts : In case of major renovation the minimum energy performances are required for the whole building. In case of partial renovation of the external walls or of the roof, the energy performances are required only for the new parts as

Control: control during the construction.

Requirement for competency : no


The UNITS 11300 define the methodology for the calculation of the minimum energy performances

POTENTIAL CONFLICTS

Solutions to be avoided during the retrofit because of their impact are:

- Use of external insulation

- Use of internal insulation for painted walls

- Intervention of super elevation of the roof

Reversible solutions instead on irreversible solutions are always preferable

STIMULATION


The D.M 26/01/2010 ( and following updates as the 13/12/2010 n.220 and d.lgs201/) defines for the retrofit of existing buildings a tax reduction at the 55% (maximum limit is 96.000 euros). The retrofit interventions must respect the energy efficiency limits established in the legislation.

Existing buildings under renovation must be certified. For historic listed buildings the energy certification is not mandatory and all interventions have to be approved by the local superintendence for cultural heritage.


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6.1.5 REPUBLIC OF IRELAND (ROI), EXCLUDING NORTHERN IRELAND (NI), WHICH APPLIES

AND ADOPTS UK LEGISLATION.

MANAGEMENT


National : The Department of Arts, Heritage and the Gaeltacht (DAHG) is the governing national authority for built and natural heritage in Ireland. www.ahg.gov.ie/en/Heritage The Department of Environment, Community and Local Government (DECLG) used to, until 2011, comprise the resort “Heritage” as Department of Environment, Heritage and Local Government (DEHLG). Through existing pre 2011 legislation and the remaining responsibilities for Planning/Development, DECLG keeps its remit for limited elements of Irish built heritage. www.environ.ie/en/ The following three government authorities are operating at a national level under the remit of the DAHG: - The National Monuments Service (NMS) administers the Archaeological Survey of Ireland, which contains the Record of Monuments and Places (RMP) for each of the 26 Counties. www.archaeology.ie/ArchaeologicalSurveyofIreland/ - The National Inventory of Architectural Heritage (NIAH) comprises surveys for each of the 26 Counties for buildings, which are classified as architectural heritage. www.buildingsofireland.ie/ - The Heritage Council, established under the Heritage Act, is putting in place practical programmes for infrastructure and networks to conserve heritage throughout communities. www.heritagecouncil.ie/about-us/about-us/ Regional: Due to the country’s relatively small size and population (4.6million 2011), Ireland’s 8 regional authorities only coordinate EU structural funds for the local authorities while advising, supporting and monitoring these with regard to built heritage activities. (NUTS II + NUTS III) Local: Each of the 26 Counties has established their Heritage Office, which in coordination with The Heritage Council record and administer the Counties’ built heritage. Each County Development Plan, which is valid for a five-year period, comprises a detailed Record of Protected Structures (RPS) and a detailed list of Architectural Conservation Areas (ACA). (LAU-1, former NUTS IV) It is noted that local built heritage records of the Counties do not entirely correspond with national

National: The Department of Environment, Community and Local Government (DECLG), through its relevant regulations, governs and implements energy efficiency in buildings. These are: S.I. No.243 of 2012 European Union (Energy Performance of Buildings) Regulations 2012, which transposes EU Directive 2010/31/EU (EPBD); S.I. No.259 of 2011 Building Regulations (Part L Amendment) Regulations 2011, which regulates conservation of fuel in buildings; and S.I. No.235 of 2008 Planning and Development Regulations 2008, which regulates micro-renewable energy technologies in the domestic, industrial, business and agricultural sector. www.environ.ie/en/DevelopmentHousing/PlanningDevelopment/Planning/ The Department of Communications, Energy and Natural Resources (DCENR) are marginally involved in buildings’ energy efficiency through The National Energy Efficiency Action Plan 2009-2020 and S.I. No.542 of 2009 European Communities (Energy End-use Efficiency and Energy Services) Regulations 2009. www.dcenr.gov.ie/Energy/ The following government authority is operating at a national level under the remit of the DECLG: The Sustainable Energy Authority Ireland (SEAI) is the leading national body to promote sustainable energy structures, technologies and practices. It advises and develops programmes to improve Ireland’s energy efficiency in buildings. SEAI has established a Dwellings Energy Assessment Procedure (DEAP) to facilitate Building Energy Ratings (BER) for all newly built and existing structures, which undergo refurbishment/retrofitting and/or change of tenure or ownership. www.seai.ie/Your_Building/EPBD/ Regional: Due to the country’s relatively small size and population (4.6million 2011), Ireland’s 8 regional authorities only coordinate EU structural funds for the local authorities while advising, supporting and monitoring these with regard to energy efficiency activities. Local: County and City Councils’ Planning Departments as local authorities have the responsibility to assess and authorise development regarding its energy efficiency and compliance with the abovementioned regulations and technical


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records, administered by the NIAH. Counties have recorded structures, which the NIAH have not listed whereas the NIAH keep records of structures which are not listed in local records. According to the NIAH, the national authorities are in the process to rectify this discrepancy in the coming years.

guidance documents.




The actual cooperation between and integration of the agendas of energy efficiency and conservation for proposed development on traditional structures is facilitated at local authority level in the individual County and City Councils. It is the responsibility of the appointed planning officer and appointed heritage officer within the council to jointly advise and decide upon any building works to architectural heritage, which require authorisation under the valid Building Regulations. Planning applications that include material works to a Protected Structure, as listed in the county’s Record of Protected Structures (RPS) require the preparation of an authorised Conservation Report, to accompany the regular planning documentation.

Commitment to a 20% reduction in energy use until 2020 with the public sector trying to achieve 33%. This will be achieved by implementing and enforcing updated Building Regulations for residential and non-residential structures.

• Greener and Warmer Homes Schemes to promote energy efficiency and conservation with financial incentives and widespread information.

• Introducing a Dwelling Energy Assessment Procedure (DEAP) to facilitate Building Energy

• Ratings (BER) for residential and non-residential buildings.

• Setting Energy Demand Reduction Targets.

• Multi-annual National Insulation Programme

• Home Energy Saving Scheme



Historic buildings The main national legislation for built heritage is the Heritage Act 1995, applying the following definition: “architectural heritage includes all structures, buildings, traditional and designed, and groups of buildings including street-scapes and urban vistas, which are of historical, archaeological, artistic, engineering, scientific, social or technical interest, together with their setting, attendant grounds, fixtures, fittings and contents, and, without prejudice to the generality of the foregoing, includes railways and related buildings and structures and any place comprising the remains or traces of any such railway, building or structure” (DAHG 1995) Of further statutory importance are the Architectural

The EPBD, Directive 2002/91/EC was transposed into Irish legislation in 2006 through the European Communities (Energy Performance of Buildings) Regulations. The amending Directive 2010/31/EU has been transposed into Irish legislation in 2012 through the respectively amending European Union (Energy Performance of Buildings


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Heritage (National Inventory) and Historic Monuments (Miscellaneous Provisions) Act 1999 and the Planning and Development Act 2000. The county authorities represent the local level. County Development Plans (CDP) provide protection for historic buildings through their Records of Protected Structures (RPS). These list all buildings within a county, which the county heritage departments declare protected or propose to protect it. Historic environments County Development Plans (CDP) declare specific parts of their jurisdiction as Architectural Conservation Areas (ACA). An ACA consists of a variety of buildings, which are not necessarily individual protected structures. The protection status applies to the historic area, character, architecture and ensemble quality rather than individual buildings and their features.

CATEGORIZATION

Historic buildings / Historic environments

National Inventory of Architectural Heritage (NIAH) at national level. Record of Protected Structures (RPS) as part of each local authority’s City or County Development Plan.


The requirements do not apply to works (including extensions) on an “existing building which is a “protected structure” or a ‘proposed protected structure” within the meaning of the Planning and Development Act 2000 (No 30 of 2000). Nevertheless, the application of this Part may pose particular difficulties for buildings which, although not protected structures or proposed protected structures may be of architectural or historical interest. Works such as the replacement of doors, windows and rooflights, the provision of insulated dry lining and damp-proofing to walls and basements, insulation to the underside of slating and provision of roof vents and ducting of pipework could all affect the character of the structure. In general, the type of works described above should be carefully assessed for their material and visual impact on the structure. Historic windows and doors should be repaired rather than replaced, and drylining and dampproofing should not disrupt or damage historic plasterwork or flagstones and should not introduce further moisture into the structure. Roof insulation should be achieved without damage to slating (either during the works or from erosion due to condensation) and obtrusive vents should not affect the character of the roof. In specific cases, relaxation of the values proposed may be acceptable, to the local building control authority, if it can be shown to be necessary in order to preserve the architectural integrity of the particular building.” 14

Comes into force: all building works, which imply material alterations or material change of use are required to comply with the Building Regulations, Part L, Conservation of Fuel and Energy. Parts: only to the refurbished parts of the building. In case of a new extension to an existing building would only apply to the newly built floor area. Control: No energy performance assessment after works have been completed are required or established. However, works of “Major Renovation”, which include works of material alteration or material change of use according to Irish regulation require planning permission through a planning application. This planning

14

Building Regulations, Part L


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application has to be accompanied by a Building Energy Rating (BER) certificate, which represents the proposed works regarding their energy performance. The building authorities depend solely on the credibility of certified BER assessors, whose standards are regulated by the Sustainable Energy Authority Ireland (SEAI), a government agency.. Requirement for competency: Only when the building is protected.


For residential buildings, the Dwelling Energy Assessment Procedure (DEAP) is the Irish official procedure for calculating and assessing the energy required for space heating, ventilation, water heating and lighting, less savings from energy generation technologies. DEAP calculates the annual delivered energy consumption, primary energy consumption and carbon dioxide emission, based on standardised occupancy. The DEAP calculation framework is based on IS EN 13790

POTENTIAL CONFLICTS

The main issues arise in the treatment of historic windows and doors, roof and façade features. The most obvious and visible conflict arises when external façade insulation and render is proposed to any historic façade, especially of a non render finish such as brick or stone. The extra layer of generally 100-150mm often has multiple repercussions as it changes the window and door rebates and clear openings, the base and roof connections and, in terraced situations, the continuity of the building front with neighbouring properties.

STIMULATION


Reduction of corporate tax base Owners and landlords of residential, non-residential and large public buildings are required to produce a BER certificate upon any lease or sale. These requirements came into force in stages since 2010.


http://www.seai.ie/


SEAI would advise on whom to contact for consultation and provide a list of certified BER/SBEM assessors. Any further services are to be sought through an architect and/or engineer with BER/SBEM qualification.

Grants for retrofitting, protected structures in particular, have been reduced generally and are regulated by the SEAI. Conditions are a certain amount of investment and specific measures that must be completed. A BER is funded with €50, grants vary from €400 - 3.600max.


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6.1.6 NETHERLANDS

MANAGEMENT


National: State advisory board, responsible for collect and dispense information and subsidising Local: Municipalities do the approvals of retrofitting/restoration plans.

National : Agents chap NL/Senter Novem, guiding energy label assessments






Historic buildings Monument law

For existing buildings (non CH buildings) the thermal resistance of the envelope must be at least 1,3 m2W.

CATEGORIZATION

Historic buildings/historic environments There are no official categorization, but is based on - type - age - style For CH buildings the local authorities decide per case whether or not retrofitting actions are allowed. Each authority more-or-less uses its own interpretation for that with the main baseline ‘not to harm the authentic appearance of the building’. The local authority is set by the ‘Monument law’.


For CH buildings the local authorities decide per case whether or not retrofitting actions are allowed. Each authority more-or-less uses its own interpretation for that with the main baseline ‘not to harm the authentic appearance of the building’. The local authority is set by the Monument law. Comes into force new buildings, or if owner/occupants/user agree Parts: Only when renovation can be considered as new construction or re-use/transformation of the building Control : no control Requirement for competency: Yes, for some applications certification is needed. eg. cavity wall insulation, ETICS


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Calculation of overall energy loss through building envelope, energy use-gain by installations, standard user behaviour – climate.

POTENTIAL CONFLICTS

The Dutch marked for renovation and retrofitting is a difficult chapter for energy saving, because owners and occupants have civil rights that limits the government's options for imposing energy requirements. If they rent the place they have a strong vote to deny the increase of rental cost due to improvement actions and if they are owner they have to decide themselves whether it is economically feasible. Implementation of EPBD 2010 harms other legal rights that are set in the Dutch building.

STIMULATION


Vat 6 % reductions. Yes



Yes


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6.1.7 NORWAY

MANAGEMENT


National : The Directorate for Cultural Heritage (Riksantikvaren) is responsible for the practical implementation of the Norwegian Cultural Heritage Act and the objectives laid down by the Norwegian Parliament (Stortinget) and the Ministry of the Environment (Miljøverndepartementet). The Directorate's task is to facilitate sound and efficient heritage management throughout the country. Regional : The regional level for public management of the Cultural heritage is delegated authority from the Directorate of Cultural Heritage, and has as its main task the management of protected cultural heritage of national value in the county. The county council shall, as far as possible, give the municipalities help and guidance in planning and development issues under the Planning and Building Act. Local . The Municipality is the key authority when it comes to the Planning and Building act – for instance zoning plans (protection) and building permits. Some larger cities have Cultural Heritage Management Offices which advise on all questions of conservation and cultural heritage.

National : Ministry of local government and regional development has overall responsibility for the building part of the Plan- and building Act (PBL). The Directorates for building quality (Direktoratet for byggkvalitet) is the central building authority. Directorate do not consider specific building projects or specific solutions, but shall contribute to a good set of rules, efficiency building process, make sure that the building meets certain quality requirements and that the built environment contributes to sustainable development and good living. Directorate is a centre for building matters, a professional body within the building matters and academic advisor in building engineering, environment, health and safety and building regulations in general. Norwegian Water Resources and Energy Directorate (NVE) is a directorate under the Ministry of Petroleum and Energy. NVE’s mandate is to ensure an integrated and environmentally sound management of the country*s water resources, promote efficient energy markets and cost-effective energy systems and contribute to efficient energy use. It is responsible for the energy labelling system in Norway. Local . The municipalities are the local building authority. They consider applications from owners relating to the PBL. They have the authority to issue permits, dispensations, assess whether actions are within the law or not etc. PBL is supplied with a technical regulation (TEK). TEK contains among many topics also requirements for energy performance.




The municipalities will in most cases be responsible for balancing the interests – heritage management and energy saving. This balance has proved in practice to vary greatly between different municipalities. Some municipalities require extensive documentation; others require simple documentation as background. Regional level shall be informed and will have the opportunity to express themselves in cases where cultural heritage is in danger of being lost due to inter alia energy savings: • Applications relating to demolition or substantial alteration of any building older than 1850 cf kml § 25 • Demolition or substantial alteration of buildings and

Passive house level by 2015.

This is going to be achieved by

- tighten the requirements in TEK - financial support - information - up till now very little is done when it

comes to buildings with cultural value. The law and the practice are unclear. It is not discussed how to handle buildings with cultural value and requirements for more energy efficiency in the future with generally stricter requirements


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facilities regulated for the purpose of preservation of expertise. Such buildings shall not initially disclosed. • Applications that may affect cultural heritage of national or regional significance. • In areas zoned for special conservation where local authority's decision be appealed by third parties, the municipality may, if it deems necessary, obtain a statement from the county before final appeal. • Applications municipality even see a need for the county shall submit statement to (cf. duty of cooperation). Region government has delegated its responsibility for listed buildings and civil authorities to refuse applications for projects that will reduce the cultural and historical values. In practice, the preservation of cultural heritage comes before the interests of energy conservation in buildings protected by the Cultural Heritage law. It is nonetheless acceptance of some measures to ensure the use and resources for maintenance also on these buildings.



Historic buildings Planning- and building act (PBL):

• Planning - decisions on over view planning,

binding land-use planning and environmental impact assessment. Consideration zones(hensynssoner), legally binding provisions, can be linked to both municipal and zoning and includes zones for the conservation of cultural heritage buildings.

• Buildings - provisions on the duty of application, control and approval of construction works etc. The provision in the PBA § 31-1 Preserving cultural values in work on existing structures can be used to instruct the developer to maintain visual and cultural qualities of the work on the existing building structure. The provision provides authority to deny measure.

The Cultural Heritage Act (KML):

• The purpose of cultural heritage management is described in the Cultural Heritage Act, which lays down that it is a national responsibility to safeguard archaeological and architectural monuments and sites and cultural environments "as part of our cultural heritage and identity and as an element in the overall environment and resource management".

The EPBDs is not implemented. However most of the requirements was introduced in the Planning and Building Act from 2009. There are requirements for U-values, energy demand and energy source. Existing buildings have to meet the requirements when going through a major renovation. For smaller measures, the measure in itself must meet the requirements. The possibilities for exceptions are not well defined and practice varies from case to case. There are slightly lower requirements for log buildings. Part of the requirements is not possible to satisfy in the existing buildings, the requirements are based on new construction situation, not in the actual situation of existing buildings. Energy certificates have been introduced: There are possibilities for exemptions from energy certification for buildings with cultural value as in EPBD. It is essential that the claim is relevant, ie that it is a relevant part of the building, fulfills a function and effect of the measure applies. Requirements are limited as a rule to include those parts of the structure to which the measure applies. If there is a question about the renovation or change of use is basically the requirements applicable to the entire building. According to the PBA. § 31-2, fourth paragraph, the municipality may allow change of use and the necessary reconstruction and rehabilitation even when it is not possible to adapt the structure to the technical requirements without disproportionate costs, if the user changes or modifications are


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• Under the terms of the Act, the Directorate for Cultural Heritage may impose a protection order on buildings, groups of buildings, cultural environment/cultural landscapes. There are two types of protection given to monuments and sites, depending on whether they date back to before 1537/1650. Monuments and sites prior to 1537/1650 are automatically protected, while those dating from 1537/1650 onwards require a protection order, which is granted on a case-to-case basis.

appropriate and necessary to ensure appropriate use.

The labeling system is as follows:

Energy grade from A to G based on estimated energy requirements. How well is your house insulated? Heating grade - COLOUR - How environmentally friendly is the energy you use? Heating grade determined by the proportion of the total heating requirements covered by electricity and / or fossil fuel products, which must be below certain values to achieve the different color grades.

CATEGORIZATION

Historic buildings/historic environments Historic buildings are not categorized beyond the various forms of protection

- Protected through The Planning and building act - Protected through The Cultural heritage act

Buildings can also be listed (no legal protection) as cultural heritage valuable by the municipality. In addition there are set special consideration related to buildings pre 1850. Life cycle assessment (LCA) is not a part of the evaluation of the energy performance in buildings.


Comes into force - all changes in buildings defined as "measures" in the Act, except normal maintenance. - alteration or repair of structures that are so extensive that the whole structure is substantially

renewed (major renovation). - change of use.

Parts: When major renovation – the whole building. Otherwise the renovated parts.

Control : Responsible designers and responsible contractor shall have a system to ensure and document that the legal requirements are met. In addition, it shall be conducted independent audit of responsible control entity when: a) there are important and critical areas and tasks b) the municipality requires that after a specific assessment.

Requirement for competency: Yes


Heat loss figures are calculated by NS 3031 Calculation of energy performance of buildings - Methods and data. The standard includes three calculation options:

- Month calculation (stationary method) according to EN ISO 13790;

- Simplified time calculation (dynamic method) according to EN ISO 13790;

- Detailed calculation programs (dynamic method) validated according to EN 15265.


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POTENTIAL CONFLICTS

Energy savings - Insolation - exterior for insulation is the most effectiv. The goal of passive and almost zero

energy house can only be reached through such measures. This leads to loss of heritage values (significant alteration of the exterior). To reduce the change of the exterior, internal insolation will often be implemented. This will change interiors and increases the risk of building physical damage (colder / wetter walls)

- Density - a prerequisite for balanced ventilation with heat recovery. Do not follow traditional

building technology and may lead to physical damages. But this requires also extensive internal work that will damage valuable historic interiors. Density requires other solutions to ventilation than natural ventilation which old buildings often are based upon.

- Ventilation with heat recovery - with the air change requirements in TEK we must have heat

recovery. This requires systems that will require space in the interior and that will require adverse impact on valuable historic building components.

The main focus is on energy conservation instead of looking more holistic when doing measures to reduce impacts on the climate. It is the climate that really is the great "case". Magnitude of GHG accounting, waste reduction and reuse are important keys. The main directions when it comes to ventilation, construction, etc. are based on modern technology. Older builds technical solutions and building characteristics are not used. This leads to actions with greater impact on valuable historic building parts than necessary, and the traditional knowledge is not utilized and not included in the new building.

STIMULATION


Vat 6 % reductions. Yes


www.ra.no


To some extend from regional and national cultural heritage authorities.


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6.1.8 PORTUGAL

MANAGEMENT


National/Regi onal : The General Directorate of Cultural Heritage (DGPC), a State agency, under the auspices of the Ministry of Culture. The core structure of the General Directorate of Cultural Heritage (DGPC) integrates the following units:

a) The Department of Cultural Property; b) The Department of Museums, Conservation

and Accreditation; c) The Department of Studies, Projects,

Construction and Supervision; d) The Department of Planning, Management

and Control.

National: ADENE (the Agency for Energy) develops and manages the Buildings Certification and coordinates the training of the qualified experts that will issue the certificates. All certificates are registered in a web based central system, by the qualified expert issuing the certificate. To fulfil the mission assigned to it, ADENE is composed by the following operational directorates:

a) Directorate of Energy Audit Industry (DI) b) Department of Energy Auditing in Buildings

(DE) c) Marketing Management (DM) d) Project Directorate (PD) e) Technical Director (TD)




Energy Efficiency (PNAEE) aims to achieve an annual energy savings of at least 1% by the year 2016, based on the average final energy consumption, recorded between 2001 and 2005. In this context, the buildings prior to 1990 (first version of RCCTE) may present a significant potential for improving its energy efficiency based on their rehabilitation The goals will be achieved by use of Portuguese Energy Performance Certification scheme.



Historic buildings Portuguese law 107/2001 establishes the basis of politics and the legal system of protection and promotion of cultural heritage. The politics of cultural heritage includes the actions promoted by the government, autonomous regions, local authorities and the rest of public administration, aiming to ensure the realization of the right to culture and enjoyment and realization of cultural values and other tasks and bindings imposed in this area by the Constitution and international law. The foreseen ways to protect cultural heritage are:

a) The legal protection of cultural property based on job classification and inventory.

b) Each kind of protection gives place to

The EPBD was transposed to the Portuguese national law on April 4, 2006 by means of a legislative package composed of three Decree-laws:

a) The Decree-law no. 78/2006, which defines the

National Energy Performance Certification System and Indoor Air Quality in Buildings (SCE) partially applies the Directive 2002/97/CE of the European Parliament and of the Council, of 16 December 2002, regarding buildings energy efficiency.

b) The Decree-law no. 79/2006, which establishes the Regulation of Temperature Control Systems in Buildings (RSECE).

c) The Decree-law no. 80/2006, Regulation of Thermal Behaviour Characteristics in Buildings (RCCTE).


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the corresponding logging level, and therefore there will be: - The registration sheet classification; - The asset inventory register.

c) The application of precautionary measures under the law does not depend on prior classification or inventory of cultural property. The Law classifies cultural heritage in movable and immovable. The property may belong to the categories of monument, ensemble or site, pursuant to which such categories are defined in international law, and furniture, among others, the categories listed in the following:

a) Archaeological heritage b) The papers c) Audio-visual heritage d) Bibliographic heritage e) Heritage phonographic f) The photographic heritage

The main Portuguese reference standard, when energy management is concerned, is the Regulation of Characteristics of Thermal Performance of Buildings (RCCTE). The Decree-Law 80/2006, of April 4, Regulation Characteristics of Thermal Performance of Buildings (RCCTE) establishes quality requirements for new residential buildings and small office buildings, particularly in terms of characteristics of the environment by limiting heat loss and controlling excessive solar gains. The regulation also imposes limits on energy consumption for air conditioning and hot water production, a clear incentive to use efficient systems and energy sources with lower impact in terms of primary energy. This legislation requires the installation of solar panels and values the use of other renewable energy sources. Full implementation of the EPBD, meaning that all the required buildings are now included: new buildings, major renovations, public buildings and all buildings when sold or rented. However this regulation does not apply to “refurbishment, restoration and expansion interventions of buildings in historic areas or on classified buildings, where there are incompatibilities with the requirements this Regulation”.

The limits of thermal quality referred to above are related to the following parameters:

a) Ratios of maximum heat transfer of the opaque envelope, which separate the outdoors units, or spaces that do not require comfort conditions or other neighbouring buildings;

b) Factors of solar horizontal and vertical glazing with a total area of more than 5% of the floor area of pavement provided that no oriented between northwest and northeast.

For further information, the complete RCCTE is available at: http://dre.pt/pdf1sdip/2006/04/067A00/24682513.PDF

CATEGORIZATION

Historic buildings/historic environments The choice of the structure of information elements comprising the records inventory and pre-inventory should result from the weighting of the following conditioning factors: objectives / functions, provided products and recipients; financial, technological and human resources; period of time. Classification therefore refers to 9 elements (examples are given for each category):

1. Category (buildings and built structures cultural and recreational, educational buildings and built structures, residential buildings and built structures, archaeological site, historic site).

2. Type (elementary school, home entertainment, museum, battlefield). 3. Identifier (PT010301010003: PT Portugal match code, code 01 to the Northern Region, 03 in the

district of Braga, 01 to the municipality of Braga, 01 Amares the parish; 0003 a code assigned by the technicians of SIPA, considering a sequential order within each county. PT050801010002: PT Portugal match code, code 05 to the region of Algarve, Faro district to 08, 01 to the municipality of Albufeira, Albufeira 01 to the parish; 0002 a code assigned by the technicians of SIPA, considering


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a sequential order within each county). 4. Appointment (Monastery of Santa Maria de Belém / Jeronimos Monastery and Church of Mercy

Hospital of Swindon / Ana Pereira Theatre, Building on the Street of Our Lady of Fatima, n. 231). 5. Location (Lisbon and Vale do Tejo, Lisbon, Lisbon Prazeres. Viseu, Lamego, Britiande. Region of

Algarve, Faro, Albufeira, Guia. WGS84: 37 ° 28’46 .11 "N, 8 ° 18’27 .31" W). 6. Access (Rua Almirante Cândido dos Reis, n. 2. S. the town of Deliverance, with access through AT

1337 from the intersection with EN 125, Lady of Deliverance direction. Avenida Almirante Reis, n. 125, formerly Dona Amelia Avenue).

7. Protection (MN, Dec. n. No. 32/97, 150, DR 2 July 199. IIM, city council Resolution of February 25, 2005. World Heritage - UNESCO, 2001. Enjoys a Protection Zone established by the Ministries of Justice and Public Works for prisons and for establishments guardianship of minors DL n. º 31,190, of March 25, 1941, and Decree. º 265/71 of 18 June. Included in the Special Protection Zone of the Cathedral of Lamego Partly included in the protection zone of the Poet House António Guerreiro Included in the Parque Natural da Ria Formosa. ZEP, DG 229, December 27, 1955 and Decree No. 251/70, DG 129, June 3, 1970 and Decree No. 516/71, DG 274, November 22, 1971. Property as proposed by the PDM Public Interest Customs of the Faith, DR 241, 18 October 1994).

8. Period of construction (Century II, Century Sixteenth / seventeenth, Century. XII, Medieval). 9. Placement (urban building, rural hermitage).


Regulation does not apply to “refurbishment, restoration and expansion interventions of buildings in historic areas or on classified buildings, where there are incompatibilities with the requirements this regulation. The most current reason is the aesthetical impact of energy efficient refurbishment, or the practical impossibility to fit typical retrofit elements to historical buildings. Aspects of plastic facades, dictated by its architectural features, may make the process of applying insulation and preclude its implementation from the outside, possibly with implications of various kinds, namely, in the case of listed buildings (heritage) or relevant Architectural interest. Minimum energy performance requirements are applied to the whole building or dwelling unit (apartment).

Comes into force Major refurbishment or alteration whose cost exceeds 25% of the building, based on a reference value per square meter of building typology and set annually by joint order of the ministers responsible the areas of economy, public works, environment, spatial planning and housing, published in October and valid for the next calendar year. Parts: only the changed building part or construction part must be covered by the requirements Control : by documentation, certificate, declaration from the technician responsible and statement of Regulatory Compliance signed by a qualified expert Requirement for competency: no


The detailed procedure to compute the minimum energy performance of buildings is reported in the complete RCCTE, available at: http://dre.pt/pdf1sdip/2006/04/067A00/24682513.PDF The Portuguese Energy Agency also provides a fairly simple software to roughly assess the energy performance of each building. This tool is available at the following address: http://www.casamais.adene.pt/ and also provides some suggestions to improve the overall energy efficiency of the dwelling.

POTENTIAL CONFLICTS

The main concern of energy efficient measures applied to cultural heritage deal with aesthetics and ease/possibility of installation. Exterior elements on facades are accepted with difficulty because of their impact. The same applies also for indoor equipment/components. Less invasive solutions shall be stimulated for their adoption in historical buildings.


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STIMULATION


Yes. Very efficient tools are available for certificate estimation. It is also compulsory when there is a property change.


Energy efficient refurbishment is stimulated through information campaigns on medias.


Refurbishment is encouraged by companies operating in the field (construction companies, suppliers, etc.)

6.1.9 SPAIN

MANAGEMENT


National : Ministry of Culture, Education and Sport, overall political responsibility Subdirectorate-General for the protection of heritage. It is responsible for the implementation of the legal regime of the protection of the Cultural heritage Council of the Spanish historical heritage. Coordinating body between the administration of the State and the autonomous communities whose purpose is to facilitate communication and the exchange of programmes of action and information relating to the Spanish Cultural heritage. Board of qualifications, assessment and export of goods of Spanish heritage. Collegiate advisory body attached to the General Directorate of fine arts and cultural property and archives and libraries responsible for the review of applications for export, import and acquisition of goods. Subdirectorate- General of the Institute of Cultural heritage of Spain. Its main functions are the elaboration and implementation of plans for the conservation and restoration of the Spanish Cultural Heritage. Regional : Galicia: Ministry of Culture, Education and

National : Ministry of industry, energy and tourism. IDEA (www.idae.es) The Institute for the diversification and saving of Energy, IDAE, is a body attached to the Ministry of industry, energy and tourism, through the Secretariat of State for energy, from who depends on organically. Contribute to the achievement of the objectives that Spanish Government has acquired in the field of improvement of energy efficiency, renewable energy and other low carbon technologies is the strategic framework for its activity. Regional: level Galicia: Ministry of economy and industry. INEGA (www.inega.es): The Instituto Enerxético de Galicia was created by law 3/1999, of 11 March. The Parlament of Galicia, once analyzed the Galician and international energy context, saw fit to create an entity that carried out the functions, initiatives and energy programmes developed until then by different bodies of the autonomous administration. The legal configuration of the Inega is an entity of public law, with legal personality and assets themselves. It is attached to the competent Department in the field of energy, the Ministry of economy and industry of the Government of Galicia,


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University planning. (http://cultura.xunta.es). The protection of the heritage is the responsibility of the Directorate General of cultural heritage.

and subject, in its activities, programs and general guidelines of the Xunta de Galicia, but with functional autonomy for studies, reports, surveys and educational or commercial activities for the public administration, for businesses and for citizens.




The Consorcio de Santiago is a public administration of cooperation between the Spanish Government, the Government of Galicia and the local government, in order to manage and develop the urban project. There is currently no cooperation among heritage management and energy management in Spain.

To ensure the reduction GHG emissions in Spain, giving special importance to measures related to the energy sector. According to the national inventory, and following the IPCC classification, in 2005, emissions from energy process represented about 78.87% of total national emissions. - To contribute to sustainable development and

the fulfillment of our climate change commitments by strengthening the use of flexible project-based mechanisms.

- To promote additional reduction measures in sectors concerned with diffuse pollution.

- To apply the National Climate Change Adaptation Plan (NCCAP) so as to integrate adaptation measures and strategies in sectorial policies.

- To increase public awareness with respect to clean energy and climate change.

- To promote research, development and innovation in matters of climate change and clean energy.

- To guarantee energy supply security by means of cleaner energies, mainly from renewable sources, achieving other environmental benefits (for example, air quality) and limiting the growth rate of external energy dependence.

- To boost the rational use of energy and saving of resources both for companies and end users.



Historic buildings Movable, immovable property and intangible highlights of Galicia's cultural heritage will be declared property of cultural interest by Decree of the Board of Galicia, on the proposal of the Ministry of culture, and shall be entered in the register of goods of Cultural interest in Galicia.

Historic environments Historic environments declared of cultural interest should develop and approve a Special Plan of protection, rehabilitation and conservation. The plan is the tool for management of the historic city. Energy requirements The Technical Building Code (Código Técnico de la Edificación), hereinafter CTE, is the regulatory

The Technical Building Code (Código Técnico de la Edificación), hereinafter CTE, is the regulatory framework for regulating the basic quality requirements to be met by buildings in Spain, including their facilities to meet the basic requirements of safety and habitability, developing expected in the second final provision of Law 38/1999, of November 5, Building Management (Ley de Ordenación de la Edificación - LOE). The goal of the basic requirement "Energy Saving" is to achieve a rational use of the energy required for the use of buildings, reducing their consumption sustainable limits and also get a portion of this consumption comes from renewable energy sources, as Because of the characteristics of their design, construction, use and maintenance.


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framework for regulating the basic quality requirements to be met by buildings in Spain, including their facilities to meet the basic requirements of safety and habitability, developing expected in the second final provision of Law 38/1999, of November 5, Building Management (Ley de Ordenación de la Edificación - LOE). The goal of the basic requirement "Energy Saving" is to achieve a rational use of the energy required for the use of buildings, reducing their consumption sustainable limits and also get a portion of this consumption comes from renewable energy sources, as Because of the characteristics of their design, construction, use and maintenance. To meet this objective, the buildings are designed, constructed, used and maintained in a way that meets the basic requirements set out in the following sections.

To meet this objective, the buildings are designed, constructed, used and maintained in a way that meets the basic requirements set out in the following sections.

CATEGORIZATION

Historic buildings/historic environments The cultural interest statement answers to the following classes: monument, historic set (historic environment), historic garden, site or historical territory, archaeological site, place of ethnographic interest and paleontological area.


Historic buildings and historic environments are excluded from minimum energy performance requirements.


Historic buildings and historic environments are excluded from minimum energy performance requirements.

POTENTIAL CONFLICTS

The historic city of Santiago do not allow the installation of panels photovoltaic or solar. The authorities responsible for the protection of the historical heritage are normally very cautious in order to avoid risks.

STIMULATION


Yes


Yes


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Municipal energy and climate adviser. Development Programme for building refurbishment. This program aims to finance the execution of works and maintenance and intervention own fixtures and equipment, as well as proprietary elements and common spaces, buildings of collective residential typology. Others are: Programme to promote regeneration and urban renewal, Programme to support the implementations of the buildings, Programme for the promotion of sustainable and competitive cities and Program support for the implementation of the plan.

6.1.10 SWEDEN

MANAGEMENT


The Swedish National Heritage Board is the governmental agency, under Ministry of Culture, responsible for matters concerning cultural environment preservation and cultural heritage.

Sweden is divided into 21 counties, each of which has a County Administrative Board and a County Governor. The Administrative Board is charged with ensuring that regional environmental targets and environmental objectives decided by Parliament are implemented in the county. This is done together with the municipal authorities (290 municipalities) and various sectors in society which are also responsible for the environment. In some regions a Regional Assembly/Council also is responsible for environmental targets and objectives as well as protection of cultural heritage. National: National Heritage Board is the central body of experts’ questions about Heritage Conservation Act and is entitled to a certain extent make regulations about how the law should be applied. Regional: County administrative boards have the practical responsibility for the implementation of the Heritage Conservation Act, except for permitted the export of cultural goods that is managed by different governmental agencies. Local: Municipalities are responsible for cultural environment issues in physical planning etc. against the provisions of the Planning and Building Act (PBL)

National , Ministry of Enterprise, Energy and Communication together with the Ministry of Environment. National Board of Housing, Building and Planning (Boverket) is the agency (under Ministry of Health and Social Affairs for community planning, urban development, building and housing who is the managing body for implementing the law on the energy performance building directives. The mission of the Swedish Energy Agency (under Ministry of Enterprise) is to promote the development of Sweden’s energy system so that it will become ecologically and economically sustainable. Advisory, not decisive. County Administrative Board, are remittance office in physical planning and in appealing building permits. Energy issues are treated by a technical environment department and cultural issues under cultural environment department but they are often organized under same unit - the city planning office - crewed by officers, not politicians. Municipalities are Environment, Social Welfare and Cultural committees. Council and committees are political appointments therefor eg. building permits and physical planning are ultimately a political decision. The policy will therefore vary over time based on political assembly and from various municipalities.


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The heritage management, on all levels, is not invited in early stages of the process. Therefor the influence of energy goals and consequence on heritage is often recognized in a very late stage. The full potential of energy saving in cultural heritage is not recognized! National authorities (Boverket, RAÄ, Naturvårdsverket, Energimyndigheten etc) need more cooperation and coordination – exchange, information, funding etc. Because municipalities work differently with municipal developments plan and regulations there is a difference in the protection of the built heritage that is under protection of plan- and building act. The widths of the differences are difficult to monitor within the heritage management sector. Therefor a national overview/inventory of buildings protected by plan- and building act is incomplete. The buildings protected by Cultural Monuments Ordinance and State Cultural Heritage Buildings Ordinance are under control.

The Swedish goals are - 4015 percent reduction in greenhouse

gas emissions.

- at least 50 percent renewable energy.

- 20 percent energy efficiency.

- Information:

http://www.swedishepa.se/Environmental-objectives-and-cooperation/Swedens-environmental-objectives/The-national-environmental-objectives/A-Good-Built-Environment/

The goals will be achieved by - Changes in taxes and tougher economic

instruments

- Implementing joint EU decision

- Emission reductions through green investments in developing countries or work in other EU countries



Historic buildings National : Cultural Monuments Ordinance protecting ancient monuments and archaeological finds, historic buildings and ecclesiastical monuments, as well as for exports and exports of older artefacts. State Cultural Heritage Buildings Ordinance, The Planning and Building Act. Regional : Municipal development plans and regulations area Planning and Building Act Historic environments National : The Swedish Environmental Code plays a major role in heritage preservation. The Code mandates protection and preservation of valuable natural and historic environments. The Code also allows for the establishment of historic reserves on the same terms as nature reserve Regional : Municipal development plans and regulations area Planning and Building Act.

Since 2012: In Energy chapter (Chapter 9 in building regulations – BBR Boverkets byggregler) same requirements for energy performance as new buildings for upgrading or modification of existing building.

15

The 40 percent climate target in comparison with 1990 and refers to the non-trading sectors, ie the sectors not

included EU ETS.


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CATEGORIZATION


General guidance is that historic buildings may exceed energy performance limits by 20%. Different limits for different climate zones in Sweden. Protected building and historic buildings may not be altered in an unacceptably way. Since building permits and physical planning is ultimately a political decision it is unclear how the new energy chapter will hit against the historic buildings protected in municipal development plans. However the state, represented regional by County Administrative Board, are remittance office in physical planning and in appealing building permits. But administrative board is not only dealing with cultural environments – they have different interests like traffic planning, access of water and energy, economic growth etc. Then the cultural buildings and environments that are not protected by the Cultural Monuments Ordinance have difficulties being acknowledged.

Comes into force when significant change of use or that the building will have a significantly extended service life. Parts: only the changed building part or construction part must be covered by the requirements Control : through certificate Requirement for competency: no


SS-EN ISO 13789:2007 (W/m2K) Thermal performance of buildings -Värmegenomgångskoefficienter –calculation BBR chapter 9:12, see 9a.

POTENTIAL CONFLICTS

Exchanging windows to more energy efficient instead of maintaining existing ones. External insulation changes appearance, tighten facade may give a problem with humidity if done wrongly. It also effects the air change of the buildings that must be considered. Churches: when ceasing to heat churches and because of changed climate, humidity-problems in the ground has created a request from several parishes to exchange the original ground construction from wood/stone to concrete. The sustainability of concrete is unknown and archaeological remains may be covered. Materials that are “free of maintaining” has been a common request – people do not want to put time into maintaining and producers are trying to sell such products! That´s the biggest threat.

STIMULATION


CO2 taxes. ROT –Maintenance, repair, or rebuild and expansion, renovation. Tax credit for 50 percent of the cost of labor for the house works performed in the home, or recreational dwelling. The maximum tax credit is 50 000 SEK per person per year.

Yes


www.energiaktiv.se Different governmental programs eg. LÅGAN - Applications for buildings with low energy consumption, BELOK- technology procurement, Hållbara städer - Delegation for Sustainable Cities, ”OFFrot” energy efficient measures in public premises.


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Municipal energy and climate adviser.

2004-2009 energy efficient windows and bio-fuel; 2006-2010 conversion from electricity to renewable energy; until 2012 Solar cells and solar energy

6.1.11 TURKEY

MANAGEMENT


National : Ministry of Culture and Tourism. Ministry of Culture and Tourism is responsible for historical and cultural heritage protection in Turkey. Their main obligations are as following;

• To investigate, protect, develop and disseminate national, spiritual, historical, cultural and touristic values in Turkey,

• To lead relevant agencies and institutes, • To improve public awareness about cultural

and historical heritage.

General Directorate of Monuments and Museums is the foundation within the ministry. The general directorate plays an important role in archaeological investigations, restoration works, establishment of museums, ensuring the protections of Turkish/Ottoman heritage outside Turkey, etc.

Regional level . Cultural and Natural Heritage Preservation Board under Ministry; Protection Directorates of Historic Environment, Directorate of Protection, Application and Control under urban municipalities where Cultural and Natural Heritage Preservation Board is the decision making and Directorate of Protection, Application and Control is the auditing body. Additionally in Istanbul; Istanbul Cultural and Natural Sites Management Directorate, Istanbul Heritage Committee

Ministry of Environment and Urbanization which is responsible for environment and urban planning in Turkey and aims to use energy and energy sources in buildings effectively and efficiently, to stop energy waste, and to protect the environment. Buildings are obliged to get Energy Performance Certificate provided by universities, professional chambers and energy consulting firms whose authorities are given by Ministry of Energy and Natural Resources, Renewable Energy Working Party. National level. Ministry of Energy and Natural Resources, Ministry of Environment and Urbanization Regional level. Responsible authority: Provincial Directorate of Environment and Urbanization, Urban Municipalities assembly and from various municipalities.




Currently, there is not any governmental cooperation between heritage management and energy management in Turkey. However some private attempts have been realized. In Istanbul, there is one historic building which has obtained LEED certificate.

The Turkish goals are

- reduce energy density 15 % by 2020

- reducing electrical energy density min. 20 % by 2023

- To increase the number of countrywide qualified/certified energy manager at least to 5000 and the number of energy


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consulting firms specialized in industry sector at least to 50 by the end of 2015

- To increase the number of novel design and/or product based on domestic R&D results regarding energy efficiency and renewable energy resources at least 50 by the end of 2023.

The goals will be achieved by

- increasing CO2 emission tax beginning from 2015 to the buildings which don’t have an appropriate thermal insulation based on building energy performance legislation

- favourable financing and tax

- restriction of sale of products which are not energy efficient

- authorizing energy consultancy firms to provide service in trainings, research, project and consultancy

- technology plan

- strategic communication plan



General Directorate of Monuments and Museums is the foundation within the ministry. The general directorate plays an important role in archaeological investigations, restoration works, establishment of museums, ensuring the protections of Turkish/Ottoman heritage outside Turkey, etc. Additionally, for the maintenance, repairing, restoration, and administration of the palaces, pavilions and museums there is Department of National Palaces, as a unit within the structure of the General Secretariat of TBMM (Turkish Grand National Assembly). There are also non-governmental organizations founded for preservation of built environment, cultural heritage and natural sources such as Foundation for the Protection and Promotion of the Environment and Cultural Heritage, Union of Historical Towns, 'The History, Archaeology, Art and Cultural Heritage Foundation.

Turkish national legislation regarding energy performance and minimum energy requirements such as ventilation and air-conditioning systems, energy requirements for the production of hot water has been regularized according to EPBD. All updated specifications and standards are stated in Turkish Standards Institution (TSE) 3419. If there is not any specification for any certain issue, standards in EPBD should be considered. Heat insulation calculations and applications of buildings and built environments must obey procedures and principles described in TS 825 (Turkish Standards). The report regarding maintenance and testing required for efficiency of lightening, electrical, mechanical and architectural systems which affect energy performance of buildings should be prepared within the scope of the legislation and submitted to the approval. Building owner, manager, administrative body and/or energy manager are responsible for maintenance and testing of buildings. The building envelop of an existing building cannot be changed in such a way that energy performance will be influenced adversely.


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CATEGORIZATION

1. Historic buildings having architectural value in global, national and local level, Palaces, ancient/mediaeval constructions, architectural examples of religion and military

2. Civil architectures composing urban environment, built by traditional construction techniques. Ancient factories, warehouses, apartments, buildings, etc

1. Historic environments having architectural value in global, national and local level. Palaces, ancient/mediaeval constructions, architectural examples of religion and military constructions, etc.

2. Civil architectures composing urban environment, built by traditional construction techniques. Ancient factories, warehouses, apartments, buildings, etc.


There is only one restriction concerning energy performance in historic buildings and environments, which is that feature and external appearance of historic buildings should not be affected by energy efficiency enhancement applications.

Comes into force when consolidation, liberation, reintegration, renovation, reconstruction, changed use and moving. Substantial repair of existing buildings must meet TSE 825 energy requirements.

Parts: the whole building.

Control : Ministry and/or organizations authorized by the ministry perform controls concerning energy consuming equipments and periodic maintenance of the buildings.

Responsible control entity when: a) there are important and critical areas and tasks b) the municipality requires that after a specific assessment.



The national legal methodology for the calculation of the minimum energy performance of buildings is defined in TS 825. The methodology in regulation of energy performance of buildings (BEP-TR) is based on simple hourly method which has easier algorithm compared to dynamic method.

POTENTIAL CONFLICTS

Even though energy performance legislation came into force in Turkey, there are not many implementations concerning heritage protection and energy efficiency.

STIMULATION


Yes. Energy performance certificate is provided by authorized organizations which are authorized architect and engineer for new buildings, energy consultancy firms for existing buildings


Seminars, workshops, conferences organized by municipalities, ministries, Istanbul Chamber of Commerce, Istanbul Chamber of Industry, etc.

Turkey Sustainable Energy Financing Facility (TURSEFF), European Bank for Reconstruction and Development (EBRD), Kreditanstalt für Wiederaufbau (KfW), Global Environment Fund


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(GEF), United Nations Development Programme (UNDP), Agence Française de Développement (AFD)


Energy consultancy firms Provided by Scientific and Technological Research Council of Turkey

6.1.12 UNITED KINGDOM OF BRITAIN AND NORTHERN IRELA ND (UK)

MANAGEMENT


Regional: England: English Heritage (non-departmental public body reporting to UK government) Northern Ireland: Department of the Environment, Northern Ireland Executive Scotland: Historic Scotland (agency of the Scottish Government) Wales: Cadw (agency of the Welsh Government) Local: The planning departments of local authorities manage the heritage-protection system ‘on the ground’ by administrating applications for Listed Building Consent, Conservation Area Consent etc. Where a building is in the ownership of a local authority, heritage management for the building is handled on a regional level.

National : Department of Energy and Climate Change, UK government, responsible for setting framework policies.

Regional: England and Wales (also see ‘Wales’ below): Department for Communities and Local Government, UK government Northern Ireland: Department of Finance and Personnel, Northern Ireland Executive Scotland: Building Standards Division, Scottish Government Wales (also see ‘England and Wales’ above): Environmental and Sustainable Development Directorate, Welsh Government Local : The building-control departments of local authorities manage the building-control system ‘on the ground’, for example by administrating applications for building permission (in England, Northern Ireland and Wales) and building warrants (in Scotland). Within England and Wales, an applicant has the opportunity to employ an approved, private building-control organisation as opposed to the local authority. In Scotland, an applicant has the opportunity to employ an approved private building-standard organisation for some building-regulation requirements, including requirements concerned with energy performance, as opposed to the local authority.


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Heritage-management and building-control authorities consult with each other when developing new governmental policies and legislation. However, the division into planning / heritage-conservation on one side and building control on the other side means that ‘on the ground’ building developers / owners need to negotiate with both authorities to find solutions satisfying the requirements of both authorities. An example for such cooperation is that the Building Standard Division of the Scottish Government had invited Historic Scotland in 2012 to comment on proposed 2013 amendments to Scotland’s building regulations. Similarly, English Heritage has been part of previous working groups for revisions to certain parts of the English and Welsh buildings regulations under the UK government’s Building Regulations Advisory Committee. Another example of cooperation is Historic Scotland’s publication Conversion of traditional buildings: application of the Scottish Building Standards. This publication was developed together with the Scottish Government’s Building Standards Division (and its predecessors) and has for historic and traditional buildings the same guidance status as the Technical Handbooks of the Building Standards Division, namely illustrating solutions which comply with building regulations.

The UKs goals are - Reduction of greenhouse gas emissions by 2020

and 2050 against a baseline of 1990 levels.

- UK, targets are set as 34% for 2020 and 80% for 2050.

- Scotland, targets are set as 42% for 2020

The goals will be achieved by - Legislation. The building regulations set

minimum requirements for the energy performance for newly constructed buildings and for alterations, extensions and conversion (i.e. change of use) of existing buildings. The building regulations generally offer a flexible and practical approach to the improvement of the energy efficiency in traditional and historic buildings.

- Financial . Green Deal, a financial instrument

supporting the energy-efficiency retrofit of existing buildings, by allowing building owners to improve their buildings with no upfront capitals cost and instead pay for the improvement measures by instalments on their future electricity bills. As part of the Green Deal, financial subsidies are being made available through the so-called Energy Company Obligations for some retrofit measures in ‘vulnerable properties’, for example, solid wall insulation in historic buildings.



Historic buildings Historic buildings are, when heritage-designated through ‘listing’, protected through the requirement for seeking Listed Building Consent prior to commencement of any construction works which might impact on the ‘character’ of the building. This protection is to manage change in the historic environment, rather than preventing change from happening.

Historic environments Historic environments are protected through the planning system by heritage-designations, such as conservation area (i.e. heritage area), battlefield site, designated garden or design landscape, etc. This protection is to manage change in the historic environment, rather than preventing change from happening.

EPBD is implemented into national legislation. There are no minimum energy-performance requirements for existing building to date in the legislation, except where existing buildings are altered, extended or converted (i.e. change of use). In such cases, building-regulations requirements must be met. There are no exemptions for this requirement for historic buildings, including listed buildings, but with the exception of buildings heritage-designated as scheduled monuments. However, for historic and traditional buildings, meeting building-regulation requirements must only be met as far as is reasonably practical. This means that meeting requirements (in full) might not be necessary for such buildings where this would impact negatively on the character of a building, including its heritage significance. An example for this is insulating solid walls, where it may not be


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appropriate to aim for a U-value of 0.3 W/(m2·K), as prescribed by the building regulations. However, it is required to demonstrate that the level of improvement in each area of the building has been fully considered. For example, where a building is being upgraded, there may be greater scope for improvement in building services than in fabric or there may be more scope for fabric improvements in parts of the buildings that are later additions or are of lesser heritage significance. In England, Display Energy Certificates (DECs) are required for all public buildings (including historic buildings) with a floor area between 500 and 1,000 m2 every decade and over 1,000 m2 every year. This does not apply to Scotland. .

CATEGORIZATION

Historic buildings Listed buildings are categorised into 3 groups, which are sometimes described as indicating if the building is of international or national importance; of regional importance; or of local importance. However, these descriptions are legally not set down.

England and Wales: Grades I, II* and II Northern Ireland: Grades A, B+ and B1 Scotland: Categories A, B and C Wales: see ‘England and Wales’ above

Specialist categorisation exists e.g. for religious buildings.

Historic environments Historic environments are categories, for example, by inclusion in inventories for conservation areas; gardens and designed landscapes; and battlefields.


Comes into force when altered, extended or converted as far as is reasonably practical. However, meeting these requirements might be restricted to the affected building elements and might, for historic and traditional buildings, be restricted to as far as is reasonably practical.

Parts: Requirements are Limeted to the renovated parts, unless the building also under-goes a conversions

(i.e. a change of use) when the whole building must meet the set requirements

Control : Where works are subject to building regulations, it is the responsibility of the relevant person (normally the building warrant applicant or building owner) to ensure that works comply. Where works are the subject of a building warrant, the applicant must certify this on completion of the works and the local authority will carry out ‘reasonable inquiry’ before accepting such a certificate.

Requirement for competency: There are professional building-conservation and -sustainability accreditation-schemes for architects, structural engineers, etc. There are accreditation schemes for EPC and Green Deal assessors. There are no combined accreditations for energy efficiency in historic buildings. There are no legal requirements for using conservation- or sustainability-accredited personnel for the planning or implementation of energy-efficiency retrofits for historic buildings


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The national calculation method (NCM) in the UK is as listed below:16

For new-build domestic: SAP2009 (derived from BREDEM) For existing domestic: RdSAP For new-build and existing non-domestic buildings: SBEM https://www.gov.uk/standard-assessment-procedure http://www.bre.co.uk/sap2009/ http://www.ncm.bre.co.uk/

POTENTIAL CONFLICTS

Over-cladding of the exterior of a building with external wall insulation is often considered unacceptable in the case of historic buildings, as this would impact negatively on the character and thereby the heritage significance of the building. Installing double glazing is a contentious issue for aesthetic reasons and because of the loss of original window frames and glass. This can be resolved by a mixture of refurbishment to reduce draughts, secondary glazing to preserve the exterior look of the window and the resurrection of original shutters.

STIMULATION


No advantage for energy-efficiency retrofit; advantages for replacing existing building stock through newly constructed buildings by VAT exemption for the latter, but not for the repair of existing buildings.

Energy Performance Certificates (EPCs) are required on newly constructed buildings, buildings for sale and rental and for certain categories of public buildings. This is not specific to historic buildings or historic environments. In England, building regulations do not require EPC for listed buildings. However, EPC for listed buildings are, for example, required to qualify for improvement measures under the Green Deal scheme. In Scotland, building regulations do require EPC for listed buildings. In addition, the Energy Act 2011 contains provisions for a minimum standard for private rented housing and commercial rented properties from 2018, and the UK government intends for this to be set at an EPC rating of ‘E’.


Information from organisations such as Carbon Trust, Energy Saving Trust, Society for the Protection of Ancient Buildings, Institute of Historic Building Conservation, English Heritage, Historic Scotland, guidance tool to assist Green Deal.

With the Green Deal the UK government has implemented in late 2012 a financial instrument for supporting energy-efficiency retrofit of existing buildings.


Through regional programmes, such as free insulation retrofits (however, these programmes are not specific to historic buildings or historic environments)

16 The exact procedure on how to use the legal methodologies varies between England, Northern Ireland, Scotland and Wales.


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6.2 Conflicts and Policy

This chapter discusses the relationship between cultural heritage management and energy efficiency,

legislations on the basis of data collected.

The requirements given in EPBD shall apply to all existing buildings, but there are exceptions for officially

protected buildings as part of a designated environment or because of their special architectural or historical

merit. But the exception applies only as long as energy saving measures cannot be implemented without

unacceptably alter their character or appearance.

Although EPBD allows the requirements to apply to listed buildings and environments as long as energy saving

measures cannot be implemented without unacceptably alter their character or appearance, relatively few

countries require this. The table below shows that only 3 out of 12 let the requirements apply on officially

protected buildings. The table also shows that the vast majority let the requirements apply on non-official

protected historical buildings. There are however a number of variations, where the requirement is adapted in

such a way that the building's historic qualities are not damaged.

Table 3: Summary of national responses related to w hen the requirements apply

6.2.1 Conflicts area

In general, there seems to be three main problem areas related application of requirements for energy

efficiency in historic buildings. This is replacing, retrofitting, repair windows or doors, external insulation and

solar panels on the roof. These are areas where the national legislation on Energy efficiency measures

interferes with historic buildings, in a way that the participants perceive as problematic and harmful.


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Table 4: Summary of the ratio between the various p roblem areas.

Although the survey did not reveal any clear legal controversies, it reveals some problematic aspects of the

practical administrations of the national legislation.

Conflict of interest on a political scale

The legislations and the practice is often perceive as unclear. “The municipalities will in most cases be

responsible for balancing the interests – heritage management and energy saving. This balance has

proved in practice to vary greatly between different municipalities.” (Reference in the survey: Norway).

This points to the undesirable situation that there are no or limited coherent practice. This also

suggests that there has been no priority to create a unified policy. The decision is left to some degree

of randomness and is strongly influenced by political compositions. Different practices also undermine

the citizens' ability to predict the outcome of a decision. .” (Reference in the survey: Norway, appendix

2)

In Netherland, requirements for energy efficiency, renovations and retrofitting, seems to be hindered by

strong civil rights for the building owner:

“The Dutch markt for renovation and retrofitting is a difficult chapter for energy saving because owners

and occupants have a ruling vote. If they rent the place they have a strong vote to deny the increase of

rental cost due to improvement actions and if they are owner they have to decide themselves on there

investment (often the pay-back time is too long to make it interesting). Implementation of EPBD 2010

harms other legal rights that are set in the Dutch building market.” (Reference in the survey:

Netherlands, appendix 2) This is also pointed out in feedback from UK, but in another context.

“[B]uilding developers / owners need to negotiate with both authorities to find solutions satisfying the

requirements of both authorities.” In this case communication between the public bodies goes through


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the owner / developer, which can cause blurred guidelines and may be subject to misunderstandings.

(References in the survey from: UK, appendix 2).

Conflicts on management/administration level

Some answers point to the problematic in that cultural heritage authorities come late in the process or

that the communication between the public bodies are unclear. In the case of cultural heritage

authorities coming late into the process, means they have limited opportunity to influence the process

in the direction of protecting the building's historic and architectural values. This could also have a

negative impact on the owner / developer economical and practical planning. The same seems to apply

in the opposite cases, in the sense that cases processed by cultural heritage authorities just to some

degree considering energy saving measures. (References in the survey from: Sweden, Turkey and

Greece, appendix 2).

6.2.2 Finance situations

The participating countries have initiated a number of measures to increase the stimulation of energy efficiency

measures in buildings and environments. The Directive has not specified which financial instrumented is to be

used to stimulate energy efficiency measures in buildings, and it has been up to the individual countries to find

suitable instruments. It is stated in the REPORT FROM THE COMMISSION TO THE EUROPEAN

PARLIAMENT AND THE COUNCIL of 18.4.2013: Financial support for energy efficiency in buildings on page

10 that it is imperative to improve the financial support for energy efficiency in buildings.

The table below gives an overview of the financial and technical measures, the participating countries have

introduced. Typical financial measures relating to direct subsidies / funding, tax benefits and attractive financing.

This is an area EU aims to get more uniform practice in the coming years.

Table 4: Summary of the ratio between the various m easures to stimulate energy performance.


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6.2.3 Compilation of the country's main practices a nd policies

Main policy Webpages

France All buildings pre 1948 is exempt from

requirements.

Comes into force :

Parts : the whole building.

Control : energy diagnosis (certificate)

Greece Under the provision of article 11 of Law 3661/2008 and as clarified in the relevant Circular ‘All buildings and monuments protected by the law due to their classification as part of a specific environment or their architectural / historical value (as in the case of historical buildings), are obliged to an assessment of energy performance in case of major renovation, given that their compliance with the Law 3661/2008 and the KENAK would not result in altering their characteristics or appearance in an unacceptable manner.

In this case, energy classification of the building under the provision of article 5 of Law 3661/2008 is carried out to the extent that this is technically, functionally and economically feasible.


e) Monuments

f) Buildings officially protected as part of a specific environment or due to their special architectural or historic value (listed within traditional settlements, etc.), provided that their compliance with minimum energy performance requirements would not result in altering their characteristics or appearance in an unacceptable manner.

g) Buildings used as places of worship or for religious activities

h) Buildings of temporary use with duration not exceeding the period of two years according to their design, industrial facilities, craft industries, laboratories, warehouses, parking lots, gas stations, non-residential buildings for agricultural uses with low energy requirements and buildings used by a sector under a national agreement regarding buildings’ energy performance.

Comes into force when renovation requires a Building Permit or major E/M elements e.g. boilers, lifts, E/M installations, etc. are upgraded. The certificate is not detached to

http://gis.ktimanet.gr/wms/ktbasemap/default.aspx


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current or future use of the building

Parts . It applies to the whole building but is to the discretion of the owner (depending on the nature of works, cost and custom needs of each one) to apply these requirements to the whole building or at a part of it.

Control : through energy inspectors and certificates.


Hungary Comes into force when major renovation and major extension (see question 14/a) §6 of Decree of Minister without Portfolio No. 7/2006 (V. 24.)

- State-owned, public-used building, with larger than 1000 m2 of useful floor area:

◦ I. By renovation for energy saving purposes, only the involved building components. §6 of Decree of Minister without Portfolio 7/2006 (V. 24.)

◦ II. By minor extension, only the new bordering structures §6 of Decree of Minister without Portfolio 7/2006 (V. 24.)

The protected historic buildings (urban areas) are exceptions of the cases above. The cited regulation defines further exceptions. Parts: only the changed parts of the building is covered by the requirements Control : building’s authorization Requirement for competency: Only senior architect can design protected historic building.

Italy Listed buildings are not compulsorily subjected to any energy standards (DPR 59/09 art1).

Historic not listed buildings the same requirements of energetic performance as the new buildings. For interventions of major renovation, they have the same requirements as the new buildings in terms of energy performances. For interventions of minor renovation, such as partial substitution of the external walls or partial substitution of the roof, the energy performances are required only for the new components as a transmittance limits.

Comes into force when there is a major renovation for buildings with a surface >1000 m2 the building has to meet the energy requirements at national and regional level. The requirements are the same as those for new buildings.

Parts : In case of major renovation the minimum


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energy performances are required for the whole building. In case of partial renovation of the external walls or of the roof, the energy performances are required only for the new parts as

Control: control during the construction.


Republic

of

Ireland

The requirements do not apply to works (including extensions) on an “existing building which is a “protected structure” or a ‘proposed protected structure” within the meaning of the Planning and Development Act 2000 (No 30 of 2000). Nevertheless, the application of this Part may pose particular difficulties for buildings which, although not protected structures or proposed protected structures may be of architectural or historical interest. Works such as the replacement of doors, windows and rooflights, the provision of insulated dry lining and damp-proofing to walls and basements, insulation to the underside of slating and provision of roof vents and ducting of pipework could all affect the character of the structure. In general, the type of works described above should be carefully assessed for their material and visual impact on the structure. Historic windows and doors should be repaired rather than replaced, and dry lining and damp proofing should not disrupt or damage historic plasterwork or flagstones and should not introduce further moisture into the structure.

Roof insulation should be achieved without damage to slating (either during the works or from erosion due to condensation) and obtrusive vents should not affect the character of the roof.

In specific cases, relaxation of the values proposed may be acceptable, to the local building control authority, if it can be shown to be necessary in order to preserve the architectural integrity of the particular building.”

17

Comes into force: all building works, which imply material alterations or material change of use are required to comply with the Building Regulations, Part L, Conservation of Fuel and Energy.

Parts: only to the refurbished parts of the building. In case of a new extension to an existing building would only apply to the newly built floor area.

Control: No energy performance assessment after works have been completed and are required or established. However, works of

www.ahg.gov.ie/en/Heritage

www.buildingsofireland.ie/

www.dcenr.gov.ie/Energy/

http://www.seai.ie/

17

Building Regulations, Part L


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“Major Renovation”, which include works of material alteration or material change of use according to Irish regulation, require planning permission through a planning application. This planning application has to be accompanied by a Building Energy Rating (BER) certificate, which represents the proposed works regarding their energy performance. The building authorities depend solely on the credibility of certified BER assessors, whose standards are regulated by the Sustainable Energy Authority Ireland (SEAI), a government agency.

Requirement for competency: Only when the building is protected.

Netherlands For CH buildings the local authorities decide per case whether or not retrofitting actions are allowed. Each authority more-or-less uses its own interpretation for that with the main baseline ‘not to harm the authentic appearance of the building’. The local authority is set by the Monument law. Comes into force new buildings, or if owner/occupants/user agree Parts: Only when renovation can be considered as new construction or re-use/transformation of the building Control : no control Requirement for competency: Yes, for some applications certification is needed e.g. cavity wall insulation, ETICS

Norway Comes into force

- all changes in buildings defined as "measures" in the Act, except normal maintenance.

- alteration or repair of structures that are so extensive that the whole structure is substantially renewed (major renovation).

- change of use.

Parts: When major renovation – the whole building. Otherwise the renovated parts.

Control : Responsible designers and responsible contractor shall have a system to ensure and document that the legal requirements are met. In addition, it shall be conducted independent audit of responsible control entity when: a) there are important and critical areas and tasks b) the municipality requires that after a specific assessment.


www.ra.no

www.enova.no

www.nve.no


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Portugal Regulation does not apply to “refurbishment, restoration and expansion interventions of buildings in historic areas or on classified buildings, where there are incompatibilities with the requirements this regulation. The most current reason is the aesthetical impact of energy efficient refurbishment, or the practical impossibility to fit typical retrofit elements to historical buildings. Aspects of plastic facades, dictated by its architectural features, may make the process of applying insulation and preclude its implementation from the outside, possibly with implications of various kinds, namely, in the case of listed buildings (heritage) or relevant Architectural interest. Minimum energy performance requirements are applied to the whole building or dwelling unit (apartment).

Comes into force Major refurbishment or alteration whose cost exceeds 25% of the building, based on a reference value per square meter of building typology and set annually by joint order of the ministers responsible the areas of economy, public works, environment, spatial planning and housing, published in October and valid for the next calendar year.

Parts: only the changed building part or construction part must be covered by the requirements

Control : by documentation, certificate, declaration from the technician responsible and statement of Regulatory Compliance signed by a qualified expert

Requirement for competency: no



Spain The cultural interest statement answers to the following classes: monument, historic set (historic environment), historic garden, site or historical territory, archaeological site, place of ethnographic interest and paleontological area. Historic buildings and historic environments are excluded from minimum energy performance requirements.

Sweden General guidance is that historic buildings may exceed energy performance limits by 20%. Different limits for different climate zones in Sweden. Protected building and historic buildings may not be altered in an unacceptably way. Since building permits and physical planning is ultimately a political decision it is unclear how the new energy chapter will hit against the historic buildings protected in municipal development plans. However the state, represented regional by County Administrative Board, are remittance office in physical planning and in appealing building permits. But administrative board is not only dealing with cultural environments – they have

www.energiaktiv.se


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different interests like traffic planning, access of water and energy, economic growth etc. Then the cultural buildings and environments that are not protected by the Cultural Monuments Ordinance have difficulties being acknowledged.

Comes into force when significant change of use or that the building will have a significantly extended service life.

Parts: only the changed building part or construction part must be covered by the requirements

Control : through certificate

Requirement for competency: no

Turkey There is only one restriction concerning energy

performance in historic buildings and environments, which is that feature and external appearance of historic buildings should not be affected by energy efficiency enhancement applications.

Comes into force when consolidation, liberation, reintegration, renovation, reconstruction, changed use and moving. Substantial repair of existing buildings must meet TSE 825 energy requirements.

Parts: the whole building.

Control : Ministry and/or organizations authorized by the ministry perform controls concerning energy consuming equipments and periodic maintenance of the buildings.

Responsible control entity when: a) there are important and critical areas and tasks b) the municipality requires that after a specific assessment.


United

Kingdom of

Britain and

Northern

Ireland

Comes into force when altered, extended or converted as far as is reasonably practical. However, meeting these requirements might be restricted to the affected building elements and might, for historic and traditional buildings, be restricted to as far as is reasonably practical.

Parts: Requirements are limited to the renovated parts, unless the building also under-goes a conversions (i.e. a change of use) when the whole building must meet the set requirements

Control : Where works are subject to building regulations, it is the responsibility of the relevant person (normally the building warrant applicant or building owner) to ensure that

https://www.gov.uk/standard-assessment-

procedure http://www.bre.co.uk/sap2009/ http://www.ncm.bre.co.uk/


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works comply. Where works are the subject of a building warrant, the applicant must certify this on completion of the works and the local authority will carry out ‘reasonable inquiry’ before accepting such a certificate.

Requirement for competency: There are professional building-conservation and -sustainability accreditation-schemes for architects, structural engineers, etc. There are accreditation schemes for EPC and Green Deal assessors. There are no combined accreditations for energy efficiency in historic buildings.

There are no legal requirements for using conservation- or sustainability-accredited personnel for the planning or implementation of energy-efficiency retrofits for historic buildings


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7 Conclusion and Recommendations

Based on collected data, it is not discovered any direct conflict between legal systems in this survey, neither on

International, European or national level. One reason for this may be that the European legislations and the

International legislations have broad formulations. This is especially true of International Conventions and

Charter, which also are considered soft law, which refers to a quasi-legal instrument which do not have any

legally binding force and work more as guidance. Regulatory authorities in each country are therefore relatively

free to adapt the requirements into national regulations in a way ensuring that they do not come in conflict with

existing national legislation. Unclear or undefined legislation leads to much room for discretion. This leads to

different practices, based on the political composition. Lack of legal conflicts is probably also related to the fact

that most participating countries seems to have adopted the Directive EPBD2010 fully. This also applies for the

participating countries which is not a Member State.

EU law makes a clear distinction between officially protected buildings or environments and non-officially

protected buildings or environments, where non-officially protected buildings or environments in principle shall

be treated equally with all other existing buildings and environments, when it comes to requirements for energy

efficiency. This concept is implemented in the guidance document “Cost-optimal methodology framework”.

When it comes to national legislations and policies, none of the participants expressed for clear rules or

common policy related to the use of the requirements on non-official protected historical buildings or

environment. On the contrary, it is shown that some participants consider the policy unclear and that it only to

some degree exists a common policy or practice in this area.

The survey also shows that communication and cooperation between relevant bodies can be improved. A close

dialogue between relevant public bodies should lead to the development of a common national standard.

There is further a need to develop a common method of cost-optimal methodology framework which is suitable

for historic buildings and environments. Existing methods are not designed to deal with the specific problems

which occur when the requirements are applied in historic buildings. A method that is particularly suitable for

historic buildings, will not only be useful for calculating efficiency without harming the building or environment, it

is likely that it causes the current policy and practice to follow.


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8 Appendix A

Section 1: Blank questionnaire

Section 2: Completed questionnaire from participati ng country

Section 3: EU No 244/2012: Cost-optimal methodology framework

Section 4: 3encult 2011: Suggestions on energy perf ormance calculations for historic buildings


conservation. Appendix A_Section 1

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8.1 Section 1: Blank questionnaire

QUESTIONNAIRE

***

IDENTIFICATION AND EVALUATION OF EUROPEAN AND NATIO NAL POLICIES AND LEGISLATION

RELATED TO ENERGY EFFICIENCY AND CULTURAL HERITAGE CONSERVATION

Task Leader: NTNU

Introduction

As part of the commitment of meeting EU targets for the reduction of CO2 emissions, EFFESUS (Energy

Efficiency for EU Historic Districts' Sustainability) is a four-year European Union research project addressing

the energy efficiency of individual buildings, buildings ensembles and districts, as well as their energy supply

from renewable sources. EFFESUS is a consortium of 23 partners in 13 countries comprises research, industry

and policy makers, and is coordinated by the Spanish research organisation Tecnalia.

The purpose

The purpose of this enquiry is to establish an overview of current national legal status and policies in Europe in

situations where energy performance requirements are applied to historic buildings, groups of buildings and

urban districts, for the purposes of improving their energy efficiency and facilitating energy supply from

renewable sources. It is of particular interest to map possible contradictions and conflicts between energy

efficiency and heritage conservation requirements.

Definitions

“Historic buildings” in this questionnaire, shall refer to architecturally, culturally and historically valuable

buildings, regardless of legal status, built prior to 1945.

“Historic environments” in this questionnaire, shall refer to architecturally, culturally and historically valuable

groups of buildings or districts, regardless of legal status, built prior to 1945.

“Heritage management” in this questionnaire shall refer to the official administration of a legal heritage

protection system concerned with the built environment.

“Major renovation” in this questionnaire shall refer to the renovation of a building where: (a) the total cost of the

renovation relating to the building envelope or the technical building systems is higher than 25 % of the value of

the building, excluding the value of the land upon which the building is situated; or (b) more than 25 % of the

surface of the building envelope undergoes renovation.18

18

Directive 2010/31/EU OF THE EUROPEAN PARLIAMENT AND CONCIL of 19 May 2010 on the energy performance of buildings (recast) Article 1

(hereinafter Directive 2010/31/EU)



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“European standard” means a standard adopted by the European Committee for Standardization, the European

Committee for Electrotechnical Standardisation or the European Telecommunications Standards Institute and

made available for public use.19

“Energy performance of a building” means the calculated or measured amount of energy needed to meet the

energy demand associated with a typical use of the building, which includes, inter alia, energy used for heating,

cooling, ventilation, hot water and lighting.20

“Energy performance certificate” means a certificate which indicates the energy performance of a building or

building unit, calculated according to a methodology adopted in accordance with Article 3, Energy Directive

2010/31/EU.21

Explanation

“EPBD – Energy Performance of Buildings Directive”

In 1993 the EU Council Directive (93/76/EEC) has been issued to limit carbon dioxide emissions by improving

energy efficiency, through recommendation for new buildings and for improving the energy efficiency in the

existing building stock.22

In 2002 the EU Directive on the Energy Performance of Buildings (EPBD) was published (Directive

2002/91/EC), requiring all EU countries to enhance their building regulations and to introduce energy

certification schemes for buildings.23

The recast of EPBD was adopted in 2010 (Directive 2010/31/EU), clarifying and simplifying certain provisions,

and extending the scope, moving towards more effective measures.24

Adoption of a methodology for calculating the energy performance of buildings

In the Article 3 of Directive 2010/31/EU it is stated that Member States shall apply and adopt a methodology for

calculating the energy performance of buildings at national or regional level. This methodology is based on the

common general framework for the calculation of energy performance of buildings.25

Setting of minimum energy performance requirements and exceptions for certain categories of buildings

In the Article 4, paragraph 1, of Directive 2010/31/EU, it is stated that Member States shall take the necessary

measures to ensure that minimum energy performance requirements for buildings or building units are set with

a view to achieving cost-optimal levels.

However, in the same Article, paragraph 2, it is stated that Member States may decide not to apply the

necessary measures to several categories of buildings including buildings officially protected as part of a

designated environment or because of their special architectural or historical merit, in so far as compliance with

certain minimum energy performance requirements would unacceptably alter their character or appearance.26

19

Article 2, Directive 2010/31/EU 20



http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:1993:237:0028:0030:EN:PDF 23



Annex I of the Directive 2010/31/EU 26

Article 4, Directive 2010/31/EU



EFFESUS • 314678 • of 262

QUESTIONNAIRE

BACKGROUND DATA.

1. Please state the name of the country.

If there are differences in legislation between the various regions within a country, one or more regions may be described in the followi ng questions. Please state the name of the region you will be answering the questi ons for.

2. Please explain how the heritage management (authori ties) are organized and what their obligations are. Please describe the heritage management on a) national level b) regional level c) local level d) other

3. Explain how the authorities which regulate energy p erformance in buildings (energy management) are organized and their obligat ions. Please describe the energy management on a) national level b) regional level c) local level d) other

4. Please describe the cooperation between heritage ma nagement and energy management, and give an overview of possible confli cts. Please illustrate the cooperation with an example.

5. Please describe the national political goals for re ducing emissions (CO2 ) and promoting energy saving measures in existing buildi ngs, historic buildings and historic environments.

6. Please describe how the goals in question 5 are proposed to be achieved.



EFFESUS • 314678 • of 262

CULTURAL HERITAGE LEGISLATION AND ENERGY PERFORMANC E OF BUILDINGS DIRECTIVES (EPBD)27

7. a) Describe the national and regional legal systems for protecting historic buildings.

b) Describe the national and regional legal systems for protecting historic environments.

8. a) How are historic buildings categorized? 28 Please give examples from the different categories.

b) How are historic environments

categorized?

Please give examples from the different

categories.

9. a) How is national legislation influenced by EPBD? b) Please state any other international charters, c onventions or principles that have relevance for national legislation regarding energy performance in historic buildings or historic environments.

10. Describe the national legal requirements for minimum energy performance in existing buildings and built environments.

11. a) In what ways are historic buildings and historic environments 29 excluded from or included in the minimum energy performance requirem ents for existing buildings?

Can you please give examples? b) If some historic buildings and historic environm ents are excluded from the requirements, what is the most common reason? 30 Can you please give examples?

27

Directive 2010/31/EU OF THE EUROPEAN PARLIAMENT AND CONCIL of 19 May 2010 on the energy performance of buildings (recast) 28

For instance:

- listed buildings and buildings of same dignity as listed buildings in the Heritage Act (or other relevant)

- buildings of certain historic, environmental or artistic significance

- buildings with positive significance for the cityscape and/or some cultural value

- buildings of national, regional or local interest 29

As defined on the page 1 30

Loss or damage on cultural heritage, economics, lack of funding etc.



EFFESUS • 314678 • of 262

12.

Describe the national legal me thodology for the calculation of the minimum energy performance of buildings. 31

13.

Is life cycle assessment (LCA) a part of the evalua tion of the energy performance in buildings?

14. In these questions we would like to know in which s ituations the r equirements for minimum energy performance in buildings would come into force: a) How is “major renovation” defined in national le gislation and will minimum energy performance requirements in buildings come i nto force when it is applied for “major renovation”? 32 Please explain. b) Will minimum energy performance requirements in buildings come into force when the use/function of a building is changed? Please e xplain. c) Please describe other situations when minimum en ergy performance requirements will come into force?

15. After renovation or other situations (see question 14), h ow can the authorities control whether the legal requirements for minimum energy p erformance actually are met?

16 Are minimum energy performance requirements limited only t o the renovated parts or to the whole building?

17. In what ways are the national legal requirements fo r minimum energy performance (in historic buildings and historic environments) s timulated? Through:

yes no Please explain:

a) direct subsidies / funding?

b) advantages / disadvantages through taxation?

c) attractive financing?

d) information?

31


As defined on the page 1



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e) energy performance certificate? 33

f) technical assistance and advice?

Other? Please explain:

18. Are there or can there be applied a requirement for competency or experience when working with historic buildings and energy efficien cy?

19. Please give examples of conflicts and solutions to implementing (different) energy efficient measures and their compatibility with heritage protection legislation.

20. Please give any further comments or suggestions.

To the person(s) who fills out the questionnaire, p lease provide:

Name:

Affiliations:

Full contact details:

Thank you for your participation.

33




EFFESUS • 314678 • of 262

8.2 Section 2: Completed questionnaire from partici pating country

QUESTIONNAIRE

BACKGROUND DATA.


FRANCE

2. Please explain how the heritage management (authori ties) are organized and what

their obligations are.

THE MINISTRY IN CHARGE OF THE HERITAGE MANAGEMENT IS THE MINISTRY

OF THE CULTURE (they make law)

Please describe the heritage management on

a) national level

b) regional level there is the architect of historic monuments (they permit or not the

work)

c) local level there is the architect of French building, the same is existing at the national

level (they permit or not the work and they send their conditions)

d) other the mayor office, (they send to the architect the documents to allows the work)

3. Explain how the authorities which regulate energy p erformance in buildings

(energy management) are organized and their obligat ions.

The ministry in charge of this part is the development one.

They make the law in particular thermal regulations which are an obligation for the

person who work on new buildings having a thermal comfort, but this is not for the old

building.

For the old we have the rage regulation, which is not yet in application.

Please describe the energy management on

a) national level

b) regional level DREAL (regional management of environment and country planning)

c) local level ALE (local agency of energy)

d) other

4. Please describe the cooperation between heritage ma nagement and energy

management, and give an overview of possible confli cts.

only some local cooperations

Please illustrate the cooperation with an example.

In the loire valley, the natural park (Parks are zones of environmental protection,

(cultural, built…)) make some index cards for private and publics persons to inform them

how removing old and historic tuffeau’ stone building with energy gain without irreversible



EFFESUS • 314678 • of 262

damage (the best practice)

5. Please describe the national political goals for re ducing emissions (CO2 ) and

promoting energy saving measures in existing buildi ngs, historic buildings and


The government’s goals are to reduce more than 38% the energy consumption in 2020.

Reduce the energetic needed to 150 kWhep/m²/year

6. Please describe how the goals in question 5 are prop osed to be achieved.

The regulation thermal only for buildings before 1948, and for all the private buildings the

energetic’ perform diagnosis.

And RAGE and the afnor reulation which are not yet ready, (afnor in 4 years)

CULTURAL HERITAGE LEGISLATION AND ENERGY PERFORMANC E OF BUILDINGS

DIRECTIVES (EPBD)34

7. a) Describe the national and regional

legal systems for protecting historic

buildings.

Architects of French buildings are

responsible

b) Describe the national and regional


environments.

Architect of French buildings are

responsible

8. a) How are historic buildings

categorized? 35

-conservation aeras (concern the historic

district, Intended to guarantee the

protection and the development of these

historic districts) their regulation are based

on “psmv” “plan of protection and

development”.


categories.

(I think it’s clear)


categorized?

- accesses of historic monuments (500

meters around an historic building)

- registered and conservation areas (on

the point of view of natural heritage, to

protect areas which present some historic,

scientific, legendary or cultural interest)

For the registered areas, you have to ask

for the ABF 4 month before to do any

work on.

For the conservation areas, you have to

ask for an special authorisation for every

work you want to do to a special authority

which is “the departmental committee for

the nature, the landscapes and the sites

34


For instance:




- buildings of national, regional or local interest



EFFESUS • 314678 • of 262

( CDNPS)” and you have to add the

opinion of the ABF in application of urban

code.

Please give examples from the

different categories.

A castle, 500m around is the perimeter of

conservation, and you have to ask of the

special authorisations.

A conservation or registered area, it can

be a garden, like “les jardins de

Versailles”, or “archipel des glénans”

which represent in the Atlantic ocean 505

km² and 9 isles.

9. a) How is national legislation influenced by EPBD?

No real influence for the historic public building, no obligation. For the private one, there

is a diagnostic of energy consumption, and you have to give it to the new owner or to the

tenant of the apartment.

b) Please state any other international charters, c onventions or principles that

have relevance for national legislation regarding e nergy performance in historic

buildings or historic environments.

Areas of UNESCO protection.

10. Describe the national legal requirements for minimu m energy performance in

existing buildings and built environments.

Before 1948 there no requirements

11. a) In what ways are historic buildings and historic environments 36 excluded from

or included in the minimum energy performance requi rements for existing

buildings? Can you please give examples?

Totally exclude

b) If some historic buildings and historic environm ents are excluded from the

requirements, what is the most common reason? 37 Can you please give

examples?

This is cause of the conservation reason, to not destroy the heritage, or to not damage it.

12.

Describe the national legal met hodology for the calculation of the minimum

energy performance of buildings. 38

13.

Is life cycle assessment (LCA) a part of the evalua tion of the energy performance

in buildings?

NO

36


Loss or damage on cultural heritage, economics, lack of funding etc. 38




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14. In these questions we would like to know in which s ituations the r equirements for

minimum energy performance in buildings would come into force:

a) How is “major renovation” defined in national le gislation and will minimum

energy performance requirements in buildings come i nto force when it is applied

for “major renovation”? 39 Please explain.

b) Will minimum energy performance requirements in buildings come into force

when the use/function of a building is changed? Please e xplain.

No

c) Please describe other situations when minimum en ergy performance

requirements will come into force?

15. After renovation or other situations (see question 14), h ow can the authorities

control whether the legal requirements for minimum energy p erformance actually

are met?

By the energetic diagnostic and by an itemised bill which show the material perform of

the manufacturer.

16 Are minimum energy performance requirements limited only to the renovated

parts or to the whole building?

Whole building,( when it’s required.)

17. In what ways are the national legal requirements fo r minimum ene rgy performance

(in historic buildings and historic environments) s timulated?

Through:


a) direct subsidies /

funding?

no

b) advantages /

disadvantages through

taxation?

yes For private one VAT 7% (the national

legal one is 19.6%), and it’ll be 10ù since

2014.

For the social building this is 5% of VAT


Yes Bank credit at rate 0%, or preferencial

rate if you have already a bank saving

passbook of sustainable development.

d) in formation?

yes Through the local agency of energy which

is an state agency to help people to do

work with energy saving.

Through professional craftsmen who are

training for this kind of work like

39




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ecoartisans.

e) Energy performance

certificate? 40

yes

f) technical assistance and

advice?

yes Energy agency and another agency which

is Local program for the housing

improvement (a thermal diagnostic is

established)


New: to have any advantage as well as preferential rate, taxes, the craftsmen will have

to be “reconnu grenelle de l’environnement” which significant that they must be trained to

the save energy and they have to work in the way of saving energy.

We think that in few years the obligation for the new building will be adapted to the old

and historics one.

The legal rule for the new buiding is named “RT 2012” , the goal is 50 KWh/m²/an and in

2020, it will be positive energy.

18. Are there or can there be applied a requirement for competency or experience

when working with historic buildings and energy eff iciency?

Yes most of time, it depends on the importance of the historical heritage.

19. Please give examples of conflicts and solutions to implementing (different) energy

efficient measures and their compatibility with heritage protection legislation.

The solars panels are not authorized on the roof, the aspect of the buiding do not be

changed, windows must have the same aspect.


No obligation regarding of the historic heritage, and if it’s not registered no obligation

cause of the compatibility with old materials and new one.

But there are some progress in particular a committee had begun a work on the

standards of the heritage and it will be finished in 4 years (as effesus).

So we will have a look on this work.


Name: Virginie Gouas

Affiliations: Gouas


40




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QUESTIONNAIRE

BACKGROUND DATA.


If there are differences in legislation between the various regions within a country,

one or more regions may be described in the followi ng questions. Please state the

name of the region you will be answering the questi ons for.

Greece

Please see following questions regarding legislation application in Regions and Districts.



National level

Responsible authorities for Heritage Management:

Ministry of Environment, Energy & Climate Change

Ministry of Education and Religious Affairs, Culture and Sports

Central Architectural Committee

Responsible Bodies for Heritage Management:

Central Architectural Committee is an independent Public Body under the supervision of

the Ministry of Environment, Energy and Climate Change, responsible for the following

issues related to the protection of ancient monuments, archaeological sites and historical

sites:

a) Conduct Official Proposals to the Ministry of Environment, Energy and Climate Change:

For the principles governing the specific aspects of the protection of cultural heritage, as

defined in article 3 of Law 3843 (O.G. 62Α 28.04.2010)

For expropriation or direct purchases, excavations, restorations, maintenance and other

work on the monuments on an annual program basis.

b) Conduct Official Recommendations to any Authority involved, on issues related to:

Monuments, places and sites on a regional interest, as well as in the sea or in rivers or

lakes,

The protection of monuments registered in the List of World Heritage, and other monuments,

archaeological sites and historical places of major importance.

Interventions of major importance in monuments, archaeological sites and historical places,

The boundary and definition of archaeological sites, historical sites and protected areas in

accordance with the Articles 12 to 17 of Law 3843 (O.G. 62Α 28.04.2010),

Compulsory expropriation or direct purchase or exchange of buildings for the protection of

cultural heritage;

The transfer of monuments or the transfer/extraction of their components,

Authorization for demolition in accordance with Section 10 of Article 6 of Law 3843 (O.G.

62Α 28.04.2010),



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Characterization of monuments’ types

The exportation of monuments

Exchange of monuments belonging to the State,

Recognition of collectors and collections registered to the State in accordance with to Article

31 of Law 3843 (O.G. 62Α 28.04.2010)

Borrowing, temporary exportation, exchange and transfer of antiquities belonging to

museums’ collections

For any other issue of major importance referred by the Minister of Culture.

Central Architectural Committee has in its’ jurisdiction the following departments:

Department of Prehistoric and Classical Antiquities

Department of Byzantine Antiquities

Department of Underwater Antiquities

The above departments are present with local offices in every region and county and their

responsibilities are to monitor and implement the scope and goals of the Central Committee

to the Local Authorities, transfer local data concerning Heritage issues to relevant Ministries

and manage any application from a citizen or a public body related with Historic Buildings,

Districts, Monuments etc..

Regional level

Commission of Planning and Architectural Control

The Commission of Planning and Architectural Control is also control by the Ministry of

Environment, Energy and Climate Change and is responsible for the urban planning,

issuance and application of building permits and control of arbitrary constructions in central

administrative level. These specific responsibilities are established by the applicable

provisions of laws, decrees and ministerial decisions.

The Commission undertakes responsibilities not included in the present Internal Services

Agency. It encompasses the following administrative units:

Department of Urban Design and Planning Applications

Department of issuing building permits

Department of Construction Control

Regional & local level

Committee of Urban and Architectural Control

The Committee on Urban & Architectural Control is controlled by the Commission of

Planning and Architectural Control was instituted two decades ago and is based both to the

Regions and the Municipalities, with the aim to control effectively the phase of building

licensing and to ensure the aesthetic and functional integrity of the buildings.

Regional Assembly

In many cases where there is regional interest or it is out of the jurisdiction of the Regional

Committee of Urban and Architectural Planning e.g. exploitation of an archeological site or

an historic building conversion to a museum any decision should be approved by the

Regional Assembly following the Official Recommendation of the District Assembly or

Municipality Committee.



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General assemblies of Districts

See previous paragraph

County or Municipality Councils

Usually they handle any citizen’s and other public bodies or authority’s application regarding

urban planning, historic buildings, monuments and archeological sites. Without the

permission of the Municipality Council none of them could precede to the next step of the

process (see questions 4 & 20).

Approximately 4.000 (in the whole country) Presidential Decrees determining Historical

Buildings status & requirements depending on the location and specific Municipality Councils

decisions.

Local Architectural Types indicating types & dimensions of openings, balconies, fencing,

roof, façades’, exterior walls permissible materials & colours. (see question 4)

3. Explain how the authorities which regulate energy p erformance in buildings (energy

management) are organized and their obligations.

Public Power Corporation S.A. (PPC)

Public Power Corporation S.A. (PPC) is the biggest power producer and electricity supply

company in Greece with approximately 7.5 million customers, founded in 1950. PPC

currently holds assets in lignite mines, power generation, transmission and distribution.

PPC’s current power portfolio consists of conventional thermal and hydroelectric power

plants, as well as RES units, accounting for approximately 70% of the total installed capacity

in the country.

After the spin-off of the Transmission and Distribution segments, two 100% subsidiaries of

PPC were created, namely IPTO S.A. (Independent Power Transmission Operator S.A.) and

HEDNO S.A. (Hellenic Electricity Distribution Network Operator S.A.). IPTO S.A. is

responsible for the management, operation, maintenance and development of the Hellenic

Electricity Transmission System and its interconnections, while HEDNO S.A. is responsible

for the management, operation, development and maintenance of the Hellenic Electricity

Distribution Network.

PPC is active in the RES sector through its subsidiary company “PPC Renewables S.A.”,

with a portfolio of 22 wind farms, 12 small scale hydroelectric plants and 12 photovoltaic

units. The total installed capacity of PPCR, also including 9 plants in which PPCR

participates through joint ventures, amounts to 132 MW.

Regulatory Authority for Energy (RAE)

The Regulatory Authority for Energy (RAE) is an independent administrative authority,

having financial and administrative independence, as defined by the provisions of its

founding legislation, L2773/1999, which was issued within the framework of the

harmonisation of the Greek Law to the provisions of Directive 96/92/EC for the liberalization

of the electricity market.

New competences and duties have been assigned to RAE with respect to electricity and

natural gas sectors by Laws, L3426/2005 and L3428/2005, aligning it with the relevant

provisions of the EC Directives 2003/54 and 2003/55, in particular with respect to access



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tariffs to electricity and gas networks, terms and conditions for the provision of balancing

services in natural gas, as well as on issues related to security of electricity and natural gas

supply.

Furthermore, on the basis of the modifications introduced with the abovementioned laws,

RAE acts as a dispute settlement authority with respect to complaints against transmission

or distribution system operators in both electricity and natural gas sectors.

Transmission System Operator of the Greek Electrici ty Transmission System (DESMIE

S.A.)

The Transmission System Operator of the Greek Electricity Transmission System (DESMIE

S.A.), was created by L2773/1999 which transferred the responsibility for the operation of the

transmission system for electricity from PPC to the operator.

DESMIE ensures that electricity is supplied to all customers with security and reliability,

utilizing electricity from all producers (PPC and independent producers) in the most cost

efficient way. It is also responsible for managing the operation and accounting of the daily

market, with transparency and accuracy.

Centre for Renewable Energy Sources and Saving (CRE S)

The Centre for Renewable Energy Sources and Saving (CRES) is the national centre for

Renewable Energy Sources, Rational Use of Energy & Energy Saving. Founded by

Presidential Decree in 1987, CRES is supervised by the Minister of Environment, Energy

and Climate Change and has financial and administrative independence.

The mission of CRES is to promote RES/RUE/ES applications at a national level, and under

article 30 of L3734/2009, to facilitate the national energy planning, assist in the formulation of

energy policies and foster the development of research and development activities in the

field of RES/ES.

Ministry of Environment and Climate Change

The Ministry of Environment, Energy and Climate Change was established following the

Decision of the Prime Minister N. 2876 on October 7th 2009, in order to confront the

continuous environmental problems and to adopt a new development model – the model of

Green Development- that will secure a better quality of life for every citizen.

Its mission includes the protection of the natural environment and resources, the

improvement of quality of life, the mitigation and adjustment to the implications of climate

change and the enhancement of mechanisms and institutions for environmental governance.

In order to achieve its mission, the Ministry of Environment, Energy and Climate Change

have developed a strategic plan based on 4 pillars amplified into strategic objectives.

PILLAR 1

Combating Climate Change by moving towards a competitive economy of low carbon

consumption.

Strategic Objectives

Improve energy efficiency

Increase the share of our country’s energy use from renewable sources and natural gas,

whilst ensuring the reliability of energy supplies.



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Secure consumers the provision of reliable energy products and services

Promote green products, sustainable production and consumption patterns

PILLAR 2

Natural resource protection and environmental enhancement

Protect and promote Biodiversity and the natural landscape

Ensure the effective management and protection of water resources

Effective management and protection of our forests

Environmental Crises prevention and effective risk management

PILLAR 3

Improve quality of life with respect to the environment

Urban Regeneration

Improve air quality and soundscape

Enhance accessibility and sustainable mobility for all

Efficient waste management and promotion of recycling

PILLAR 4

Enhancement of environmental governance mechanisms and processes

Strengthen the planning system in order to ensure policy cohesion

Simplify and code environmental legislation whilst strengthening its enforcement

mechanisms

Promote environmental research, innovative technologies and accessibility to environmental

information

Enable environmental accountability and volunteerism

The Ministry will implement a series of actions in collaboration with public administration, the

private sector, social partners, citizens and international community, in order to achieve the

strategic objectives and eventually establish the pillars of Green Development.

DEPA

DEPA Group is the incumbent natural gas utility in Greece, responsible for the wholesale,

trading, transmission, distribution and supply of natural gas. The Group is currently owned

65% by the HRADF (Hellenic Republic Assets Development Fund/TAYPED) and 35% by

Hellenic Petroleum (HelPe).Through DEPA, the Group is active in the wholesale, trading and

supply of natural gas to large end-users. DEPA procures gas through long-term ToP

contracts for piped gas and LNG with Gazprom, Botas and Sonatrach totalling 4.2 bcm per

annum. In turn, DEPA sells gas under medium and long-term ToP contracts to power

producers, large industrial customers and the three existing gas distribution and supply

companies, the EPAs. In 2011, these customer groups accounted for 96% of gas sold by

DEPA.

Through its wholly-owned subsidiary DESFA, the Group owns and operates the regulated

high pressure gas transmission network and Greece’s LNG re-gasification terminal. DESFA

has the right to operate, maintain, manage and develop Greece's transmission network, the

NNGS and is responsible for providing non-discriminatory third-party access to the system.

The NNGS is one of the youngest natural gas transmission systems in Europe with its main



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pipeline completed in 1996. The system is primarily comprised of a main pipeline of 512 km

in length, branch pipelines with a total length of 707 km and an LNG receiving terminal with a

maximum annual capacity of 5.3 bcm at Revythousa island near Athens.

DEPA owns 5,600 km of low and medium pressure distribution networks in the regions of

Attika, Thessaloniki and Thessalia and has the right to develop and exploit further

distribution networks throughout Greece. DEPA also owns 51% participations in the EPAs,

which are active in the supply of residential, commercial and small industrial customers in

the regions of Attica, Thessaloniki and Thessalia. The other 49% stake in EPA Attikis is

owned by Shell while the 49% stakes in EPA Thessalonikis and EPA Thessalias are owned

by Eni. Upon their establishment in 2000-1, the EPAs were granted a 30-year concession

license which provides for the exclusive right to develop, operate and exploit the distribution

networks in their respective areas and supply gas to non-eligible customers.

Hellenic Transmission System Operator (HTSO)

HTSO is a S.A. company the 51% of which belonging to the Public Sector, and the 49%

belonging to the electricity production companies existing in Greece. This means that P.P.C.

today owns this 49% but its share will be decreasing giving the opportunity to whatever new

producers may appear. The company today is composed of 160 employees approximately

(that are going to become double in number during its final growth) and its annual budget

estimated to be at the rate of about € 15 millions.

The Operator is responsible for a number of procedures:

At the beginning the produced, transmitted and consumed energy has to be calculated in a

reliable, accurate and indisputable way by the market notables. First procedure of the

Operator’s responsibility is the existence of a metering system being officially certified.

Second procedure that consists the heart of the system is the Dispatching Center. It is well

known that electric energy is an idiomorphic commercial good that cannot be stored and thus

at any time the production will have to be analogous to the consumption. So it is the

Dispatching Center that has to settle the schedules of which station is going to produce in

what quantity. The Dispatching Center dispatches each station in such a way so that the

quality characteristics (currency, tension) are maintained, the operational cost is the

minimum one and the bilateral commercial relations between consumer-providers are

respected.

In order to maintain the reliability of the system and the quality characteristics of the

delivered electric energy to the consumer, the Operator needs specific, the so called

auxiliary services, capability of special regulations etc that are going to be obtained through

transparent procedures by market producers, in the first stage the only provider is P.P.C.

The settlement, in other words who owns to whom, is a procedure related to the free

purchase of electric energy. As far as the Greek market goes, basically a system of bilateral

commercial relations between consumer and provider-producer has been chosen. The

Operator does not interfere in these bilateral agreements that are under the absolute

authority of the contracting parties. But during the daily operation and for several reasons a

provider’s production is not completely analogous to a client’s consumption. This deviation is



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been calculated and invoiced by the Operator who dictates to any incomprehensive producer

the amount he is going to pay through the Operator to another active producer. This

procedure is called clearing of the market and is been arranged in such a way that the

economic operation of the System to be encouraged.

Another basic obligation of the Operator is the maintenance of the system and its further

development in order to accept new producers and new customers. This maintenance will be

implemented by P.P.C. (as the owner of the grid) while the expansions will be charged

according to very specific rules being included in the norms of interaction governing the

market. P.P.C. is compensated.

Finally, one of Operator’s duties is the support and further development of the market and

the updating of the interested parties. The Operator makes short, mid and long term

forecasts for the needs of the system, publishes estimations, proposes improvements to the

market rules and to the operation of the system and obtains a high degree transparency of

the market, of System Operation including the operation of the company. Basically, all

actions taken by the Operator are done via Internet and they can be obtained through

Internet.

HTSO aim is to achieve a reliable and impartial operation of the Hellenic Transmission

System Operation as well as of the market that depends on it so that the new producers, the

selected customers and all consumers to have the traditional reliability of the system that is

being serving Greece the last 50 years, characterized by the transparency and impartiality

that the rules of the new market demand.


National level

Reference to existing national and regional legislation and summary of local legislation

concerning the increase of the share of energy from renewable sources in the building

sector.

L3661/2008 'Measures for the building energy consumption reduction'. This law,

implementing Directive 2002/91/EC in Greece, requires that passive solar systems as well

as heating /cooling/ electricity production systems that utilise RES and CHP must be

considered in the H/C specification study submitted in the licensing procedure of buildings

thus promoting the installation of small-scaled RES technologies.

L3851/2010 on “Accelerating the development of Renewable Energy Sources to deal with

climate change and other regulations in topics under the authority of MEECC”.

The new law complements L3661/2008, by setting new requirements that stipulate the

coverage of 60% of the need of new buildings for hot water by solar thermal systems after 1

January 2011.

Additionally, all new building construction or major renovation requires henceforth a full

energy analysis study that includes energy conservation and cost/benefit analysis of the

utilization of RES cogeneration, district heating, and heat pump systems.

Furthermore, L3851/2010 stipulates that by 31.12.2019, all new buildings must cover the

total of their primary energy consumption with RES, CHP, district heating on a large area



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scale/block scale as well as heat pumps. This requirement is extended to all new public

buildings by 31.12.2014 at the latest.

L3855/2010 on “Measures to improve energy efficiency in end-use, energy services and

other provisions”, and in particular Article 8 for energy efficiency measures in the public

sector and Article 16 on the energy performance contracting framework. This law, which

transposes Directive 2006/32EC, foresees specific measures for the buildings of the public

sector in order to improve their energy performance and achieve energy savings.

Additionally, it sets the framework for the establishment of the ESCO market in Greece

through Energy Performance Contracts, promoting the use of domestic RES systems.

The “Energy Performance of Buildings Regulation ” - ΚΕΝΑΚ (OG 407/Β/2010) that

stresses the obligation for new or refurbished buildings to meet 60% of their needs for hot

water through solar thermal systems. For the proper implementation of this regulation, in

relation also with domestic RES systems, the Technical Chamber of Greece will issue a

guidebook about the technical instructions for “RES installations in buildings”.

Joint Ministerial Decree "Measures to improve energy efficiency and energy saving in the

public and broader public sector" (OG 1122/Β/2008), where a connection with the natural

gas network is made mandatory.

Ministerial Decree (OG 1249/B/2009) that defines, streamlines and facilitates the licensing

procedure and framework for the exploitation of geothermal resources for own use through

energy systems (ground source heat pumps) for space heating and cooling of a building.

Decision 1945/134/17-1-2003 by the General Secretary of Ministry of Environment, Public

Works and Urban Planning for the “Installation of solar heaters” in buildings.

Decision 16094/08-04-2008 of deputy Minister of Ministry of Environment, Public Works and

Urban Planning (OG B 917) and Decision 16095/08-04-2008 of Deputy Minister of Ministry of

Environment, Public Works and Urban Planning (OG B 925): These decisions integrate PV

systems in the provisions already applicable for solar collectors.

Modifications to the Building Code (L1577/85 and L2831/00) (OG B 140) have been

made as regards passive systems integration (referring to the Article 13(4.6) of the

Directive).

The anticipated use of renewable energy in buildings is described on the following table:

2005 2010 2015 2020

Residential 15,00% 17,00% 22,00% 27,00%

Commercial 10,00% 14,00% 27,00% 39,00%

TOTAL 14,00% 16,00% 24,00% 30,00%

Table 3.1 Estimated share of renewable energy in the building sector

Source: Ministry of Environment, Energy and Climate Change

The mandatory fields of the implementation of the EPBD for the house owners are:

At least 50% heat recovery in the central air-conditioning units



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At least 60% hot water production from solar panels.

There are no limitations or specific requirements other than these described on the relevant

TGTCGs for the installation of systems such as:

Wind turbines,

Heat pumps,

Solar cells,

Photovoltaic installations,

Passive ventilation systems,

Solar thermal Systems, etc.



Legislation applied (Architectural – Planning)

Building Regulations L 4067/2012 - FEC 79Α/2012 (General Building Regulations partially

amends previous Building Regulations Laws)

Law L 4014/2011 (Addition to Building Laws – Legalisation of illegal Buildings)

Law 3814/2010 (Addition to Building Laws – Legalisation of illegal spaces and components

of Buildings)

Law L 3212/2003 FEC -308/Α/31-12-03 (Addition to Building Law related to Building

Permissions at urban areas)

Building Regulations L 2831/2000 – FEC 140A (General Building Regulations partially

amends previous Building Regulations Laws)

Law L 2508/97 (EC -124/Α/13-6-97 General Planning Regulations)

Building Regulations L 1597/1985 (General Building Regulations partially amends previous

Building Regulations Laws)

Presidential Decree P.C. 24/31-5-85 (addition to Building Laws – General Regulations for

Housing Buildings)

Regulation 54247/34/25-5-98 (Regulations for Building Permission Approval)

Presidential Decree P.C. 29/98 FEC -169/Α/15-7-98 (Addition to Building Laws – Building

close to Historical Buildings)

Law L 1337/1983 (Addition to Building Laws – Obligations of owners to preserve Historical

Buildings)

Presidential Decree P.C. 15/28-4-88 (addition to Building Laws – Rehabilitation Repairs to

Historical Buildings)

Law L 2300/1995 – Traditional Settlements and Historical Buildings

Law L 2917/1954,(addition to Building Laws – Repairs on damages occurred after a Natural

Disaster)

Presidential Decree P.C. 8-2/1-3-79, ,(addition to Building Laws – Repairs on damages

occurred after a Natural Disaster)

Presidential Decree P.C. 7/13-3-80, addition to Building Laws – Repairs on damages

occurred after a Natural Disaster)



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New Anti-seismic Code NAK 2000

Presidential Decree P.C. 70/1978- Fire Protection in Buildings

A range of Presidential Decrees and Regulatory Decisions for almost every aspect

concerning design & construction such as: permissible building, provision of parking spaces

to new buildings (depending on the city), Use of Land Orders, etc.

NATIONAL REGULATIONS (Energy Efficiency)

Law L 3661/2008 FEC 89/A/2010 (KENAK)

Law L 3851/2010

Law L 3889/2010

Law L 3661/2008

Law L 20701-1/2010

MAIN PROVISIONS

According to the Greek Constitution (voted in 1975 and revised in 1986, 2001 and 2008),

spatial planning (that is both urban and national and regional spatial planning) is placed

under the regulatory authority and the control of the State, in the aim of serving the

functionality and the development of settlements and of securing the best possible living

conditions (art. 24 par.1).

For the purpose of urbanization, the Constitution (art. 24 par. 3) provides that properties

inserted in the town plans must participate, without compensation, in the disposal of land

necessary for the creation of public spaces and public utility areas and contribute toward the

expenses for the execution of the basic public urban works, as specified by law.

PLANNING LECISLATION

Town planning legislation has a history of over a century in Greece. The first universal town

planning legislation came into force in 1923 (Law Decree of 17 July 1923) and was applied

for over 50 years. On the contrary, national and regional planning legislation is more recent.

In fact, it is within the Greek Constitution of 1975 and the L.360/1976 that the first legal

provisions for the supra-urban spatial planning were introduced.

Today, apart from the constitutional provisions, the main body of general planning law

consists of three major legislative acts: L. 2742/1999, which concerns the territorial spatial

planning in the national and regional levels, L. 2508/1997 concerned with sustainable urban

planning and, finally, the building law (L. 1577/1985, amended and supplemented by L.

1772/1988 and 2831/2000) which comprises the general rules for the erection of buildings

and other structures on plots and parcels of land.

In parallel, a special body of statutes provides for planning and building in particular

categories of areas and settlements (second home areas, rural settlements, settlements

below 2.000 inhabitants, areas of building cooperatives and industrial and tourist estates as

well).

A major distinction established within Greek planning legislation is between the within-the-

plan areas, on one side, and the out-of-plan areas, on the other. Within-the-plan areas are

covered by statutory detailed town plans that grant development rights to the landowners.

These plans determine street alignments, building lines and land-use designations and are



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accompanied by a statement of building provisions, including minimum plot size and plot

dimensions, maximum plots ratios and the floor-area ratio. Out-of-plan areas, on the

contrary, are not covered and regulated by town plans. However, according to existing

legislation, these areas are not devoid of development rights and are not necessarily wild,

natural or agricultural land. Most of these areas outside plans traditionally (since 1928)

permit a limited (but significant) amount of development so long as landowners possess

plots of a minimal size of 4.000 sq. m and road access.

The 13 Regions in which the country is actually divided are entrusted with several planning

responsibilities concerned mainly with the elaboration, the approval, the amendment, the

revision and the monitoring and control of different types of urban plans, the approval of

zones for the transfer of floor-area ratio and the approval of departures from general building

rules in the case of non-residential buildings (buildings used for health care, education and

welfare services, as well as industrial plants and public sports facilities).

Apart from regional administrations, a great number of second-tier (Prefectural self-

government) and first-tier (Municipalities and Communes) local authorities41 intervene in the

planning process. In the production and approval of statutory plans the role of local

authorities is mostly advisory, while the hard core of their responsibilities is concerned with

the delivery of building permits and other licenses and the implementation of town plans.

PLANNING & BUILDING CONTROL

Planning control in Greece is realized through the building permit. This permit is required for

any work of construction in or out of a settlement. It is a combined system of planning and

building control, which regulates building construction and demolition, as well as land-use

change.

Besides building permit, other consents depending on the use of the building or its location

are needed. Among them, we should mention the consent required if development is to take

place on or around monuments and historic buildings (article 10 of L. 3028/2002) and the

approval of environmental conditions required in the case of public or private projects that

may have significant impact on the environment (articles 3-5 of L. 1650/1986 as amended by

L. 3010/2002). Both permits are prerequisites for the granting of the building permit.

Summarizing though Legislation (L 3212/2003, L 2508/1997 FEC -124/Α/13-6-97, Regulation

54247/34/25-5-98, L 2508/97 (EC -124/Α/13-6-97, and P.C. 24/31-5-85 ) the procedure to

obtain a Building Permit for retrofitting the sequence is the following:

All documentation (studies, drawings, etc.) first submitted to the Relevant Planning Authority.

If there referring to a non-historical Building the permission is granted without any delay

within two working days, as far as the area, volume, facades and openings of the building

will not be altered.

If some of the mentioned on the above parameters will be altered then it the owner is obliged

41 Actually, the country is divided in 54 Prefectures, 900 Municipalities and 133 Communes.



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to be awarded with:

Assurance from the Relevant Committee of Antiquities that the Building is not an Historical

Building or is located on an Historical Area.

If it is a rural or Agricultural Area an Assurance by the Forestry Department is required.

(These documents are required due of the continuous update of the Historical Areas and

Forestry Protected Areas in Greece).

Then license will be granted within sixty days of final submission of all documents.

In case of an Historic Building the limitations are clearly defined to L 1337/1983 and P.D.

15/1988 where restrictions apply to the use of materials and construction techniques and the

sequence of obtaining a License is much more complicated.

All documentation (studies, drawings, etc.) first submitted to the Relevant Planning Authority.

An owner requires also to submit:

Permission of the Municipality’s Committee of Urban and Architectural Control,

Permission of the Relevant Committee of Antiquities indicating the Building Classification (if

it belongs to a Building with local Interest, usually there is either a Region or a County

Decision which it determines it) or

If it is a National Interest Building needs a permission Central Committee of Historical

Buildings located to the Ministry of Culture (usually for every Building of National Interest

exists a P.D. determining its status)

License will be granted in approximately six to nine months and the Relevant Committee will

appoint a representative to inspect the retrofitting works, or

No license for retrofitting will be granted if the owner will not comply with the requirements of

P.D. 15/1988 especially with the use of designated materials.

P.D 15/1988 also describes a “fast track” retrofitting process which applies only to repairs

after a physical disaster or deterioration of crucial elements by appointing the owner to

immediately start the required works and the provision of an inspector during these works

but in any case without altering the nature, facades, materials etc. of the building.

The basic Legislation that architects and owners should follow ((with no exceptions)in case

of new and / or existing buildings are:

Building Regulations L 4067/2012 - FEC 79Α/2012

New Anti-seismic Code NAK 2000

Presidential Decree P.C. 70/1978- Fire Protection in Buildings

Law L 3661/2008 FEC 89/A/2010 (KENAK)

Local Architectural Types

Additionally, during design and construction, architects have to implement to their design any

other Legislation applies to the Building e.g.: Land Use Order, or Provision of parking

spaces, or TGTCC 24718/8 Gas Supply to Buildings etc.

Though, as the Anti-seismic Code NAK 2000 is relatively new and a very large number of

buildings have been constructed with the older Codes of 1973 & 1991, the obligation to

adopt the provisions of NAK 2000 is limited up to the Structural Stability Certificate which will

be issued by a Structural Engineer.



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According the Terms of Law L 1337/1983 the ow ner of an Building must:

Under the provisions of Art-79 section 6 of P.D.-8/73 owners must maintain the architectural,

artistic and static components of the building, to reconstruct them according to the

instructions of the relevant Committee (refers to the Committees 1,2,3,4, & 5 of previous

question) , even if the damage is due to force majeure. If the owners, occupiers or

usufructuary fail their obligation may intervene in government or the local authorities

concerned and to perform the operations attributing the relative expense to the respondents.

Those who in any way own or lease these properties have to accept the above interventions.

All or part of the cost of repairs or reconstruction can be undertaken by the State or the

relevant local authority, if the debtor is unable to meet these costs in relation to the

performance of the operation of the building and at the same time if the damage was not

deliberate energy, according to the provisions of Presidential Decree issued on the

recommendation of the relevant Ministry A similar PD can regulate the procedures for the

application of this paragraph, the competent bodies in each case, administrative sanctions

for acts or omissions in contravention of the above provisions and any related or additional

detail.

Additionally the P.D. 15/28-4-1988 also defines:

In case of damage or deterioration of the architectural and artistic landmark buildings or the

buildings are traditional settlements, the responsible planning agency or municipality or

community, if these buildings do not belong in full ownership to the State or a public body,

set a reasonable deadline for the debtor for the beginning and end of work of the restoration,

including the static elements of the building.

If the owner begins the restoration of the building or any restoration work started but has not

been completed within the dedicated schedule of works, the penalties are per description of

par.18 of this article and simultaneously the planning agency or municipality or community

will issue a new deadline for the completion of the work.

If the time expires as per paragraph 1 and paragraph 3, then the State or the municipality or

the community may undertake the remaining works required by attributing all or part of such

costs at the expense of taxpayers.

For granting planning permission repair or reconstruction of the buildings the owner should

submit to the relevant planning agency together with the supporting study of color photos of

all sides of the building, and photographs of interiors, where architectural interest exists.

Since the start of the construction work and until the completion of repair or restoration,

except those carried out in accordance with Art-335, it is possible the agency issuing the

license, depending on the type and extent of repair or reconstruction of the building, to

inspect and advise for the relevant work.

Limitations By Building Regulations L 4067/2012 - FEC 79α/2012 For Retrofitting:

In general L 4067/2012 - FEC 79Α/2012 allows the owner to use for building the 60% of the

total land area, (depending on the location this figure might vary from 10% -80% determined

by a P.D. for each area separately) which is described as Coverage Area.



EFFESUS • 314678 • of 262

In addition the term Total Permissible Area is the total area of the building and is a

multiplying factor of the total land area translated to m2. This factor is determined also by

P.D. for each area separately and varies from 0,10 – 8,00 depending on the location and the

nature of the building. E.g. For a land of 1.000,00m2 in a city with land coverage area 60% of

the land and building factor 1,2 for housing use the owner is allow to cover with its building

up to 600,00m2 and up to 1.200,00m2 of building areas. To the same land if the owner

wants to build a hotel the coverage area will still be the same 60% but he could build up to

6.000,00m2 of building and if was to build up a hospital or a school then the building area

would be increased up to 8.000,00m2. The Total Permissible Area factor is not the same for

a city as the general rule is that on city centers is higher (can reach up to 14,00) and in

suburbs of the same city might be equal with the Coverage Area factor.

In the same P.D. is also determined the Permissible Height of each building. E.g. to the

same land mentioned on the above for housing the maximum permissible height is 9,00 for

housing (therefore is a three storey building as per limitation of the L 4067/2012 - FEC

79Α/2012 each storey should not be less than 2,40 m on height), 18,00 m for hotels and

hospitals (six storeys).

Regardless of what type of building somebody builds, or if he retrofits an existing building,

these limitations are mandatory, with no exceptions. This means that for retrofitting it is not

allowed to increase building areas, or building height if they already have been used if

Coverage Area or Total Permissible Area values have been reached their limit. If these

values have not reached their limit then new building or retrofit should exceed them

maximum permissible.

Façades should not be altered without a Building permit as described on the above.

Openings (windows and doors) on façades should not be altered without Building permit.

The L 4067/2012 - FEC 79Α/2012 determines that openings should not be less than 10% of

the total area of the façade of the building but in some cases where the Local Architectural

Type is imposed that maximum openings’ area is set up to the 25% - 40% of the total area

of the façade (on mountainous cities and villages). In order architect to exceed this limit a

permit should be granted by the Municipality’s Committee of Urban and Architectural Control.

Same limitation applies for structural glazing and glazed facades.

Balconies are not permitted to be continuous on the perimeter of each floor. Local P.D. is

determining the length and the width of the balcony which varies from 0,6m – 4,0m width.

Local Architectural Types are specifically determining (regardless of new or retrofit building):

Windows openings dimensions, material, (wood, aluminum, PVC etc.) types and colours

Window shutters material, types and colours

Door dimensions, material, types and colours

Type of roof (flat or pitched), pitch angles, material and colour of roof frame (wood, steel

etc.), roof cover (material and colour e.g. slates, clay tiles, etc.), type and material of rain

gutters.

Balconies dimensions, dimensions, type, materials and colours of hand railing.

Exterior wall, type (concrete, brick, timber, stone etc.), dimensions and specific requirements



EFFESUS • 314678 • of 262

(e.g. for brickwork double or single, type of bond etc.), rendering type (cement, plaster etc.),

colours.

Fencing dimensions and height, material (concrete, timber, bricks, stone, steel, etc.) colours.

Law 2300/1995 set up the Regulations for the characterization of a Settlement (village) as

“Traditional”. There are more than 2.100 “Traditional Settlements” in Greece, and their

Building Regulations are clearly defined for each one separately with a P.D. Usually, on

these areas no intervention to building shape and designed is allowed to be made, no

alternation to the external design, components, materials could be executed. All materials

and techniques might be used for a retrofit should be of the same result and aesthetics as

the original.

To Monuments or Buildings with International Interest no actions could be taken by the

owners prior the approval of the Ministry of Culture and the consent of the Central

Committee of Historical Buildings.


A Public Audit was held at 2009 regarding the rehabilitation of the Historic Market of Chania.

The main goal was the complete restoration of this 1910 building which was accommodating

75 small traders and is locating in the Historic Centre of the city.

Initially, the Municipality Committee has approved the restoration and because it was part of

the Historical Centre the Official Recommendation of the Local Department of the

Department of the Byzantine Antiquities was required.

During this process and as financial crisis hit the country, the Municipality of Chania

reformed its original decision and approved the proposal of the traders to incorporate

photovoltaic panels in the roof and solar heating system in order to reduce operational costs.

Having the assurance of the Electricity Provider (DEI) and the manufacturer of the

photovoltaic panels (Solartech SA) that aesthetically they will not alter the building as they

will be fitted in the roof in such a way that will not be easily visible another application to the

Local Department of the Department of the Byzantine Antiquities has been submitted and

has been approved.

An Official Recommendation has been issued by the Local Department of the Department of

the Byzantine Antiquities to both the County and Regional Committee and having their

approval finally the upgraded restoration has been published to the Official Gazette on

January of2011 and its construction has been fully completed on July of the same year.



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Municipal Market of Chania: Installation of photovoltaic panels on the roof.




Major priority was given to achieving the targets set by the Directive 2009/28/EC and by the

international commitments of the country for the protection of the environment. To this line,

the Parliament adopted the Law L3851/2010 which came into effect on 4th June 2010 and in

which ambitious national targets for RES (namely 20% on final energy consumption, 2%

above the mandatory level of 18% set by Directive 2009/28/EC) are specified.

The triple targets of the 20-20-20 package are considered by the Greek Government as both

obligations and opportunities. It is envisioned that they will play a key role in ensuring energy

security, reducing national GHG emissions and boosting the competitiveness of the

economy and attracting investment capital and technical knowhow. It is also estimated that

they will assist in the economic improvement of conditions in rural areas and in boosting eco-

industry that utilizes comparative advantages of local agricultural production and food

industry.

The target of a 20% share of renewable energy in the gross final energy consumption in

2020 will be achieved through the combination of measures for energy efficiency as well as

for the enhanced penetration of RES technologies in electricity production, heat supply and

transport. A major role in this respect will be played by the streamlining of the existing

framework of licensing regulations and the rationalization of the terms and conditions of land

management.

Meeting the targets set within the RES roadmap until 2020 calls for the elaboration of

policies and measures, which aim at the simultaneous fulfillment of the “20-20-20”

obligations and the acceleration of the Greek economy through “green” development and

enhanced competitiveness of the private sector. For this purpose, a number of major

legislative initiatives have been proposed by MEECC and approved by the Greek

Parliament.

Among them, L3851/2010 (OG A/85/4th June 2010) on “Accelerating the development of

Renewable Energy Sources to deal with climate change and other regulations in topics



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under the authority of the Ministry of Environment, Energy and Climate Change” is of

particular importance and it amends significant provisions of the currently applicable

legislation, aiming at simplifying the licensing procedure, at rationalizing the feed-in-tariff

scheme, at tackling existing barriers at local level, as well as at establishing specific

regulations for the use of RES in buildings in accordance with the recently approved “Energy

Performance of Buildings Regulation” - ΚΕΝΑΚ (OG 407/Β/2010). Additionally, L3851/2010

sets specific targets for 2020 regarding the share of RES in final energy consumption,

electricity generation and contribution in heating, cooling and transport.

6. Please describe how the goals in question 5 are proposed to be achieved .

The implementation of the Energy Performance in Building Developments by the Ministry of

Environment, Energy and Climate Change (MEECC) set up new rules and terms in the

construction enforcing construction industry to update its products or to adopt new more

energy efficient products.

One of the main goals for its implementation is to put pressure to the owners to retrofit their

buildings with the use of more energy efficiency materials and systems. In order to achieve

this goal a range of subsidies are provided to the owners. These are:

‘Energy Saving at Home’ , addressed to house/flat owners and providing direct subsidies

(up to 30%) and low rate bank loans (covering the remaining share of the investment) for the

renovation-Energy Performance improvement of existing buildings. An EPC is required

before the implementation of measures and one after the implementation in order to prove

that the EP rating was improved by two categories (i.e., a flat rated as H should be E

after the implementation of measures).

‘Save Energy’ addressed to Municipalities, for buildings owned/used by municipal services,

administration, schools and housing blocks (the process started in 2009, energy efficiency

plans have been prepared and applied by Municipalities, the selection of the experts to

evaluate the proposals has already been completed, and the evaluation of the plans is under

way). An energy audit is required in the proposal submission phase and an EPC is required

after the implementation of measures, in order to demonstrate the improvement of energy

performance. The programme covers 100% of the expenses.

Energy Performance Improvement of Public Buildings . The Programme was launched in

September 2010 – deadline for applications: March 2011. Audits according to the new

Regulation are required for documenting the interventions. The programme covers 100% of

the investment costs.

Energy Performance Improvement of School Buildings . The programme is under

development. An EPC will be required after the implementation of measures. The

programme covers 100% of the investment costs.

Since it’s fully implementation on January 2011, in conjunction with the economic recession

which has frozen the construction activity in Greece, there are not sufficient data for the use

of the building materials to extrude reliable conclusions.



EFFESUS • 314678 • of 262

42


For instance:






DIRECTIVES (EPBD)42



buildings.

Law (L. 1577/1985, amended and

supplemented by L. 2831/2000) which

comprises the general rules for the erection

of buildings and other structures on plots

and parcels of land.

law (L. 3028/2002)

«New building regulation», Article 6



environments.

Law 2300/1995 set up the Regulations for

the characterization of a Settlement

(village) as “Traditional”. There are more

than 2.100 “Traditional Settlements” in

Greece, and their Building Regulations are

clearly defined for each one separately with

a P.D. Usually, on these areas no

intervention to building shape and designed

is allowed to be made, no alternation to the

external design, components, materials

could be executed. All materials and

techniques might be used for a retrofit

should be of the same result and aesthetics

as the original.

Presidential Decree 358/ 1986:

jurisdictions for protection of natural and

cultural environment are transferred from

YPEKA to Ministry of Macedonia and

Thrace.


categorized? 43

Grade I . Preservation of the building and

the surrounding area, with absolute

protection.

Buildings of Grade I.

a) The alteration or destruction of individual

architectural, decorative and structural

components is prohibited.

b) The repair and static reinforcement with

traditional materials of the same type, the


categorized?

I) The definition of archaeological sites

includes any areas in land or sea or lakes

or rivers i) which contain or is possible to

contain ancient monuments, ii) which were

considered as monumental, residential or

tomb assemblies since 1830.

The archaeological sites include the

necessary free environment that allows the

preserved monuments to form historical,



EFFESUS • 314678 • of 262

use of iron and any other interference for

static or operational reasons is allowed.

Reinforced concrete can be used only in

non-visible parts.

c) The damaged structural components

may be replaced with materials of the same

type with the aim to bring to light all original

external and internal components

(architectural, decorative, old ironwork,

masonry compositions, etc.).

d) Alterations of the facades and typology

of buildings are prohibited whereas the

restoration of their original shape and

structure is required during the repair

process. Any necessary interventions to

ensure sanitary facilities should be limited

to secondary spaces without altering the

important components of buildings.

Grade II. Preservation of the building and

the surrounding area, with absolute

protection of the building envelope.

Buildings of Grade II.

a) The alteration or destruction of individual

architectural, decorative and structural

components is prohibited.

b) The repair and static reinforcement with

traditional materials of the same type, the

use of iron and any other interference for

static or operational reasons is allowed.

Reinforced concrete can be used only in

non-visible parts.

c) The damaged structural components

may be replaced with materials of the same

type with the aim to bring to light all original

external and internal components

(architectural, decorative, old ironwork,

masonry compositions, etc.).

d) Alteration of buildings’ facades is

prohibited and the restoration of their

original shape is required if any recent

interventions are observed during the repair

aesthetic and functional assemblies.

II) As Traditional Settlements (villages) are

defined any areas in land or sea or lakes or

rivers i) in which historical or mythical

events occurred after 1830, ii) which

contain or is possible to contain ancient

monuments dating after 1830, iii) composite

constructions of both human and nature

dating after 1830 which constitute

characteristic and homogeneous spaces,

can be defined topographically and must be

protected as a result of folk, ethnic, social,

technical, architectural, industrial or general

historical, artistic or scientific significance.


categories.

Traditional Settlement in Nymfeo, Florina,

Greece

Archaeological Theater of Epidavros,

Greece



EFFESUS • 314678 • of 262

process. Internally, in order to improve

living conditions, interventions that may

affect the original arrangement of the

interior spaces are allowed.

Grade III. Preservation of the volumetric

contour (reconstruction).

Buildings of Grade III.

a) The reconstruction of the original building

as well as the rehabilitation of

morphological features, are allowed for

functionality reasons. The repositioning of

old ironwork and external wood carvings

doors, if they are well preserved, is

mandatory.

b) The reconstruction and preservation of

recent additions, that fulfill the functional

needs of buildings, are allowed.


categories.

Grade I listed Buildings

Karipeion Melathron, Thessaloniki

District of grade II listed Buildings

Achileos str., Thessaloniki

Grade III listed Buildings



EFFESUS • 314678 • of 262

Ag. Asomaton 15 str. ,Athens

9. a) How is national legislation influenced by EPB D?

In Greece there was no specific regulation concerning the assessment of energy

performance and certification of buildings until the Energy Performance of Buildings

Directive (EPBD).

• Pre-existing relevant regulations have been:

the Greek Thermal Regulation, implemented in 1981, which prescribed limits for U-values

and restricted heat transfer through the building envelope,

The Technical Codes of the Technical Chamber of Greece (TOTEE): 2421/86 for the

installation of boilers for the heating of buildings, 2423/86 for the installation of cooling

systems in buildings and 2425/86 for the calculation of cooling loads in buildings.

• In 2008, the Greek Law 3661/2008 ‘Measures for decreasing the energy consumption of

buildings’ was voted, according to which the Energy Performance Regulation for Buildings

(KENAK) is foreseen.

The impact of EPBD on the national requirements concerns:

the introduction, for the first time, of the energy performance certificate,

the definition of specific energy performance levels,

the definition of specifications for different building systems,

the consideration of renewables in buildings above 1.000 m2

More precisely, the modifications induced by EPBD in national legislation, involved the

following:

The Law 3661/2008 (FEC 89/A/2010) "Measures to reduce energy consumption in

buildings and other provisions amended:

with Article 10 of Law 3851/2010 "Accelerating the development of renewable energy in

tackling climate change and other provisions relating to the Ministry of Environment,

Energy and Climate Change" (Gov. 85/A/2010),

with Article 28 of Law 3889/2010 "Financing Environmental Interventions, Green Fund,

Ratification forest maps and other provisions to be extended to include residential

buildings intended for use not exceeding four (4) months (summer cottages).

Delegated to Law 3661/2008 issued the following regulations, complete the legislative

framework required to fully implement the law:



EFFESUS • 314678 • of 262

The Energy Performance of Buildings Regulations (KENAK) approved by the Joint

D6/V/oik.5825/30-03-2010 the Minister of Finance and PECA (Official Gazette B 407). To

support the implementation of KENAK approved by the Minister Highlights PECA decision

17178/2010 (Official Gazette 1387 / V/2.9.2010) following the instructions of the Technical

Chamber of Greece, which are available from the TCG:

THEN 20701-1/2010 "Comprehensive national standards parameters for calculating the

energy performance of buildings and issuing of energy performance certificate,

THEN 20701-2/2010 "Thermophysical properties of construction materials and control of

thermal insulation efficiency of buildings"

THEN 20701-3/2010 "Climatic data Greek regions,"

THEN 20701-4/2010 'instructions and forms energy audits of buildings, boilers and

heating and air conditioning.

Also for the purposes of KENAK issued:

the Circular on Implementing the Energy Performance of Buildings Regulations (KENAK)

(Fin 1603/4.10.2010) and The Circular "Clarifications to the proper implementation of

Energy Performance of Buildings Regulations (Building 2279/22.12.2010).The Circular

"Clarifications on Circular 2279/22.12.2010 to the obligation to issue Energy Performance

Certificate (EPC) in cases of buying and selling real estate (Fin 2366/5.1.2011).

Circular Clarification of the Coordinating Committee of Associations of Notaries Greece

"Specialized Settings Article 6 and 11 of Law 3661/08, Articles 14 and 15 Rules of Energy

Performance of Buildings (KENAK).

By Decision of the Minister MEECC 49731/2010 (Official Gazette 498 AAP/23.11.2010)

amends Article 25 of the building code (FEC 380/D/1997) to the requirements of studies of

hydraulic and electrical installations and extends to all buildings within the scope of Law

3661/2008.

To facilitate the engineers out a case study as well as Energy Efficiency Checklist and

application of minimum requirements for the Town Planning Office Presidential Decree

100/2010 "Energy Building Inspectors, Boiler and heating and air conditioning (FEC

177/A/6.10.2010).

b) Please state any other international charters, c onventions or principles that have

relevance for national legislation regarding energy performance in historic


See question 4



The main approach of the Energy Performance in Building Developments could be

focused to the following:

The classification of buildings in 9 classes is done according to the scale shown in Table

10.1 and Figure 10.1 which indicates the climate zones in Greece. The category B

corresponds to the minimum accepted category of new buildings and those undergoing

major renovation. E.A. refers to the total primary energy consumption of the existing



EFFESUS • 314678 • of 262

building and K.A. refers to the total primary energy consumption of the reference building.

The reference building is defined as a building with the same geometrical characteristics

as the building under consideration, which has specified characteristics for the U values of

all the structural elements, as well as for the energy efficiency of heating, cooling and

lighting installations. The reference building is always rated as Energy Class B. Other

categories are defined as percentage of energy consumption of the reference building.

Category Limits Α+ Ε.A. ≤ 0,33K.A. Α 0,33 K.A. < Ε.A. ≤ 0,50 K.A. Β+ 0,50 K.A. < Ε.A. ≤ 0,75 K.A. B 0,75 K.A. < Ε.A. ≤ 1,00 K.A. Γ 1,00 K.A. < Ε.A. ≤ 1,41 K.A. ∆ 1,41 K.A. < Ε.A. ≤ 1,82 K.A. Ε 1,82 K.A. < Ε.A. ≤ 2,27 K.A. Ζ 2,27 K.A. < Ε.A. ≤ 2,73 K.A.

Η 2,73K.A. < Ε.A. Table 10.1 Classification of Buildings according their Energy efficiency

Source: Ministry of Environment, Energy and Climate Change

According to the Regulation of the Energy Performance of Buildings, a set of minimum

requirements are applied to new buildings. Therefore, all applications for building permits

after the 1st of October 2010 must be accompanied by an Energy Study that proves that

the building under planning is in compliance with these minimum requirements.

The type and level of requirements are a function of the type of building (dwellings, tertiary

sector buildings) and cover:

The design of the building, taking orientation, surrounding area, passive solar systems,

natural ventilation, daylight etc., into account:

Maximum U-value for walls, windows, roofs etc., for each one of the four climatic zones in

Greece. The main parameter used for the climatic zones is the annual heating degree-da

Maximum value for the average U-value for the whole building

At least 50% heat recovery in the central air-conditioning units

Minimum levels of insulation of the heating and cooling distribution network

At least 60% hot water production from solar panels.

Minimum requirement for lighting installations in the tertiary sector buildings (55 lm/W).

Figure 10.1 Classification of Climate Zones in Greece Source: Ministry of Environment, Energy and Climate Change



EFFESUS • 314678 • of 262

The Energy study must prove that all new buildings are classified at least as B. After the

completion of the construction, an energy audit is conducted and the energy certificate is

issued. If the constructed building deviates from the design and is not classified at least as

B, the owner must perform all necessary improvements within a year.

Existing buildings undergoing major renovation should be upgraded in order to be

classified at least as B.

The general certificate model to be used will be the A+ to H label. There are three

categories above the B level, that is A+, A, and B+, in order to stimulate

competition towards very efficient building designs in the future. On the first page of the

certificate one can find:

The basic data of the building (location, owner, building use, climatic zone, year of

construction, total surface area, heated area).

The classification which is done based on the primary energy consumption of the building

compared to the primary energy consumption of a reference building.

The calculated primary energy consumption of the building and of the reference building.

The calculated CO2 emissions.

The actual total energy consumption data and the consumption by energy carrier based

on the bills available over the last three years, as well as the calculated CO2 emissions.

An indication of the quality of thermal, visual and acoustic comfort and air quality.

On the second page of the certificate (Figure 10.2), there is space for presenting at least

three recommendations specific to the building, for which the software calculates the

energy savings, cost and payback period.

Figure 10.2. Certificate of Building Energy Efficiency Source: Ministry of Environment, Energy and Climate Change



EFFESUS • 314678 • of 262

44



The certificate is issued by energy auditors, who are listed in the official registry of auditors

(provisional for the time being), which is maintained by the Department of Energy Audits,

Ministry of Environment, Energy and Climate Change. The database development and

maintenance, together with the development and operation of the Energy Certificates

database, is done by Centre of Renewable Energy Sources (CRES).

The certificate is valid for ten years, unless the building undergoes major renovation, in

which case a new certificate is required. All the certificates and the data used for the

calculations are stored in a central electronic register, which is operated by CRES.

Certification is obligatory for new buildings with a building permit issued after the 1st of

October 2010. The public sight of the certificate is compulsory for public buildings (public

buildings are those used by public authorities, rented or owned).

The certificate is required as a legal document in the case of rental or sale of buildings

after the 9th of January 2011.

11. a) In what ways are historic buildings and historic environments 44 excluded from or

included in the minimum energy performance requirem ents for existing buildings?

Can you please give examples?

Under the provision of article 11 of Law 3661/2008 and as clarified in the relevant Circular

‘All buildings and monuments protected by the law due to their classification as part of a

specific environment or their architectural / historical value (as in the case of historical

buildings), are obliged to an assessment of energy performance in case of major

renovation, given that their compliance with the Law 3661/2008 and the KENAK would not

result in altering their characteristics or appearance in an unacceptable manner.

In this case, energy classification of the building under the provision of article 5 of Law

3661/2008 is carried out to the extent that this is technically, functionally and economically

feasible.


requirements, what is the most common reason? 45 Can you please give examples?


Monuments

Buildings officially protected as part of a specific environment or due to their special

architectural or historic value (listed within traditional settlements, etc.), provided that their

compliance with minimum energy performance requirements would not result in altering

their characteristics or appearance in an unacceptable manner.

Buildings used as places of worship or for religious activities

Buildings of temporary use with duration not exceeding the period of two years according

to their design, industrial facilities, craft industries, laboratories, warehouses, parking lots,

gas stations, non-residential buildings for agricultural uses with low energy requirements

and buildings used by a sector under a national agreement regarding buildings’ energy



EFFESUS • 314678 • of 262

46


performance.

12.

Describe the national legal methodology for the cal culation of the minimum energy

performance of buildings. 46

The regulation of Buildings’ Energy Performance (KENAK), approved by the joint decision

of the Ministers of Finance and Environment, Energy and Climate Change, defines the

appropriate calculation methodology, the minimum requirements for energy efficiency in

buildings, the type and content of the required Energy Efficiency Study conducted for the

buildings or building units, the procedure and the frequency of energy audits of buildings,

heating and air conditioning systems, the type and the content of the issued Energy

Performance Certificate, the issuance process, the control of the energy audit, the bodies

responsible for this and any other specific issues or necessary detail.

KENAK regulation also sets the parameters for the calculations of economic feasibility of

the cases of Articles 7 and 8, the technical specifications and the minimum energy

performance requirements of nearly zero emissions buildings of Article 9.

Under the provision of article 5 of KENAK, the methodology applied for the assessment of

buildings’ energy performance is a quasi-steady monthly method in line with European

Standards EN ISO 13790 (2009), as summarized in the following table.

The energy efficiency of a building is determined by the calculated or actual annual energy

consumption to meet the needs associated with the building’s use including the energy

needs for heating, cooling, ventilation and lighting in order to achieve internal conditions of

thermal and visual comfort as well as needs for hot water.

The energy performance of a building should be clearly expressed and include Energy

Efficiency Index (energy categories) and numeric index for primary energy use, based on

conversion rates of the final primary energy consumption, which are based on national or

regional annual weighted averages or special price for site production.

The calculation methodology is determined by the provisions of the EU Regulation no.

244/2012 of Committee of 16th January 2012 «In completion of the Directive 2010/31/EC

of the European Parliament and of the EU Council on the buildings’ energy performance

by defining comparative methodology framework for calculating cost-optimal levels of

minimum energy performance requirements for buildings and structural components» (L

81 / 03.21.2012).

The main calculation methodology of the EPBD though is mainly based in the typology of

the reference buildings it has been produced by the TABULA PROJECT (TABULA:

www.building-typology.eu) in order to determine the optimum relation of cost – efficiency

and the optimal conditions of energy efficiency.

In more detail the calculation method takes in consideration:

the actual thermal characteristics of building (internal partitions included):

aa) heat capacity,

bb) thermal insulation,



EFFESUS • 314678 • of 262

cc) thermal bridges,

Heat and hot water supply installations, included their insulation characteristics,

Air conditioning installation, included its insulation characteristics,

Natural and mechanical ventilation which may also include airtightness,

Installation of general lighting (in the tertiary sector buildings)

design, location and orientation of the building, including outdoor climate,

passive and hybrid solar systems for solar protection

passive heating and cooling,

indoor climatic conditions, taking into account the conditions of indoor climate design and

internal loadings

In the calculations of energy efficiency, the positive effect of the following factors in taken

into account:

Active solar systems and other heating, cooling, hot water supply and power systems

based on energy from renewable

useful heat and electricity energy produced by cogeneration

district heating and district cooling in regional or block range,

natural lighting

In order to calculate energy building efficiency, buildings are classified in the following

categories of use, as specified according to currently valid planning provisions:

detached houseς of various types,

multifamily houses,

offices,

educational buildings,

hospitals,

hotels,

restaurants,

sports facilities,

buildings of wholesale and retail trading services,

As well as other building types that consume energy to condition the indoor climate

conditions, in order to ensure the comfort of users.

Calculations are carried out with the use of specific software validated by Special Service

of Energy Inspection which is under the jurisdiction of The Special Secretariat for the

Environment and Energy Inspectorate (SSEEI) of Ministry of Environment, Energy &

Climate Change.

A software tool was developed with funding from the Hellenic Technical Chamber. This

can be used as a stand-alone tool for energy audits and benchmarking and it is available

to software companies, in order to integrate it into already existing tools. Any new software

that comes into the market must be verified by the Department of Energy Audits, Ministry

of Environment, Energy and Climate Change. The main criterion is that the software uses

the computational engine developed by the Technical Chamber and produces the same

results for a test case.



EFFESUS • 314678 • of 262

The software calculations’ have been defined from architectural and electro-mechanical

studies and drawings, energy audit, in accordance with the Technical Instructions by

Technical Chamber of Greece (TITCG) concerning climatic data and fields could be assed

and modified are:

Use of the building, desired conditions of internal environment (temperature, humidity,

indoor ventilation), functional characteristics and number of users.

Climatic data of the building surrounding area (temperature, humidity, air speed and solar

radiation).

Geometrical characteristics the structural components of the building envelope (building’s

shape and form, transparent and non- transparent surfaces, shutters, etc.) in relation to

building’s orientation and to the characteristics of internal structural components (partitions

etc.). Thermal characteristics of the building’s envelope structural components and

materials (thermal transmittance, thermal mass, solar absorption).

Technical characteristics of heating installations (type of systems, supply system, system’s

efficiency, etc.)

Technical characteristics of cooling/AC installations (type of systems, supply system,

system efficiency, etc.)

Technical characteristics of mechanical ventilation installations (type of systems, supply

system, system efficiency, etc.)

Technical characteristics of hot water generation systems (type of systems, supply

system, system efficiency, etc.)

Technical characteristics of lighting installations in the tertiary sector buildings.

Passive solar systems if present in the building

Energetic solar systems and other heating/ cooling/ electricity generation systems with the

utilization of RES.

Generated Energy by cogeneration technologies of electricity and heating / cooling

Central heating and/or cooling systems in regional or building block range (district

heating).

Exploitation of natural lighting.

The same methodology is applied for the calculation of the total primary energy

consumption for both the building under consideration and the reference building.

The calculation method of building energy performance will be re-evaluated in a regular

basis in accordance with paragraph 5 of article 3 of Law 3661/08. The first re-evaluation

must be carried out two years after KENAK entry into force. The calculation of the

estimated final fuel consumption into primary is based on the conversion coefficients

included in the following table:



EFFESUS • 314678 • of 262

Energy Source Conversion Coefficient

to primary energy

Pollutants emitted per

unit

energy (kgCO 2/kWh)

Natural gas 1,05 0,196

Heating oil 1,1 0,264

Electrical energy 2,9 0,989

LPG 1,05 0,238

Biomass 1

District Heating PPC

0,70

0,7 0,347

Additionally, for the Energy Efficiency of the buildings, the Greek Standards Organization

(ELOT) under the supervision of the Ministry of Environment, Energy and Climate Change

trying to incorporate the local conditions and standards to the EPBD, has issued the

following Greek Standards which they not only take into consideration the specific climate

and regional requirements but are fully in line with the relevant EU Directives:

ELOT EN ISO 13790:2008 Energy performance of buildings -- Calculation of energy

use for space heating and cooling

ELOT EN 15316.01:2008

Heating systems in buildings - Method for calculation of

system energy requirements and system efficiencies – Part

1: General

ELOT EN

15316.02.01:2008

Heating systems in buildings - method of calculation of

system energy requirements and system efficiencies - part

2-1: space heating emission systems

ELOT EN

15316.02.03:2008


system energy requirements and system efficiencies - Part

2.3: Space heating distribution system

ELOT EN

15316.04.01:2008



4-1: space heating generation systems - combustion

systems (boilers)

ELOT EN

15316.04.02:2008



4-2: space heating generation systems - heating pump

systems

ELOT EN

15316.04.03:2008



4-3: heating systems, thermal solar



EFFESUS • 314678 • of 262

ELOT EN

15316.04.04:2008



4-4: space heating generation systems. Cogeneration

systems embedded in the building

ELOT EN

15316.04.05:2008

Heating systems in buildings - method of calculating energy

systems' requirements and systems' performance - Part 4-

5: space heating generation systems. Performance and

quality of district heating and large volume systems

ELOT EN

15316.04.06:2008

Heating systems in buildings - method of calculating energy

systems' requirements and systems' performance - Part 4-

6: space heating generation systems. Photovoltaics

ELOT EN

15316.04.07:2010



4-7: space heating generation systems. Biomass

combustion systems

ELOT EN 15243:2008 Rolling bearings -- Damage and failures -- Terms,

characteristics and causes

ELOT EN ISO 13790:2008 Energy performance of buildings -- Calculation of energy

use for space heating and cooling

ELOT EN ISO 13789:2007 Thermal performance of buildings -- Transmission and

ventilation heat transfer coefficients -- Calculation method

ELOT EN ISO 6946:2007 Building components and building elements -- Thermal

resistance and thermal transmittance -- Calculation method

ELOT EN ISO 13370:2007 Thermal performance of buildings -- Heat transfer via the

ground -- Calculation methods

ELOT EN ISO 14683:2007 Thermal bridges in building construction -- Linear thermal

transmittance -- Simplified methods and default values

ELOT EN ISO 10211:2007 Thermal bridges in building construction -- Heat flows and

surface temperatures -- Detailed calculations

EN ISO 10077-1:2006 Thermal performance of windows, doors and shutters --

Calculation of thermal transmittance -- Part 1: General

ELOT EN 15241:2012 Rolling bearings -- Symbols for physical quantities

ELOT EN ISO 15927-

1:2003

Hygrothermal performance of buildings -- Calculation and

presentation of climatic data -- Part 1: Monthly means of

single meteorological elements

Also, the Technical Chamber of Greece in order to cover the installation gaps were

existing prior the implementation of the EPBD and the ELOT Standards, issued a number



EFFESUS • 314678 • of 262

Technical Instructions by Technical Chamber of Greece (TITCG) which are yearly revised

and updated, for the following issues:

ΤIΤCG DESCRIPTION APPROVALS ISSUES

2411/86 Plumbing Installation on

Houses

FEC 843Β/16-11-

88 D΄ Edition

2412/86 Sewage Installations on

Houses

FEC 177/Β/31-3-

88 E΄ Edition

2421 · Part

1/86

Heating Installations on

Houses FEC 67/Β/4-2-88 D΄ Edition

2421 - Part

2/86

Heating Installations on

Multi-storey Houses

FEC 148/Β/17-3-

88 D΄ Edition

2423/86 AC Installations on Houses FEC 177/Β/31-

3/88 C΄ Edition

2425/86 AC Installations on Multi-

storey Houses

FEC 177/Β/31-

3/88 E΄ Edition

2427/83 Central Heating Installation

on Houses FEC 631∆/7-11-85 E΄ Edition

2451/86 Fire fighting Installations FEC 632/Β/26-11-

87 E΄ Edition

2471/8 Gas Sytem installations on

Buildings

FEC 366/Β/16-7-

87

FEC 187/Α/20-10-

87

D΄ Edition

2481/86 Vapor Installations on

Buildings

FEC 334/Β/24-6-

87 D΄ Edition

2491/86 Installation of gas supply

systems for Medical use FEC 665/Β/9-9-88 C΄ Edition

13.

Is life cycle assessment (LCA) a part of the evalua tion of the energy performance in

buildings?

By definition, making an LCA or determining the LCC of a building covers the whole life

cycle of a building. This means that generic information about the potential

environmentally negative activities related to each stage of the life cycle is needed from



EFFESUS • 314678 • of 262

the very beginning of the process. The life cycle stage of a building include according to

CEN/TC 350 the product stage, construction stage, use stage and end of-life stage but is

not calculated to the EPBD.

At present, the LCA methodology is standardized by the Technical Chamber of Greece by

the ISO 14040:2006 and ISO 14044:2006. This standard describes the principles and

framework for LCA, but it does not describe the LCA technique in detail, nor does it

specify methodologies for the individual phases of the LCA. The intended application of

LCA results is considered during definition of the goal and scope, but the application itself

is out-side the scope of this International Standard.

The CEN/TC 350 “Sustainability of Construction works” standard is under development.

This standard will provide a calculation method based on LCA to assess the

environmental performance of a building and give the means of communication of the

outcome of the assessment.

The building process and examples of options for taking LCA-based decisions in different

phases:

Phase Specifications Actors Planning

instruments

Project

development/

planning phase

City/spatial planning authority

sets the frames for the

development

Choice of site, orientation

Costs

Size (e.g. room allocation plans)

Targets for the energy

performance, environmental

impact, health requirements etc.

are started

Municipality Master plan

Local plan

Land contract

Local Agenda

21

Local

environmental

targets

Investigation

phase

The developer starts the design

process. This phase is probably

one of the most important

phases in the building process.

All project phases of a new

building are based on

specifications made in this

phase, so here we can find the

highest potential for sustainable

building design.

Design – construction (e.g.

lightweight or solid construction)

Materials to be used

If possible e.g. benchmarks for

Developer Environmental

programme

Early sketch



EFFESUS • 314678 • of 262

heating and cooling, renewable

energy sources for the building

services etc.

Preliminary

Conceptual

design/ architect

competition

Revised preliminary design,

including preliminary selection of

superstructure, building

materials, constructions. This

phase mainly raises design –

related issues such as definition

of heated/cooled areas,

shape/volume ratio, area and

disposition of windows, building

position and orientation. It is

generally too easy to decide

details about the technical

systems (HVAC) and choice of

building materials.

Developer,

architect

Environmental

programme

Submission

planning

Final design for submission to

building authority for planning

permission (determination of

superstructure, building

materials, constructions).

Energy certificate following the

(EPBD)

Architect Sketch

Detailed design

phase/

implementation

planning

Final selection of superstructure,

building materials, constructions,

systems for building services as

the base for tendering for the

construction work. In this design

phase the exact definition of all

components of the building and

the HVAC system are

addressed.

Architect,

consultants,

developer

Tendering

documents

Environmental

plan

Construction

phase

The construction work according

to the implementation plan is

now carried out. This should

include clear quality assurance

measures for monitoring energy

and ecological performance.

Contractor,

developer



EFFESUS • 314678 • of 262

47


14. In these questions we would like to know in which s ituations the requirements for





EPBD is valid for 10 years under the condition that no any alternations to crucial elements

of the structure have been occurred in the meantime. (See question 10)

According the existing Legislation (L 3212/2003, L 2508/1997 FEC -124/Α/13-6-97,

Regulation 54247/34/25-5-98, L 2508/97 (EC -124/Α/13-6-97, and P.C. 24/31-5-85)

major renovation considered to be any renovation requires a Building Permit or major E/M

elements e.g. boilers, lifts, E/M installations, etc. are upgraded. (See question 4)



The energy certificate is not detached with the current or future use of the building but is

examining the performance behaviour of the building or its elements.

Though, in some cases of change of use Local Authorities might among other

requirements require a new certificate especially if the building is converted to a public

gathering or commercial building e.g. cinemas, theatres, malls, private museums etc.

Additionally, EPBD needs to be reissued to the following cases when:

the building will be sold or change ownership status (owners responsibility)

the building will be rented (owners responsibility)

the building area is larger than 500 sqm and will be used for any Public Authorities

services. From the 9th of July 2015 the minimum area for this type of buildings would be

250 sqm.

the building (any type) area is less than 50sqm no EPBD required. From the 01.01.2016

this rule will not be valid.



The long term plan of the Ministry of Environment, Energy and Climate Change is:

Revaluate the energy efficiency requirements after the completion of 5 years of the EPBD

implementation (EPBD Recast).

Revaluate the EPBD calculation method at 2013 (EPBD Recast).

Fully harmonisation of the Greek Legislation (KENAK) with the updated EU Directive

2010/31/EC

Update the Technical Instructions by Technical Chamber of Greece (TITCG) in order to

fulfill the previous preconditions



are met?



EFFESUS • 314678 • of 262

The Ministry of Environment, Energy and Climate Change has created a register of

Energy Inspectors, in the form of an electronic database, which entered with the Serial

Number Registry Energy Inspectors with all required details.

To the Register are three (3) categories of Energy Inspectors, as follows:

Energy Inspectors Buildings

Energy Inspectors heating system and

Energy Inspectors HVAC Systems.

Also, an Achieve Building Inspection Platform has been created in the form of an

electronic database maintained by the Ministry of Environment, Energy and Climate

Change and updated electronically by Energy Inspectors, who are responsible to record

in it:

the Building Energy Performance Certificates and the corresponding forms of energy

audit of buildings,

the inspection of building heating system and

the inspection of air conditioning systems of buildings.

To control and monitor the process and quality of the energy audits, the accuracy of the

issued EPBD and the Regular Inspection Reports of the recorded E/M systems of

buildings, as well as the reliable execution of the tasks of the appointed Energy

Inspectors and their compliance and enforcement of provisions of the existing Legislation,

the Ministry of Environment, Energy and Climate Change has appointed the jurisdiction of

the Special Inspectorate Energy (EVEPEN) in accordance with the provisions of

Presidential Decree 72/2010 (132 A).

Regular audits are carried out ex officio, and in random sampling of at least five percent

(5%) or after termination of all EPBD and inspection reports and consisting of:

check the validity and accuracy of input data stored in the form of electronic data files in

the Archive Building Inspection Platform maintained by the Ministry of Environment,

Energy and Climate Change

electronically verification of the results of the EPBD and the inspection report, including

the recommendations of the Energy Inspectors,

site inspection of the reference building to verify the accuracy of EPBD and inspection

report

For additional comments see questions 4 & 10

16 Are minimum energy performance requirements limited only to the renovated parts

or to the whole building?

It applies to the whole building but is to the discretion of the owner (depending on the

nature of works, cost and custom needs of each one) to apply these requirements to the

whole building or at a part of it.

17. In what ways are the national legal requirements fo r minimum energy performance


Through:



EFFESUS • 314678 • of 262

48




funding?

X Energy Saving at Home

Saving Energy

Energy Performance Improvement of Public

Buildings.

Energy Performance Improvement of

School Buildings

(See question 6)

b) advantages /


taxation?

X


X

d) information?

X http://gis.ktimanet.gr/wms/ktbasemap/defau

lt.aspx

http://www1.okxe.gr/geonetwork/srv/en/mai

n.home

http://web.gys.gr/GeoSearch_EN/

http://geodata.gov.gr/maps/

http://estia.minenv.gr/

http://opac.tee.gr/cgi-bin-

EN/egwcgi/egwirtcl/targets.egw

http://opac.tee.gr/cgi-bin-

EL/egwcgi/463225/query.egw;/-

1+artemis.tee.gr:216/ADVANCE

e) energy performance

certificate? 48

X Through the subsidies (see question 6)

f) technica l assistance and

advice?

X Ministry of Education and Religious Affairs,

Culture and Sports

Ministry of Environment, Energy & Climate

Change

Ministry of Justice, Transparency



EFFESUS • 314678 • of 262

and Human Rights

Public authorities (see question 2)


(See question 6)

18. Are there or can there be applied a requirement for competency or experience when

working with historic buildings and energy efficien cy?

In Greece there is not a requirement for competency or experience to work with historic

buildings. Though the owners of such kind of buildings are always seeking due to the

complexity of technical requirements and advanced skills required experienced companies

and/or contracts to appoint them for the execution of works.

Some well established companies contractors are the following:

http://www.exinos.gr/02_aei.html

http://www.epidomos.gr/

http://www.ttee.gr/el/repair/masonry

http://www.nakos.com.gr/meletes.html

http://www.takisgavrilis.gr/?page_id=2

http://mourtzouchos.net/kdm/main.htm

http://www.houseservice.gr/service.php?sid=57

http://etechniki.com/?page_id=47

http://www.bousias.gr/index.htm

http://www.polismichaniki.gr/polis/index.php/item/17.html

http://www.kdm.gr/

http://www.drymalitis.gr/

http://www.anadomisi.gr/index.php/construction-works/7-refurbished-listed/

http://www.kaxiris-constructions.com/services.htm

http://www.arketipo.gr/activity/restoration-reinforcement-of-buildings/

http://www.vezyrgiannis.gr/

http://www.eltexnika.gr/

http://www.techoexpress.4ty.gr/

http://www.psichas.gr/

http://www.esghellas.gr/

http://www.xoroprotasi.gr/



In summary the main concept of the applied legislation is that Central Government should

legislate the General Rules and to allow the flexibility to Regions, Districts, Counties and

Municipalities to legislate by themselves for certain historic buildings or districts according

public audits and Official Recommendations to the relevant Ministry by the Local

Authorities.



EFFESUS • 314678 • of 262


Though, there are cases that Local Authorities Official Recommendations have not been

approved or have been modified by the Ministry of Culture of The Ministry of Environment,

Energy and Climate Change (depending the nature of the Official Recommendation) due

to limitations applied by the National Legislation, e.g. an Historic Market in the city of

Chalkis has not been characterised as Grade II Historic Building having all the benefits

and the limitations of an Historic Building due to constant appeals to the characterisation

by the some of the owners (see question 8) and will be demolished as the Supreme Court

has accepted some other owners appealed as they were not consent to the Official

Recommendation of the Municipality of Chalkis to the Ministry of Culture, presenting a law

case of 1955 which was not allowing the status change of the ownership in multiple owned

properties if all owners are not fully consent to it.

In the other hand, most of the times the Official Recommendations by the Authorities are

compulsory for the owners and especially the Official Recommendations form the

Archaeological Departments which are excluded from any Public Audit and applying even

to the Local Authorities (Municipalities and Counties) having an immediate effect and are

not necessary to be published to the Official Gazette.

For additional conflicts see question 4



Name: Dr. Gelly Papavasiliou

Affiliations : Ms. Aggeliki Antonopoulou

Mrs. Maria Sachini

Mr. Konstantinos Tsoutis


Dr. Gelly Papavasiliou

Advanced Management Solutions Ltd

465, Irakliou Ave.,

GR14122, Neo Iraklio,

Athens,

Greece

Tel: +302102842615

Fax: +302102817160

Mail: [email protected]



EFFESUS • 314678 • of 262

Questionnaire

Answers from Komárom-Esztergom County's Government Office for C onstruction and Heritage

Protection – marked with blue.

Answers from Nógrád County's Government Office – marked with green.

Answers collected by the team of HOR-BER – marked w ith black.

1. Please state the name of your country.

If there are differences in legislation between the various regions within a country, one or more regions may be

described in the following questions. Please state the name of the region you will be answering the questions

for.

Hungary

2. Please explain how the heritage management (auth orities) are organized and what their obligations

are.

Deputy State Secretariat for Regional Development a nd Construction (belonging to the Ministry of

Interior).

The Deputy State Secretariat for Regional Developme nt and Construction is responsible for

determining specialist regulations related to spati al planning in settlements, analyzing trends in spa tial

planning, developing legislative proposals, oversee ing the implementation of subsequent decisions,

directing implementation of legislation and initiat ing measures necessary to achieve this.

Fields of responsibility:

Spatial planning, settlement matters

Spatial planning establishes the regulations and po licy for the land-use. By the preparation of spatia l

plans, the technical-physical systems must be defin ed, and attention should be paid that the plan’s

spatial structural and the regulatory elements fit into the regulations of spatial structural elements and

spatial planning defined by the international co-op eration.

Construction matters

The definition of construction matters encompasses those activities, which contribute dire ctly to the

forming and the preservation of the built environme nt. Under the definition of construction matters fall

the spatial planning, urban planning, construction of buildings and heritage preservation as well. The

construction matters’ central management – in regard to the spatial plann ing, the relevant national

regulations and the requirements of public interest –, co-ordination and control are the state’s

responsibility.

Monitoring System of Construction Matters (ÉMR)

The monitoring system of construction matters is a geographic information system (GIS), which is

monitoring, tracking, analyzing and recording the u nits of the land-use, the planned and actual data o f

the buildings and their changes.

Settlement development

The settlement development is a settlement-wide soc io-economic and environment-forming activity,

which aims to improve the population’s standards of living, supply and environmental conditions, and

to secure the sustainable settlement development. T he preparation of the development plans is the

local government’s responsibility – with the involv ement of the inhabitants and the concerned

professionals.



EFFESUS • 314678 • of 262

National Chief Architect's Office

Its tasks are to maintain a high quality of the Hun garian architecture, to improve the general visual

culture, to support the architectural activities, a nd to strengthen its recognition in public life and

thinking. It aims to preserve the architectural val ues and traditions, and to spread the modern techni cal

and organizational solutions. It represents the pro fessional interests of the architects and the

constructional sector in the professional commissio n of the European Union.

Heritage Preservation

Provides the preparation, to declare as preserved t he archeological sites, monuments and historic site s.

Performs the professional manager tasks in the fiel ds of preservation of monuments and archeological

heritage preservation. Prepares and comments strate gic documents and laws, contributes in their

amendments. Operates professional committees (Excav ation Committee, Monuments Advisory Board).

Takes care of international professional relations and co-operation programs.

The obligations of heritage management:

Exploration of heritage value, research, estimation, review, documentation, registration and scheduling

protected monuments and historic environments

Preservation of historic buildings and environments, their restoration and protection, and the utilization of these

according to their goodwill value.

Maintenance and development of historic environments, and the determination of the appropriate method of

maintenance due to their value.

Scientific research, exploration, education and expanding knowledge.

Cultural heritage carries the spiritual value of a whole nation, therefore it is everyone's duty to protect it. It is

forbidden to endanger, damage, destroy or adulterate the elements of heritage values.

The protection of cultural heritage is public weal, it's realization means contribution rights and cooperative

obligation for government members, gentilitial organizations, the church, social and economic organizations

and for citizens.

Within the confines of international cooperation – in accordance with international contracts – it is needed to

enforce the protection of Hungarian trans-border heritage, and other countries' cultural heritage in our inland.

The authority of 1 st instance: Construction and Heritage Bureau of the capital's and the county capital's

regional offices.

The authority of 2 nd instance: Construction and Heritage Bureau of the Capital and County Government

Office.

The authority is responsible for the preservation, the subservience and support of the sustainable use

of cultural heritage elements. For this purpose it assumes:

The authority and special authority duties defined by the acts and decrees;

The supervision duties of the heritage protection;

The scientific duties defined by the law, and their co-ordination; and

Other duties, entrusted to their competence.

By construction activities on the monument, the con struction authority – in cases defined by

legislation – carries out authorization procedure a nd control.

The authority permits the activities, which – defin ed by the legislation – don't require permission o f the

construction authority or other authorities.



EFFESUS • 314678 • of 262

The authority – in order of monumental protection – may differ from the national legislation of

construction and mandatory national standards by th e authorization of the monument's renovation and

restoration works. The difference shall be authoriz ed, if the applied solution meets the requirements of

life and property security (or can be provided othe rwise).

The authority – (as the supervisor of heritage prot ection):

monitors the condition of cultural heritage element s and their proper use;

carries out activities which subserve sustainable a nd complex protection;

subserves professional and social collaboration whi ch affects the interests of heritage protection.

Involvement of the Planning Councils

In case of monuments, the commentary is duty of the central planning council (I. and II. category) or the

regional architectural-engineering council (III. category) (Government Decree No. 252/2006 (XII. 7.) on the

settlement arrangement and architectural-engineering planning councils).

Central planning council comments:

design documentation of the significant construction cases from the point of view of the national economy,

design documentation related to building permission of the monuments from the I. and II. Categories,

documentation of the heritage protection related to the I. and II. categories, and (according to the Government

Decree No. 393/2012 (XII. 20)) in case of renovation of the entire facade or the entire interior,

for the request of the second instance authority, the documentation commented by the regional architectural-

engineering council.

Regional architectural-engineering council comments:

the design documentation of the area or building under local monumental protection in the capital,

design documentation related to the building permission of the monuments from the III. category,

design documentation of the heritage protection related to the III. category,

in world heritage or conservation area, the design documentation of the building, which is closest to the street,

but is max 10 meters far from it (in absence of the mayor’s townscape opinion).

Please describe the heritage management on:

a) national level: preparation for protection and registration of monuments, scientific background work which

establishes the verdict of authorities 1st instance.

b) regional level: the authorities of the 1st and 2nd instance are both on county level.

c) local level: local protection and its enforcement is a task of a settlement. Municipal regulations are created

in order to describe how protected monuments can be restored/renovated and which are the main aspects of

protection.

d) other

3. Explain how the authorities which regulate energ y performance in buildings (energy management)

are organized and their obligations.

Construction authorities

The provisions relating to the construction authorities; the nomination and operating conditions of the

construction's supervision authorities are included in the Government Decree No. 343/2006 (XII. 23.)

The Government nominates the notary of the local government to be responsible as the primary construction

authority.



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The Government nominates the public administration office to be responsible as the secondary construction

authority.

In case of the buildings, which are under heritage protection, the responsible construction authorities are

nominated by special legislation. In the absence of such legislation, the public administration office and the

notary of the local government are dealing with the case. If the legislation prescribes, that the primary

construction authority is the public administration office, than Minister of Construction deals with the secondary

cases.

4. Please describe the cooperation between heritage management and energy management, and give

an overview of possible conflicts. (Please illustra te the cooperation with an example.)

Energy performance requirements do not pertain to buildings with heritage protection status. If someone wants

to renovate/restore a building with heritage protection status (irrespectively of whether the work consist energy

management or not), the approval of the heritage management department is needed.

Possible conflicts (since supported solutions regarding energy performance are difficult to reconcile with

historical structures and the appearance of monuments):

Heat transfer coefficients of historic windows and doors (building openings) are difficult to measure, therefore

these can not be considered in energy performance competitions – applicants rather plan on changing these

doors and windows during the restoring works.

Outer thermal insulation brings down the performance of walls of historic buildings (humidification for example)

and it eventuates the disappearance of ornaments of a facade therefore it is authorized only in special cases.

Installation of photovoltaic and solar panels worsens the historic appearance of monuments and historic

environments.


Competitions for renovation of a monument's energy performance; partial restorations with the consideration of

historical value.

5. Please describe the national political goals for reducing emissions (CO2) and promoting energy

saving measures in existing buildings, historic bui ldings and historic environments.

Domestic laws are delivered in accordance with the EPBD. Currently there are conciliations about the

inauguration of more strict requirements.

Energy performance requirements will be extended to existing buildings (with conditions), from July 9, 2013.

Nearly Zero Energy Building requirements will come into force in the EU from 2019 regarding public buildings,

and from 2020 regarding residential buildings.

Energy performance requirements are not regarded to historic buildings, arrangements refer only to not

protected buildings.

6. Please describe how the goals in question 5 are proposed to be achieved.

By means of different competitions that support energetic renovations.

National Climate Change Strategy (NCCS)

The National Climate Change Strategy (NCCS) was prepared pursuant to §3 of Act No. LX/2007 (V. 28.) on the

framework for the implementation of the UN Framework Convention on Climate Change and of the Kyoto

Protocol thereof. In accordance with the national commitments, the Climate Change Strategy had to be

elaborated for the first time for the 2008-2025 period. The objectives of the National Climate Change Strategy

shall be implemented by National Climate Change Programs to be prepared on a biannual basis. The NCCS is



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also adjusted to the National Sustainable Development Strategy adopted by the Government by Gov. Decree

No. 1054/2007 (VII. 9.).

Climate change is a risk threatening both the Hungarian society and the national economy, and forces action.

Multiple analysis suggest that our natural values, water resources, flora and fauna, forests, agricultural

production yields, buildings, residential environment, public health and quality of life are all threatened by the

significant changes in temperatures and precipitation rates, the possible shifting of seasons and the

intensification and increased frequency of certain extreme weather phenomena as predicted for the following

decades. A group of scientists of the United Nations concluded that Hungary is one of the most vulnerable

countries of Europe in terms of the effects of the climate change on biological diversity, i.e., the multiplicity of

species.

The scientific background for the NCCS was a research project known as "Global Climate Change: National

Effects and Responses VAHAVA (VÁltozás – HAtás –VÁlaszok; "Change – Effect – Responses")".

Background, the importance of the Strategy The NCCS identifies three major directions of action for the long

term climate change policy:

1. it foresees measures in compliance with the EU and international requirements in order to reduce the

emissions of climate change gases and to prevent the increase thereof. The reduction of greenhouse gas

emissions should be achieved by reducing the overall energy use in a manner that enables a shift in production

and consumption structures towards lower material and energy needs.

2. it includes the key elements of the fight against the unfavorable ecological and socio-economic effects of the

inevitable climate change, and of the improvement of the adaptability to the consequences of the climate

change; and

3. the raising of social awareness of the climate change and the strengthening of climate awareness.

The NCCS is an explicitly inter-sectoral and all-social framework system and affects all economic sectors and

all social groups. Therefore, the relevant strategic objectives and tasks should be integrated into the activities of

all sectors (and ministries).

National Energy Strategy

The challenges related to the imminent change of the energy structure may be turned to the advantage of our

country. In order to do so, however, we should be able to make the most of the opportunities, conducive to

employment and economic growth, offered by energy improvements. the change of the energy structure should

include:

(I) energy efficiency measures spanning the entire supply and consumption chain;

(II) increasing the share of low CO2-intensive electricity generation based primarily on renewable sources of

energy;

(III) promoting renewable and alternative methods of heat generation;

(IV) increasing the share of low CO2-emission modes of transport.

7. a) Describe the national and regional legal syst ems for protecting historic buildings.

Act No. LXIV/2001 on the conservation of cultural heritage

Act No. LXXVII/2011 on the world heritage

Act No. LXXVII/1997 on the built environment and its conservation

Governmental Decree No. 393/2012 (XII. 20.) on the rules relating to the preservation of archeological and

historic values



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Governmental Decree No. 312/2012 (XI. 8.) on the procedures and controls of the constructions and

construction's supervision authorities, and on the services of the construction authorities

Decree of Ministry of Interior No. 80/2012 (XII. 28.) on the registration of archeological sites and historic

buildings, their declaration to be protected, and on the detailed rules of archeological excavation

Decree of Ministry of Rural Development No. 66/1999 (VIII. 13.) on professional rules of the protection of local

architectural heritage.

The protection is based on real estate.

7. b) Describe the national and regional legal syst ems for protecting historic environments.

See question 7. a).

8. a) How are historic buildings categorized? Pleas e give examples from the different categories.

International preservation – World Heritage

Categories of World Heritage (Cultural, Natural)

Cultural and Natural heritage sites with outstanding significance and universal value can be registered to the

World Heritage list, which are uniquely meaningful not only for a specific country, but for the whole humanity.

The Convention includes those criteria, which are used to pronounce an environment as part of the World

Heritage. The criteria are categorized in two groups in the actual regulations, based on this, an environment is

either part of the category of the cultural- or the natural heritage in the list of World Heritage. In the first one, the

main criterion is historical authenticity, while in case of natural heritage the main criterion is integrity (untouched,

undamaged).

Cultural heritage

Cultural landscapes (historical landscapes)

Natural heritage

Mixed sites

Cultural heritage

According to the Convention, cultural heritages are:

monuments (architectural, monumental pictorial, statuary and archeological items);

(building)ensembles (coherent or separated buildings);

sites (man-made or the interaction of mankind and nature)

which correspond to the criterion of the historical authenticity, and to at least one of the six additional criteria.

National preservation of monuments

Monument (M)

Monumental value is, which is declared to be preserved by the law, according to the Act No. LXIV/2001.

Monumental value: each building, garden, cemetery or burial site (or their remains), and their intended coherent

ensemble, system, which – in terms of our country’s history and the community’s identity – is highly significant,

together with its historical, artistic, scientific and technical memories, components, accessories and furnitures.

Local preservation of monuments

The buildings of our architectural heritage, which are under the protection of the local government, are integral

parts of a national, multilevel preservation system. According to the Act No. LXXVIII/1997 on “The Built

Environment and its Conservation”, the Decree No. 66/1999. (VIII.13.) states, that the “local preservation

includes all the elements of the architectural heritage, which is not protected by specific legislation, and the

local government’s regulation declares it to be preserved as municipal, landscape, natural, architectural,



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ethnographic, fine- or applied artistic, industrial historical, archeological value”. The local preservation may

cover the “settlement and its surrounding or its coherent parts (local areal protection), and certain buildings, its

details (local individual protection)”.

The local preservation aims to preserve as better and more complete the valuable architectural, landscape and

built environment related to the natural characteristics of the settlement’s and its surrounding. The remaining

and protectable buildings, building ensembles represent historical as well as art historical significant value, at

the same time they are also important pillars of the self-determination of the community. Therefore their

preservation and proper utilization is economic, cultural and eventually settlement-political interest.

The large number of locally protected monuments defines the attributes of the typical characteristic of our

settlements, and the diversity of the local preservation’s memories requires professional, authentic renovation

and preservation. The basic condition for the preservation is – beyond the moral recognition – to maintain a

good technical condition, “the proper maintenance”, and the high quality of the prospective restoration, which is

occasionally inevitable.

Categories:

1. Protected real estates

1.1. monuments under national protection (protected by Ministerial Decree): the monuments are classified in

three categories according to the Annex of the Government Decree No. 191/2001 (X. 18.) on the fines of

heritage preservation.

1.2. monuments under local protection (protected by decree of the local government, settlement-wide

protection).

2. Unprotected historic buildings

Please give examples from the different categories.

1.1. Monuments with national preservation status:

Main Cathedral (monument reg. Number: 2350) – 1. Szent István square, Esztergom (parcel number 16240) –

1st category monument

Pálma Hotel (monument reg. Number: 10724) – Angolkert, Tata (parcel number 3306/7) – 2nd category

monument

Roman Catholic (Szent József) temple (monument reg. Number 2488) – Templom square, Dorog, (parcel

number 1157) – 3rd category monument

1.2 Monuments with local preservation status:

Residential building – 5. Széchenyi square, Esztergom (parcel number 17337)

8. b) How are historic environments categorized? Pl ease give examples from the different categories.

International preservation – World Heritage

Categories of World Heritage (Cultural, Natural)

Cultural and Natural heritage sites with outstanding significance and universal value can be registered to the

World Heritage list, which are uniquely meaningful not only for a specific country, but for the whole humanity.

The Convention includes those criteria, which are used to pronounce an environment as part of the World

Heritage. The criteria are categorized in two groups in the actual regulations, based on this, an environment is

either part of the category of the cultural- or the natural heritage in the list of World Heritage. In the first one, the

main criterion is historical authenticity, while in case of natural heritage the main criterion is integrity (untouched,

undamaged).



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Cultural heritage

Cultural landscapes (historical landscapes)

Natural heritage

Mixed sites

Cultural heritage

According to the Convention, cultural heritages are:

monuments (architectural, monumental pictorial, statuary and archeological items);

(building)ensembles (coherent or separated buildings);

sites (man-made or the interaction of mankind and nature)

which correspond to the criterion of the historical authenticity, and to at least one of the six additional criteria.

In the category of cultural heritage belong the so-called cultural landscapes (historical landscapes), which have

evolved through the interaction of mankind and nature – id est they are man-made, but they integrally interact

with the natural effects. Cultural landscapes fall into three main categories:

Clearly defined landscape designed and created inte ntionally by man. This embraces gardens and

parkland landscapes constructed for aesthetic reasons, which are often (but not always) associated with

religious or other monumental buildings and ensembles (e.g. the Palace and Park of Versailles).

Originally evolved landscape. This results from an initial social, economic, administrative, and/or religious

imperative and has developed its present form by association with and in response to its natural environment.

Such landscapes reflect that the process of evolution in their form and component features (e.g. the rice

terraces in Asia, and this includes our country’s three cultural landscapes: Hortobágy National Park – the

Puszta, Fertő / Neusiedlersee Cultural Landscape, Tokaj Wine Region Historic Cultural Landscape).

Associative cultural landscape. The inclusion of such landscapes on the World Heritage List is justifiable by

virtue of the powerful religious, artistic or cultural associations of the natural element rather than material

cultural evidence, which may be insignificant or even absent (Tongariro National Park in New-Zealand, which

has religious significance for the Maori).

Natural heritage

According to the Convention, natural heritages are:

Aesthetic or scientific point of view, extremely valuable physical and biological formations or groups of

formations;

Scientific or preservation point of view, extremely valuable geological and physiographic formations, precisely

defined areas, which are the places of production and living of the animal and plant species, which are

threatened of extinction;

Natural landscapes

which correspond to the criterion of integrity (untouched, undamaged), and to at least one of the four additional

criteria:

(vii) Extraordinary natural beauty and aesthetic importance of natural phenomena or areas;

(viii) An outstanding example in displaying the great geological period(s), including the traces of life’s

evolvement; significant and ongoing geological processes of the evolution of the earth’s surface, and significant

geomorphological or configuration phenomena;

(ix) An outstanding example of the ongoing ecological and biological processes – in the evolutionary

development of the terrestrial, aquatic, coastal and marine ecosystems, animal and plant associations;



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(x) Contains the most distinctive and significant natural habitats in the aspects of preserving the biological

diversity “in situ”, including the endangered species, which represent outstanding universal value in terms of

science and preservation.

National preservation of monuments

Historical gardens (such as monuments)

The historical garden attains historic or artistic value, independently or in connection with another monument,

and is a landscape architectural creation, green area or park, which appears as part of the historical settlement

structure; the highly significant historical garden can be declared as monument.

Conservation area

That part of the settlement is declared as conservation area, which has significant, historically developed

structure, and the overall picture, the relation to the landscape, the squares and streets, the buildings create a

coherent system – which is worth for protection – and expresses the architectural culture of the establishing

community, and which is declared to be preserved by the law.

Historic building environment

Properties directly adjacent to monuments or conservation areas, parts of the public place and properties

directly adjacent to parts of the public place – by virtue of law – are declared as historic building environment.

Regulation – declaring monuments or conservation areas – under specific conditions may designate differently

the historic building environment.

Historic sites

The historic sites – under monumental protection – are those partially built-up areas, which are culturally

(historical, monumental, artistic, scientific, technical, etc.) significant, as the result of the interaction of man and

nature. By their characteristics and uniformity, they form a topographically definable unit, and are declared to

be preserved by the law.

Local preservation of monuments

The buildings of our architectural heritage, which are under the protection of the local government, are integral

parts of a national, multilevel preservation system. According to the Act No. LXXVIII/1997 on “The Built

Environment and its Conservation”, the Decree No. 66/1999. (VIII.13.) states, that the “local preservation

includes all the elements of the architectural heritage, which is not protected by specific legislation, and the

local government’s regulation declares it to be preserved as municipal, landscape, natural, architectural,

ethnographic, fine- or applied artistic, industrial historical, archeological value”. The local preservation may

cover the “settlement and its surrounding or its coherent parts (local areal protection), and certain buildings, its

details (local individual protection)”.

The local preservation aims to preserve as better and more complete the valuable architectural, landscape and

built environment related to the natural characteristics of the settlement’s and its surrounding. The remaining

and protectable buildings, building ensembles represent historical as well as art historical significant value, at

the same time they are also important pillars of the self-determination of the community. Therefore their

preservation and proper utilization is economic, cultural and eventually settlement-political interest.

The large number of locally protected monuments defines the attributes of the typical characteristic of our

settlements, and the diversity of the local preservation’s memories requires professional, authentic renovation

and preservation. The basic condition for the preservation is – beyond the moral recognition – to maintain a



EFFESUS • 314678 • of 262

good technical condition, “the proper maintenance”, and the high quality of the prospective restoration, which is

occasionally inevitable.

9. a) How is national legislation influenced by EPB D?

The national legislature is prepared in accordance with the EPBD, is based on that.

9. b) Please state any other international charters , conventions or principles that have relevance for

national legislation regarding energy performance i n historic buildings or historic environments.

There isn't any.

10. Describe the national legal requirements for mi nimum energy performance in existing buildings and

built environments.

Currently there aren’t any, only for the government-owned buildings.

From the 9th of July, 2013 (§6 of Decree of Minister without Portfolio No. 7/2006 (V. 24.))

By renovation of existing buildings, for energy saving purposes, the building components involved in the

construction and assembly works shall comply with the requirements for the newly built building components.

By enlargement of existing buildings, if the extension does not exceed the 100 % of the original building’s

useful area, the new partition structures must comply with the requirements of the Annex I and V.

Existing building’s extension bigger than determined in (2), or in case its significant renovation, the

requirements for new buildings shall be applied.

Before major renovation of an existing building, the application of alternative systems and the economic

feasibility must be examined and documented, as determined.

11. a) In what ways are historic building and histo ric environments excluded from or included in the

minimum energy performance requirements for existin g buildings? Can you please give examples?

i. The building or the built environment is preserved by the law.

In this case, it’s not necessary to fulfill the building’s energetic standards.

ii. The building or the built environment is not preserved by the law.

1. In case of smaller than “significant renovation” is not necessary to fulfill the building’s energetic standards.

2. In case of “significant renovation” the building’s energetic standards must be fulfilled.

11. b) If some historic buildings and historic envi ronments are excluded from the requirements, what i s

the most common reason? Can you please give example s?

The most common reason is that the historic building or the historic environment are under some kind of

protection (e.g. under local preservation).

12. Describe the national legal methodology for the calculation of the minimum energy performance of

buildings.


13. Is life cycle assessment (LCA) a part of the ev aluation of the energy performance in buildings?

No.

14. In these questions we would like to know in whi ch situations the requirements for minimum energy

performance in buildings would come into force:

a) How is “major renovation” defined in national le gislation and will minimum energy performance

requirements in buildings come into force when it i s applied for “major renovation”? Please explain.



EFFESUS • 314678 • of 262

“Major renovation”: renovation, which affects at least 25 % of building envelope. In case of major renovation,

the minimum energy performance requirements are valid. §2 of Decree Minister without Portfolio No. 7/2006. (V.

24.)

Another interesting definition:

“Major extension”: if the extension does not exceed the 100 % of the original building’s useful area. In case of

major extension, the minimum energy performance requirements are valid for the whole building. §6 of Decree

of Minister without Portfolio No. 7/2006. (V. 24.)

b) Will minimum energy performance requirements in buildings come into force when the use/function

of a building is changed? Please explain.

The value of the overall energy performance shall be determined according to the function of the building. The

regulation distinguishes the followings: residential building, office, educational and other type of building. If the

building falls into one of the categories of question 14/a, then by the determination of the requirements the new

function shall be taken into consideration, if that falls into other group according to the classification above. §4

of Decree of Minister without Portfolio No. 7/2006. (V. 24.)

c) Please describe other situations when minimum en ergy performance requirements will come into

force?

In case of major renovation and major extension (see question 14/a)

§6 of Decree of Minister without Portfolio No. 7/2006 (V. 24.)

State-owned, public-used building, with larger than 1000 m2 of useful floor area:

I. By renovation for energy saving purposes, only the involved building components.

§6 of Decree of Minister without Portfolio 7/2006 (V. 24.)

II. By minor extension, only the new bordering structures


As previously stated, the protected historic buildings (urban areas) are exceptions of the cases above. The

cited regulation defines further exceptions, from these the followings are relevant to EFFESUS: religious

buildings, agricultural and industrial buildings.


15. After renovation or other situations (see quest ion 14), how can the authorities control whether th e

legal requirements for minimum energy performance a ctually are met?

The relevant building’s energy performance calculation is part of the building’s authorization plan (its

preparation: see earlier). This may be checked by the construction authority. The calculation must be carried

out in cases falling under the regulation (see question 14)

16. Are minimum energy performance requirements lim ited only to the renovated parts or to the whole

building?

See the answer of the question 14/c.

17. In what ways are the national legal requirement s for minimum energy performance (in historic

buildings and historic environments) stimulated?

Through:

a) direct subsidies / funding? YES – with the help of competitions

b) advantages / disadvantages through taxation? YES – reduction of corporate tax base (§7 of Act No.

LXXXI/1997) and exemption from local taxation (§13/a of Act No. C/1990)



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c) attractive financing? NO

d) information? NO

e) energy performance certificate? YES – it is obligatory to have an energy performance certificate in case of

selling or renting out an existing building or construction of a new building.

f) technical assistance and advice? NO

Other? Please explain: NO

18. Are there or can there be applied a requirement for competency or experience when working with

historic buildings and energy efficiency?

Only senior architect can design protected historic building. Among the entitlements of the engineers, there is a

branch relating to the preservation of monuments, both for architects and structural engineers (e.g. engineer of

historical preservation). These may be required in specific phases of the work.

19. Please give examples of conflicts and solutions to implementing (different) energy efficient

measures and their compatibility with heritage prot ection legislation.

As stated earlier, the protected monuments are exceptions from the building’s energy performance

requirements.

The Government Decree No. 176/2008. (VI. 30.) on the certification of the energy performance of buildings

does not apply to protected buildings (monuments, buildings under local protection) and sites (conservation

area, historic building environment, local protected area).

Using insulating plastering, instead of thermal insulation board,

Repair of windows and LOW-E glazing, instead of window-replacement,

Instead of window-replacement, insulating glazing of inner sash,

Upper insulation of the topmost slab,

Thermal insulation is not enough, care must be taken to the waterproofing and humidity.

20. Please give any further comments or suggestions .

In question 14, the cited Decree's (Decree of Minister without Portfolio No.7/2006 (V. 24)) next stage is entering

in force at 9th of July, 2013. The relevant and interesting parts – from the point of view of the questions above

and the EFFESUS project – are:

The floor area of the building, and the facts that it is state-owned and public-used are not aspects anymore by

the determination of the building’s energy performance. According to this, the cases listed in 14/c apply to all of

the existing buildings.

The exceptions – see 14/c – do not change. The building’s energy performance requirements still do not apply

to the protected monuments.



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QUESTIONNAIRE

BACKGROUND DATA.

1. Please sta te the name of the country.




ITALY



The D.Lgs.n.42 / 2004 defines that the local superintendence of the Italian provinces

protects the cultural heritage. This means that the superintendence lists all the buildings

subjected to specific restrictions because of their historical or cultural value. For every

intervention on listed buildings the superintendence has to give an authorization.

The director of State Office for the Preservation of Historical Monuments determines the

objects of particular artistic, historical, archaeological or ethnological value, which must

be placed under monument protection.

The owner of the object is informed about the proposal for giving protection to his object.

Until the decision of the state government, which must be made within 180 days from the

proposal, the proposed object has to be considered as protected building.

Within 30 days from the proposal, the owner has the opportunity to submit statements

and objections. After this the state government decides on the conservation bond for the

proposed heritage.

Article 5 com 2 of Italian law d.lgs. 85/2010 foresees the allocation of heritage portfolio to

municipalities and regions.

Within the XVI legislation, the law D.L. 34/2011 has foreseen financing intervention for

the protection and maintenance of cultural heritage since 2011.


a) national level in charge of the global protection of the heritage portfolio

b) regional level in charge of the valorisation of the heritage portfolio

c) local level

d) other

The heritage portfolio in Italy encompasses:

More than 3400 museums

2100 archaeological parks

43 UNESCO sites

3. Explain how the authorities which regulate ene rgy performance in buildings


The first national Italian legislation on minimum energy requirements for buildings and

systems is the Legge 10/91. This legislation defines how to design and to regulate the



EFFESUS • 314678 • of 262

building systems at a national level.

The European directives were then introduced into t he national legislation as

follow:

The 2002/91/CE was introduced in Italy thought:

D. Lgs 192/2005 application of 2002/91/CE

D. Lgs 311/2006 additional and update disposition

DPR 59/09 application of 192/2005

The 2006/32/CE was introduced in Italy thought:

D. Lgs. n. 115 30 May 2008 has assigned the function of National agency for Energy

efficiency to ENEA

The 2009/28/CE (renewable energies) was introduced in Italy thought:-

D.Lgs. 28- 3 March 2011

The 2010/31/UE was introduced in Italy thought:

Dlgs 28/2011, the achievement of target defined are under the responsibilities of regions

and autonomous provinces as reported within the law: DM 2010 20 September.


national level

At a national level the energy requirements of the below listed laws have to be reach.

b) regional level

c) local level

At a regional and local level the administration can improve the energy requirements to

higher standards. At a local level many types of different certification have been

developed both for new or existing retrofitted buildings.

Any examples of local energy certifications are:

CENED (Lombardia), KlimaHaus (Alto Adige/Südtirol), LEED (Trentino)

d) other



At a national level, there is not direct mandatory cooperation between the energy

management and the heritage management.

The local superintendence for cultural heritage has to evaluate each intervention on

historic listed buildings. Only with the approval of the local superintendence is possible to

do a retrofit action.

Listed buildings are not subjected to any energy standards (DPR 59/09 art1). However,

some regional legislations are trying to improve this cooperation trough mandatory

energy certification for retrofit interventions on existing and historic buildings.


In the region Alto-Adige/Südtirol the KlimaHaus agency developed the certification

KlimaHaus R. This certification defines the minimum energy standards to achieve after

the retrofit starting from the existing building.



EFFESUS • 314678 • of 262

5. Please describe the na tional political goals for reducing emissions (CO2 ) and



The Italian national goals within the 2020 are the reduction of the 13% of Co2 emissions

and the production of the 17% of energy with renewable energies sources. (ENEA)

The national legislations promotes the retrofit of existing buildings mainly through

economic advantages. The law 244/2007 establishes a contribution of tax reduction of

the 55% for the energy retrofit interventions. Examples of interventions are the external

insulation, the substitution of old windows and old non heating systems.

6. Please describe how the goals in question 5 are proposed to be achi eved.

The technical requirements to reach the goals are described in the receptive Italian of the

EPBD legislation, the technical legislations UNI TS 11300/1-2-3-4 (see answer 9).


DIRECTIVES (EPBD)49

7. a) Describe the n ational and regional


buildings.

Listed buildings: Situation in South

Tyrol/Italy: Based on the national Italian

law, the “Codice dei beni culturali e del

paesaggio” (Decreto legislativo 22 gennaio

2004, n.42), buildings are protected by

decision of the provincial government. The

protection status is registered in the land

register. Any change of the appearance of

the building has to be approved by the

State Office for Preservation.

Further information, source:

http://www.provinz.bz.it/denkmalpflege/



environments.

Surrounding of listed buildings “indirect

protection”:

The “Denkmal-Bannzone” includes the

surrounding/the context of the listed

building: The State Office for the

Preservation of Historical Monuments has

the right to declare the surrounding area/the

context of the listed building into a so called

“ban zone”. The State Office exercises this

right not in every case of a listed building

but in some outstanding cases, for example

the surroundings of a cathedral, also

because of administrative effort. Within this

zone buildings are indirect protected

(according to article 45-52, see also below)

that means in case of a refurbishment

project guidelines with regard the outside

appearance has to be complied. The

project has to be approved by the State

Office for Preservation.

49

Directive 2010/31/EU OF THE EUROPEAN PARLIAMENT AND CONCIL of 19 May 2010 on the energy performance of buildings (recast)



EFFESUS • 314678 • of 262

Generally in the neighbourhood of a listed

building the State Office for the

Preservation of Historical Monuments has

influence in a limited way, in the sense of

article 45-52 “indirect protection” of the

Italian Heritage Act (see law mentioned

above “Codice dei beni culturali e del

paessagio” -> “Tutela indiretta/Indirekter

Schutz”). On the base of this law,

construction bans or restrictions can be

prescribed with regards the outside

appearance of the building: the height or

the spacing in the vicinity of monuments.

However, these measures are made often

ad hoc, that means only in case of

reasonable danger to the monument.

In case of a refurbishment project of

neighbourhood buildings the State Office is

not informed automatically, it depends very

much on the self-interest of building owner

and planners or the building authorities or if

the State Office informs itself.

Art. 45 : Rules for indirect protection:

“The ministry is empowered to prescribe the

distances and dimensions and to enact

further regulations in order to avoid that the

integrity of immovable cultural objects is

compromised, that the incidence of light will

be affected or that the décor and

environment conditions are changed.”


http://www.provinz.bz.it/denkmalpflege/

Protection of ensembles

(„Ensembleschutz“)

In comparison to listed buildings the

“protection of ensembles” includes more

than the individual building like construction

volume, outside appearance, courts, open

spaces, streets. In this way it is also a tool

for urban development.

Ensembles are not individual objects but an



EFFESUS • 314678 • of 262

interplay of several objects, which reflect

the history and the interaction of human

and nature and which contribute with their

individuality to local and regional identity.

The State Spatial Planning Law defines

ensembles as ““Gesamtanlagen” in

particular streets, squares, townscapes and

parks, together with buildings, including the

related plants and water areas and open

spaces, whose preservation is of special

public interest for scientific, artistic or native

historical reasons.”

In contrast to the preservation of

monuments the “protection of ensembles” is

initiated and implemented by the

municipalities. According to the Spatial

Planning Act (provincial act of the 11th

august 1997, no. 13 I) the “protection of

ensembles” is located on the municipality

level. It is thus task of the municipality to

implement the protection in its district. The

Spatial Planning Act commits the

municipalities to create a list of protected

properties, together with appropriate

conservation measures and to protect these

ensembles legally effective by registration

of the buildings in the land use plan of the

municipality. The state established a board

of advisors (consisting of one person from

the department for spatial development, the

department for preservation of monuments

and the departments for nature and

landscape) for the protection of ensembles,

which has an advisory function. It supports

the municipalities in technical matters. The

designation of the ensembles is however

task of the municipality. The municipality

has therefore also the responsibility for the

maintenance of cultural identity and local

character.




EFFESUS • 314678 • of 262

http://www.provincia.bz.it/ensembleschutz/i

ndex_d.asp


categorized? 50

Selection criteria (according to article 10 of

the law mentioned above): “Object of

protection

Are immovable or movable objects of

artistic, historic, archeological or

ethnographic and ethnological interest

(para. 1)

Are immovable or movable objects, which

are of particular great interest because they

are connected with the history of politics,

military, literature, art, science, technics,

commerce or culture or because they bear

witness to identity and history of the public,

the community or the religious institutions

(para. 3 a)”

As a prerequisite to become a listed

building the object has to be at least 50

years old and may not be the work of a

living artist/architect.

The preservation of monuments covers

outstanding buildings (examples). Where

historic buildings are protected, they have a

role model for other similar buildings.


categories.

Examples:

Buildings which are not necessarily of

architectural, artistic value, but testimony of

an historical event: e. g. the wall in Berlin

Buildings which have their significance from

history relating to a person: e. g. composer

How are historic environments

categorized?

To implement the protection of ensembles

ten criteria were stated for the

establishment of ensembles. An ensemble

is protected as such, when it applies to at

least two of these criteria: 1. Historic value;

2. Picturesque character; 3. Monumentality

of the buildings to each other and to the

landscape; 4. Stylistic characterization

(uniform style or consciously mixing of

different styles; 5. Appearance

(recognisability, conspicuity, landmark); 6.

Panorama (distant views, perspective views

and elevation); 7. Collective memory; 8.

Continuation of the urban system

(recognitions of a plan or a founding act

determined by the settlement morphology);

9. Continuation of the construction typology;

10. Natural characteristics, geomorphology

and natural character.


categories.

1. Historic value: Monastery Neustift (South

Tyrol)

2. Picturesque character: Weiler Seres

(Gader valley)

3. Monumentality of the buildings to each

other and to the landscape: Monastery

Säben

4. Stylistic characterization (uniform style or

consciously mixing of different styles:

City center of Sterzing

50

For instance:







EFFESUS • 314678 • of 262

cottage from Gustav Mahler (small wooden

cottage)

Buildings of ethnographic, technical,

religious significance: cathedrals, but also

residential buildings of every social class

and epoch such as farms with barns etc.

Buildings of architectural value,

representing a certain epoch: e. g. row

house of the 1920th

5. Appearance (recognisability, conspicuity,

landmark): hydroelectric power station

Kardaun

6. Panorama (distant views, perspective

views and elevation): Castelfeder

(Neumarkt)

7. Collective memory: Glurns

8. Continuation of the urban system

(recognitions of a plan or a founding act

determined by the settlement morphology):

historic city center of Meran

9. Continuation of the construction typology:

Bruneck

10. Natural characteristics, geomorphology

and natural character: wine terraces

(Kortsch)

See all examples with pictures under the

following link:

http://www.provincia.bz.it/ensembleschutz/a

usweisungskriterien.asp

9.

a) How is national legislation influenced by EPBD?

The national legislation applies the EPBD trough the DPR 59/2009. This law defines the

minimum energy requirements for buildings. The methodology to calculate if the

requirements are achieved is the technical legislation UNI TS 11300.

The UNITS 11300-1 describes the methods to calculate the heating and cooling demand

The UNITS 11300-2 defines the efficiency of hot water and heating systems

The UNITS 11300-3 defines the efficiency of the cooling systems

The UNITS 11300-3 defines how to use renewable energies in buildings

At a regional level, the minimum requirements are defined in the energy certification

standards.




10. Describe the national legal requirements for minimum energy performance in


Existing buildings subjected to the renovation of the whole envelope have the same

requirements of new buildings. For the envelope and for the systems they must respect

the minimal levels described in the DPR 59/09.

For the renewable energies they have to respect the D.Lgs. 28- 3 March 2011. This law

introduces the mandatory use of the Renewable energies for major renovation



EFFESUS • 314678 • of 262

interventions in existing buildings with a surface > 1000 m2.

For new and major renovated buildings, Renewable Energies have to provide the 50 % for

hot water and from 20% to 50% of the energy request for the heating and cooling systems

(depending on the time of the construction approval). If the building is connected to district

heating this legislation is not applied. The regional legislation can improve these minimum

percentages. For public buildings these limits are 10% higher.




Listed buildings are not compulsorily subjected to any energy standards (DPR 59/09 art1).

Historic not listed buildings the same requirements of energetic performance as the new

buildings. For interventions of major renovation, they have the same requirements as the

new buildings in terms of energy performances. For interventions of minor renovation,

such as partial substitution of the external walls or partial substitution of the roof, the

energy performances are required only for the new components as a transmittance limits.



The most common reason is that the designed energy retrofit interventions often damage

the aspect of historic buildings. Therefore, the superintendence for cultural heritage does

not approve the energy retrofit solutions.

12.



The UNITS 11300 define the methodology for the calculation of the minimum energy

performances (for further information see question 09).

13.


buildings?

Actually LCA is not a mandatory part of the evaluation of the energy performances of

buildings.






Major renovation is defined as a refurbishment of the external walls of the building, of the

external plaster, of the roof, and of the roof´s water tightness.

Whenever there is a major renovation for buildings with a surface >1000 m2 the building

51







EFFESUS • 314678 • of 262

has to meet the energy requirements at national and regional level. The requirements are

the same as those for new buildings.



Whenever the use-change is connected to a renovation, the building has to meet the

energy requirements at national and regional level.



Whenever there is a partial renovation of the envelope, the new parts must reach the

energy requirements.



are met?

There is no control after the construction of the buildings. During the construction, the

0,4% of the certification is controlled on a national level and each certification is controlled

on a local level in Alto Adige/Südtirol.



In case of major renovation the minimum energy performances are required for the whole

building. In case of partial renovation of the external walls or of the roof, the energy

performances are required only for the new parts as transmittance limits. In case of

renovation of the systems, the seasonal efficiency must meet the requirements.

(DPR 59/09)

17. In what ways are the n ational legal requirements for minimum energy perfo rmance


Through:



funding?

X

b) advantages /


taxation?

X Tax reduction:

The D.M 26/01/2010 ( and following

updates as the 13/12/2010 n.220 and

d.lgs201/) defines for the retrofit of existing

buildings a tax reduction at the 55%

(maximum limit is 96.000 euros). The

retrofit interventions must respect the

energy efficiency limits established in the

legislation.



EFFESUS • 314678 • of 262


d) information?


certificate? 55

X Existing buildings under renovation must be

certified. For historic listed buildings the

energy certification is not mandatory and all

interventions have to be approved by the

local superintendence for cultural heritage.


advice?




There is no requirement for specific competency when working on historic buildings.



Solutions to be avoided during the retrofit because of their impact are:

Use of external insulation

Use of internal insulation for painted walls

Intervention of super elevation of the roof

Reversible solutions instead on irreversible solutions are always preferable.



Name: Francesca Roberti, Dagmar Exner

Affiliations: EURAC

Affiliations: D´APOLLONIA



55




EFFESUS • 314678 • of 262

QUESTIONNAIRE

BACKGROUND DATA.





Republic of Ireland (ROI), excluding Northern Ireland (NI), which applies and adopts UK

legislation.

Comparison between ROI and NI could be researched if appropriate and useful for WT

1.3 (to be discussed and decided upon)




a) national level (NUTS I)

The following two ministerial departments are responsible for the administration,

recording, survey, conservation and preservation of Irish built heritage including any

associated works:

- The Department of Arts, Heritage and the Gaeltacht (DAHG) is the governing national

authority for built and natural heritage in Ireland. www.ahg.gov.ie/en/Heritage

- The Department of Environment, Community and Local Government (DECLG) used to,

until 2011, comprise the resort “Heritage” as Department of Environment, Heritage and

Local Government (DEHLG). Through existing pre 2011 legislation and the remaining

responsibilities for Planning/Development, DECLG keeps its remit for limited elements of

Irish built heritage. www.environ.ie/en/

The main national legislation for built heritage is the Heritage Act 1995, applying the

following definition:

“architectural heritage includes all structures, buildings, traditional and designed, and

groups of buildings including street-scapes and urban vistas, which are of historical,

archaeological, artistic, engineering, scientific, social or technical interest, together with

their setting, attendant grounds, fixtures, fittings and contents, and, without prejudice to

the generality of the foregoing, includes railways and related buildings and structures and

any place comprising the remains or traces of any such railway, building or structure”

(DAHG 1995)

Of further statutory importance are the Architectural Heritage (National Inventory) and

Historic Monuments (Miscellaneous Provisions) Act 1999 and the Planning and

Development Act 2000.

The following three government authorities are operating at a national level under the

remit of the DAHG:



EFFESUS • 314678 • of 262

- The National Monuments Service (NMS) administers the Archaeological Survey of

Ireland, which contains the Record of Monuments and Places (RMP) for each of the 26

Counties. www.archaeology.ie/ArchaeologicalSurveyofIreland/

- The National Inventory of Architectural Heritage (NIAH) comprises surveys for each of

the 26 Counties for buildings, which are classified as architectural heritage.

www.buildingsofireland.ie/

- The Heritage Council, established under the Heritage Act, is putting in place practical

programmes for infrastructure and networks to conserve heritage throughout

communities. www.heritagecouncil.ie/about-us/about-us/

b) regional level (NUTS II + NUTS III)

Due to the country’s relatively small size and population (4.6million 2011), Ireland’s 8

regional authorities only coordinate EU structural funds for the local authorities while

advising, supporting and monitoring these with regard to built heritage activities.

c) local level (LAU-1, former NUTS IV)

Each of the 26 Counties has established their Heritage Office, which in coordination with

The Heritage Council record and administer the Counties’ built heritage. Each County

Development Plan, which is valid for a five-year period, comprises a detailed Record of

Protected Structures (RPS) and a detailed list of Architectural Conservation Areas (ACA).

It is noted that local built heritage records of the Counties do not entirely correspond with

national records, administered by the NIAH. Counties have recorded structures, which

the NIAH have not listed whereas the NIAH keep records of structures which are not

listed in local records. According to the NIAH, the national authorities are in the process

to rectify this discrepancy in the coming years.

d) other

n/a




a) national level (NUTS I)

The following two ministerial departments are responsible for the guidance,

administration and regulation of energy performance and fuel efficiency in buildings:

- The Department of Environment, Community and Local Government (DECLG), through

its relevant regulations, governs and implements energy efficiency in buildings. These

are: S.I. No.243 of 2012 European Union (Energy Performance of Buildings) Regulations

2012, which transposes EU Directive 2010/31/EU (EPBD); S.I. No.259 of 2011 Building

Regulations (Part L Amendment) Regulations 2011, which regulates conservation of fuel

in buildings; and S.I. No.235 of 2008 Planning and Development Regulations 2008,

which regulates micro-renewable energy technologies in the domestic, industrial,



EFFESUS • 314678 • of 262

business and agricultural sector.

www.environ.ie/en/DevelopmentHousing/PlanningDevelopment/Planning/

-The Department of Communications, Energy and Natural Resources (DCENR) are

marginally involved in buildings’ energy efficiency through The National Energy Efficiency

Action Plan 2009-2020 and S.I. No.542 of 2009 European Communities (Energy End-use

Efficiency and Energy Services) Regulations 2009. www.dcenr.gov.ie/Energy/

The following government authority is operating at a national level under the remit of the

DECLG:

- The Sustainable Energy Authority Ireland (SEAI) is the leading national body to promote

sustainable energy structures, technologies and practices. It advises and develops

programmes to improve Ireland’s energy efficiency in buildings. SEAI has established a

Dwellings Energy Assessment Procedure (DEAP) to facilitate Building Energy Ratings

(BER) for all newly built and existing structures, which undergo refurbishment/retrofitting

and/or change of tenure or ownership. www.seai.ie/Your_Building/EPBD/

The requirements for energy efficiency and conservation in buildings are laid out in the

Technical Guidance Documents L: Conservation of Fuel and Energy, Dwellings

www.environ.ie/en/Publications/DevelopmentandHousing/BuildingStandards/FileDownLo

ad,27316,en.pdf; and Technical and Guidance Documents L: Conservation of Fuel and

Energy, Buildings other than Dwellings.

www.environ.ie/en/Publications/DevelopmentandHousing/BuildingStandards/FileDownLo

ad,20322,en.pdf

b) regional level (NUTS II + NUTS III)

Due to the country’s relatively small size and population (4.6million 2011), Ireland’s 8

regional authorities only coordinate EU structural funds for the local authorities while

advising, supporting and monitoring these with regard to energy efficiency activities.

c) local level (LAU-1, former NUTS IV)

County and City Councils’ Planning Departments as local authorities have the

responsibility to assess and authorise development regarding its energy efficiency and

compliance with the abovementioned regulations and technical guidance documents.

d) other

n/a



Planning and Development Act 2000

Technical Guidance Document L, Conservation of Fuel and Energy, Dwellings (DECLG

2011) and Technical Guidance Document L, Conservation of Fuel and Energy, Buildings

other than Dwellings (DEHLG 2008) note that buildings under heritage protection are

exempt from compliance with energy conservation and performance requirements.

Furthermore, it is acknowledged that the application of energy conservation technology

might be inappropriate for particular existing buildings of histories or architectural value,

regardless their heritage protection status.



EFFESUS • 314678 • of 262

The government policy Energy Efficiency in Traditional Buildings (DEHLG 2010) refers to

the EU Directive 2010/31/EU (EPBD) and serves as a guidance for authorities,

practitioners and owners alike to improve energy efficiency of traditional buildings while

maintaining their architectural character and significance.


The actual cooperation between and integration of the agendas of energy efficiency and

conservation for proposed development on traditional structures is facilitated at local

authority level in the individual County and City Councils. It is the responsibility of the

appointed planning officer and appointed heritage officer within the council to jointly

advise and decide upon any building works to architectural heritage, which require

authorisation under the valid Building Regulations. Planning applications that include

material works to a Protected Structure, as listed in the county’s Record of Protected

Structures (RPS) require the preparation of an authorised Conservation Report, to

accompany the regular planning documentation.

The use of one case study would remain too specific and would therefore not be

representative enough to illustrate how energy efficiency and conservation have been

married in a traditional building. According to the abovementioned government policy

Energy Efficiency in Traditional Buildings a “traditional building” until the mid 20th century

is generally built of solid masonry walls of brick and/or stone, often with a render finish,

with single-glazed timber or metal windows and a timber-framed roof, usually clad with

slate but often with tiles, copper or lead. A selection of principal measures to traditional

buildings would convey a standard approach, such as the use of lime-based mortar and

render to reinstate a breathable and dryer envelope, draught-proofing and the

reinstatement of original shutters to existing windows, chimney dampers, internal roof

insulation and an energy efficient boiler.

These measures would, within the constraints of conservation, considerably improve the

energy performance of a traditional building.

The following paragraphs from the Building Regulations 2011, Technical Guidance

Document, Part L: Conservation of Fuel and Energy – Dwellings indicate the limitations

of energy efficiency measures to historic buildings, with or without protection status:

“0.6 APPLICATION TO BUILDINGS OF ARCHITECTURAL OR HISTORICAL

INTEREST

0.6.1 Part L does not apply to works (including extensions) to an existing building which

is a “protected structure” or a “proposed protected structure” within the meaning of the

Planning and Development Act 2000 (No. 30 of 2000).

0.6.2 Nevertheless, the application of this Part may pose particular difficulties for

habitable buildings, which, although not protected structures or proposed protected

structures, may be of architectural or historical interest.

0.6.3 Works such as the replacement of doors, windows and rooflights, the provision of

internal and/or external insulation and damp-proofing to walls and basements, insulation

to the underside of slating and provision of roof vents and ducting of pipework could all



EFFESUS • 314678 • of 262

affect the character of the structure.

0.6.4 In general, the type of works described above should be carefully assessed for their

material and visual impact on the structure.

0.6.5 Historical windows and doors should be repaired rather than replaced, and internal

insulation and damp-proofing should not disrupt or damage historic plasterwork or

flagstones and should not introduce further moisture into the structure.

0.6.6 Roof insulation should be achieved without damage to slating (either during the

works or from erosion due to condensation) and obtrusive vents should not affect the

character of the roof.

0.6.7 In specific cases, relaxation of the values proposed may be acceptable, to the local

building control authority, if it can be shown to be necessary in order to preserve the

architectural and historical integrity of the particular building.”

5. Please describe t he national political goals for reducing emissions (CO2) and



- Energy Efficiency in Traditional Buildings is a 2010 government policy document, which

provides guidance to authorities, planners and proprietors about marrying energy

efficiency measures with conservation requirements.

The following documents are the main national policy and regulations for energy

efficiency and resulting GHG reductions. They do not explicitly dwell on solutions for built

heritage:

-Delivering a Sustainable Energy Future for Ireland: The Energy Policy Framework 2007-

2020.

This government policy, issued 2007 by the Department of Communications, Marine and

Natural Resources, provides general information why and how our energy use is to be

made more efficiently and gives guidance to conserve energy through better technology

and behavioural change while shifting from fossil energy sources to the use of energy

from renewable sources in order to reduce CO2 emissions.

- Maximising Ireland’s Energy Efficiency: National Energy Efficiency Action Plan 2009-

2020.

This government policy, issued 2009 by the Department of Communications, Energy and

Natural Resources, build upon the before mentioned policy and states the country’s

commitment to a 20% reduction in energy use until 2020 with the public sector trying to

achieve 33%. A national Roadmap to Energy Savings prescribes various measures to

improve energy conservation across the residential, commercial and transport sector.

- Energy Performance in Buildings Directive (EPBD) Regulations 2012. This legislation

transposes the EU Directive into Irish law and provides the framework for all energy

efficiency measures at authority and planning level.


- Implementing and enforcing updated Building Regulations for residential and non-



EFFESUS • 314678 • of 262

residential structures.

- Greener and Warmer Homes Schemes to promote energy efficiency and conservation

with financial incentives and widespread information.

- Introducing a Dwelling Energy Assessment Procedure (DEAP) to facilitate Building

Energy Ratings (BER) for residential and non-residential buildings.

- Setting Energy Demand Reduction Targets.

- Multi-annual National Insulation Programme

- Home Energy Saving Scheme


DIRECTIVES (EPBD)56



buildings.

Covered in Quest ion 2

At national level, historic buildings are

protected by the following three acts:

- Heritage Act 1995

- Architectural Heritage (National Inventory)

and Historic Monuments (Miscellaneous

Provisions) Act 1999

- Planning and Development Act 2000

In addition, the government policy

Architectural Heritage Protection:

Guidelines for Planning Authorities 2011

serves as guidance for local authorities to

administer built heritage.

The county authorities represent the local

level. County Development Plans (CDP)

provide protection for historic buildings

through their Records of Protected

Structures (RPS). These list all buildings

within a county, which the county heritage

departments declare protected or propose

to protect it.

b) Describe the n ational and regional


environments.


The same legislation applies to historic

environments than to historic buildings.

Furthermore, the Regional Planning

Guidelines (RPG) for a total of eight regions

provide guidance at regional level while the

local authorities in the 26 counties remain

the decision makers.

County Development Plans (CDP) declare

specific parts of their jurisdiction as

Architectural Conservation Areas (ACA). An

ACA consists of a variety of buildings,

which are not necessarily individual

protected structures. The protection status

applies to the historic area, character,

architecture and ensemble quality rather

than individual buildings and their features.

(Extends to protection of historic

landscapes, landscape character and visual

amenities)

56




EFFESUS • 314678 • of 262


categorized? 57


- National Inventory of Architectural

Heritage (NIAH) at national level.

- Record of Protected Structures (RPS) as

part of each local authority’s City or County

Development Plan.

As previously mentioned, the national and

local registers are not coherent and do not

yet inform one another.


categories.

Whereas the NIAH lists a total of 32

structures of architectural heritage for the

town of Malahide, County Fingal, the Fingal

County Development Plan comprises a total

of 71 protected structures within the town of

Malahide


categorized? 58

No differentiation to a)


categories.

No differentiation to a)


The EPBD, Directive 2002/91/EC was transposed into Irish legislation in 2006 through the

European Communities (Energy Performance of Buildings) Regulations. The amending

Directive 2010/31/EU has been transposed into Irish legislation in 2012 through the

respectively amending European Union (Energy Performance of Buildings) Regulation

2012.

Furthermore, the Building Regulations 2008, Technical Guidance Document L,

Conservation of Fuel and Energy, Buildings other than Dwellings and the Building

Regulations 2011, Technical Guidance Document L, Conservation of Fuel and Energy,

Dwellings have adopted the EPBD requirements for Dwelling Energy Assessment

Procedure (DEAP), Non Domestic Energy Assessment Procedure (NEAP) and Building

Energy Rating (BER).

57

For instance:




- buildings of national, regional or local interest 58

For instance:







EFFESUS • 314678 • of 262




The National Inventory of Architectural Heritage (NIAH) liaises with the International

Centre for the Study of the Preservation and Restoration of Cultural Property, the

International Council on Monuments and Sites, Europa Nostra and the Irish Georgian

Society. An explicit reference to the aspect of energy performance is not stated.



The Building Regulations, Part L, Conservation of Fuel and Energy, shall be complied with

in existing buildings, dwellings and non-dwellings, by:

Fabric insulation. Providing reasonable levels of fabric insulation in all new construction,

including the limitation of thermal bridging including, where provided, replacement

windows and doors;

Air tightness. Limiting air infiltration through the newly constructed elements as far as

practicable;

Boiler efficiency. Providing an efficient boiler or other heat source;

Building Services Controls. Where new space and/or water heating services are provided,

controlling, as appropriate, the demand for, and output of, these space heating and hot

water services.

Insulation of pipes, ducts and vessels. Limiting the heat loss from pipes, ducts and vessels

used for the transport or storage of heated water or air.




The following extract from the Building Regulations, Part L provides a comprehensive

summary:

“APPLICATION TO BUILDINGS OF ARCHITECTURAL OR HISTORICAL INTEREST

Part L does not apply to works (including extensions) to an existing building which is a

“protected structure” or a ‘proposed protected structure” within the meaning of the

Planning and Development Act 2000 (No 30 of 2000).

Nevertheless, the application of this Part may pose particular difficulties for buildings

which, although not protected structures or proposed protected structures may be of

architectural or historical interest.

Works such as the replacement of doors, windows and rooflights, the provision of

insulated dry lining and damp-proofing to walls and basements, insulation to the underside

of slating and provision of roof vents and ducting of pipework could all affect the character

of the structure.

In general, the type of works described above should be carefully assessed for their

59




EFFESUS • 314678 • of 262

material and visual impact on the structure.

Historic windows and doors should be repaired rather than replaced, and drylining and

dampproofing should not disrupt or damage historic plasterwork or flagstones and should

not introduce further moisture into the structure.

Roof insulation should be achieved without damage to slating (either during the works or

from erosion due to condensation) and obtrusive vents should not affect the character of

the roof.

In specific cases, relaxation of the values proposed may be acceptable, to the local

building control authority, if it can be shown to be necessary in order to preserve the

architectural integrity of the particular building.”



As stated above, retrofitting for energy efficiency could alter the character of the historic

structure through works to any historic fabric, windows, doors, façade, roof and interior

lining of external walls in particular.

12.



For residential buildings, the Dwelling Energy Assessment Procedure (DEAP) is the Irish

official procedure for calculating and assessing the energy required for space heating,

ventilation, water heating and lighting, less savings from energy generation technologies.

DEAP calculates the annual delivered energy consumption, primary energy consumption

and carbon dioxide emission, based on standardised occupancy.

The DEAP software contains equations and algorithms representing the relationships

between the factors contributing to the annual energy performance of the dwelling. The

software is accompanied by a series of reference data tables and is also available as an

XL spreadsheet table in order to produce a Building Energy Rating (BER).

DEAP is in compliance with the methodology framework of the EPBD. The DEAP

calculation framework is based on IS EN 13790, and has generally adopted tabulated data

and calculation methods from the UK system for energy rating assessments, the Standard

Assessment Procedure (SAP).

The equivalent tool for non-residential buildings is the Non Domestic Energy Assessment

Procedure (NEAP). This methodology is used to assess compliance with specific energy

performance aspects of Building Regulations Part L. It is applied to generate Building

Energy Rating (BER) and advisory report for new and existing non domestic buildings.

The general calculation tool for NEAP is the Simplified Building Energy Model (SBEM),

which is based on CEN standards and has been developed by BRE on behalf of the

Department of Communities and Local Government in the UK.

60





EFFESUS • 314678 • of 262

DEAP and NEAP calculate the energy consumption and CO2 emissions associated with a

standardised building use and occupancy. The energy consumption is measured in energy

per floor area per year (kWh/m2/yr) and the CO2 emissions are measured in mass of CO2

per floor area per year (kg CO2/m2/yr).

13.


buildings?

No, building performance assessments such as BREEAM, LEED, DGNB have neither

been encouraged by authorities nor have they been promoted by national market forces or

stimulation.






The requirements as stated in the Building Regulations, Part L, Conservation of Fuel and

Energy apply to all works to existing buildings, which are not exempted due to their

protected status or historic character. This includes any extensions, material alterations,

material changes of use and window and door replacement. While these works are being

carried out, energy requirements and CO2 emissions for the operation of the building shall

be limited.

“Major Renovation” as such is not specified in the legislation, although it is noted that it

may not be in all circumstances appropriate to apply the requirements for energy

efficiency to material alterations and change of use of existing buildings as they may prove

to be restrictive or impractical, in particular in built heritage.



Yes, these requirements would apply as material alterations or change of use generally

imply works of “Major Renovation” with significant works executed and include retrofitting

measures. Also, it regulates and enforces the upgrade of existing building stock in terms

of energy performance and CO2 emissions.



As stated in a), all building works, which imply material alterations or material change of

use are required to comply with the Building Regulations, Part L, Conservation of Fuel and

Energy.

62




EFFESUS • 314678 • of 262



are met?

No energy performance assessment after works have been completed are required or

established. However, works of “Major Renovation”, which include works of material

alteration or material change of use according to Irish regulation require planning

permission through a planning application. This planning application has to be

accompanied by a Building Energy Rating (BER) certificate, which represents the

proposed works regarding their energy performance. The building authorities depend

solely on the credibility of certified BER assessors, whose standards are regulated by the

Sustainable Energy Authority Ireland (SEAI), a government agency.



The prescribed energy performance requirements are only applied in theory and only to

the refurbished parts of the building or in case of a new extension to an existing building

would only apply to the newly built floor area.

(To extend the requirements to the entire existing building would in many cases impose

unreasonable measures to upgrade building elements which were initially not part of the

scope of works. Building costs for proposed works which are small compared to the

existing fabric, would increase significantly and the requirements would act as a deterrent

to retrofitting).



Through:



funding?

X Grants for retrofitting, protected structures

in particular, have been reduced generally

and are regulated by the SEAI. Conditions

are a certain amount of investment and

specific measures that must be completed.

A BER is funded with €50, grants vary from

€400 - 3.600max.

b) advantages /


taxation?

? ? ?

c) attractive financing? X Financing of any constuction works has

been stressed in Ireland since 2008.



EFFESUS • 314678 • of 262

d) information?

X SEAI provide very comprehensive

information for authorities, planners and

building owners with regard to energy

efficiency and renewable energies.

http://www.seai.ie/


certificate? 63

X Owners and landlords of residential, non-

residential and large public buildings are

required to produce a BER certificate upon

any lease or sale. These requirements

came into force in stages since 2010.


advice?

X SEAI would advise on whom to contact for

consultation and provide a list of certified

BER/SBEM assessors. Any further services

are to be sought through an architect and/or

engineer with BER/SBEM qualification.

Other? Please ex plain: - / -



Generally, as stated above, the requirement of a BER implies the involvement of an

officially certified architect or engineer, who not necessarily provides experience with

historic buildings. If the historic building is a protected structure, an officially certified

conservation architect is appointed and will have to produce a conservation report as part

of the planning application. The specific trade of energy efficient retrofitting for historic

buildings has not yet evolved in the market nor has it been initiated by the authorities. The

Irish Georgian Society and Dublin Civic Trust have raised the issue of a need for further

experience and expertise in these fields and provide relevant information.



As stated above (11.) the main issues arise in the treatment of historic windows and

doors, roof and façade features.

The most obvious and visible conflict arises when external façade insulation and render is

proposed to any historic façade, especially of a non render finish such as brick or stone.

The extra layer of generally 100-150mm often has multiple repercussions as it changes

the window and door rebates and clear openings, the base and roof connections and, in

terraced situations, the continuity of the building front with neighbouring properties.


The integration of energy performance indicators into a wider building performance

assessment such as BREEAM, LEED or DGNB has not been promoted strongly through

the authorities, nor has it been driven through market forces.

63




EFFESUS • 314678 • of 262


Name: Thorsten Peters

Affiliations: DWE

Full contact details: [email protected]



EFFESUS • 314678 • of 262

QUESTIONNAIRE

BACKGROUND DATA.





NL




a) national level; state advisory board RCE, collect and dispense info rmation and

subsidising retrofitting action to regain authentic state

b) regional level; --

c) local level; approval of retrofitting/restauration plans

d) other; specialised consultants




a) national level; Agentschap NL/Senter Novem, guiding energy label as sesments

b) regional level

c) local level

d) other

4. Please describe the cooperation between heritage managemen t and energy


None





No clear goals


--



EFFESUS • 314678 • of 262


DIRECTIVES (EPBD)64



buildings.

- Monument law

- Retrofitting of identified monuments to

be approved by local authority



environments.

- Identification of protected city sights


categorized? 65

- type

- age

- style

(no official categorisation)


categories.


categorized?


categories.

9.


not




not



not

11. a) In what ways are hi storic buildings and historic environments 66 excluded from or


64


For instance:







EFFESUS • 314678 • of 262


There are no legal requirements



--

12.



Calculation of overall energy loss through building envelope, energy use-gain by

installations, standard user behaviour - climate

13.


buildings?

No, there is a separate guideline for LCA of constr uction-building materials






No minimum requirement; in general all comes back t o the owner/occupants/user

to agree on investment for energy saving



Not for listed CH buildings



--



are met? not

16 Are minimum energy performance requirements limited only to the renovat ed parts

or to the whole building? Only when renovation can be considered as new

construction or re-use/transformation of the buildi ng

66







EFFESUS • 314678 • of 262



Through:



funding?

X

b) advantages /


taxation?

X VAT rate 6%


X

d) information?


certificate? 70

X


advice?

X




Yes, for some applications certification is given. eg. cavity wall insulation, ETICS



In general the retrofitting action should not harm the authenticity of CH buildings


--

70




EFFESUS • 314678 • of 262


Name: Bas Verhey, Harold Brocken

Affiliations:


Additional mail sent April 22th from Harold Brocken to Michael Kahn:

As far as we know there is no requirement for energy performance on existing buildings. There is a guideline

for determining the energy efficiency. To be honest with that determination and involved guidelines for new

buildings Netherlands was in front already 20 years ago. As a consequence all relatively young buildings are in

energy performance category B (at least). The Dutch markt for renovation and retrofitting is a difficult chapter

for energy saving because owners and occupants have a ruling vote . If they rent the place they have a strong

vote to deny the increase of rental cost due to improvement actions and if they are owner they have to decide

themselves on there investment (often the pay-back time is too long to make it interesting). Implementation of

EPBD 2010 harms other legal rights that are set in the Dutch building market. In fact I have discussed that with

EU quarters and with the responsible Dutch government office about 2 years ago. Outcome, the EU leaves

implementation to each members state for itself without further EU involvement. The Dutch government office

has an ongoing discussion/request with EU to understand the situation?

Of course when it comes to governemental buildings the case is different. (The government does try to set an

example.) Beyond the governemental buildings there are lots of good examples and initiatives in the market,

but there is no official requirements for existing buildings.

For CH buidlings the local authorities decide per case whether or not retrofitting actions are allowed. Each

authority more-or-less uses its own interpretation for that with the main baseline ‘not to harm the authentic

appearance of the building’. The local authority is set by what we call the ‘Monument law’.

Since several years the building market is asking the government for more clear requirements on energy saving

actions on existing building but with respect to the actual economy these requirements are postponed. It’s a bit

disappointing I know!

Additional mail sent May 6th from Harold Brocken to Michael Kahn:

CH buildings that are official listed are free from the requirement; retrofitting for those building must be

approved by the local heritage authority.



EFFESUS • 314678 • of 262

Questionnaire

BACKGROUND DATA.





Norway



At the national level The Directorate for Cultural Heritage (Riksantikvaren) is responsible

for the practical implementation of the Norwegian Cultural Heritage Act and the

objectives laid down by the Norwegian Parliament (Stortinget) and the Ministry of the

Environment (Miljøverndepartementet). The Directorate's task is to facilitate sound and

efficient heritage management throughout the country.

The regional level for public management of the Cultural heritage is delegated authority

from the Directorate of Cultural Heritage, and has as its main task the management of

protected cultural heritage of national value in the county. The county council shall, as far

as possible, give the municipalities help and guidance in planning and development

issues under the Planning and Building Act.

The Municipality is the key authority when it comes to the Planning and Building act – for

instance zoning plans (protection) and building permits. Some larger cities have Cultural

Heritage Management Offices which advise on all questions of conservation and cultural

heritage.

All levels give to some extend advices to owners on topics like maintenance, changing of

valuable buildings, energy efficiency etc.


a) national level

b) regional level

c) local level

d) other

3. Explain how the authorities which reg ulate energy performance in buildings


Energy performance in buildings is controlled through the planning – and building act

(PBL).

Ministry of local government and regional development has overall responsibility for the

building part of this Act.



EFFESUS • 314678 • of 262

PBL is supplied with a technical regulation (TEK). TEK contains among many topics also

requirements for energy performance.

The Directorates for building quality (Direktoratet for byggkvalitet) is the central building

authority. Directorate do not consider specific building projects or specific solutions, but

shall contribute to a good set of rules, efficiency building process, make sure that the

building meets certain quality requirements and that the built environment contributes to

sustainable development and good living. Directorate is a center for building matters, a

professional body within the building matters and academic advisor in building

engineering, environment, health and safety and building regulations in general.

The municipalities are the local building authority. They consider applications from

owners relating to the PBL. They have the authority to issue permits, dispensations,

assess whether actions are within the law or not etc.

Norwegiaon Water Resources and Energy Directorate (NVE) is a directorate under the

Ministry of Petroleum and Energy. NVE’s mandate is to ensure an integrated and

environmentally sound management of the country*s water resources, promote efficient

energy markets and cost-effective energy systems and contribute to efficient energy use.

It is responsible for the energy labeling system in Norway.


a) national level

b) regional level

c) local level

d) other

4. Please describe t he cooperation between heritage management and ener gy


The municipalities will in most cases be responsible for balancing the interests – heritage

management and energy saving. This balance has proved in practice to vary greatly

between different municipalities. Some municipalities require extensive documentation,

others require simple documentation as background.

Regional level shall be informed and will have the opportunity to express themselves in

cases where cultural heritage is in danger of being lost due to inter alia energy savings:

• Applications relating to demolition or substantial alteration of any building older than

1850 cf kml § 25

• Demolition or substantial alteration of buildings and facilities regulated for the purpose

of preservation of expertise. Such buildings shall not initially disclosed.

• Applications that may affect cultural heritage of national or regional significance.

• In areas zoned for special conservation where local authority's decision be appealed by

third parties, the municipality may, if it deems necessary, obtain a statement from the

county before final appeal.



EFFESUS • 314678 • of 262

• Applications municipality even see a need for the county shall submit

statement to (cf. duty of cooperation).

Region government has delegated its responsibility for listed buildings and civil

authorities to refuse applications for projects that will reduce the cultural and historical

values. In practice, the preservation of cultural heritage comes before the interests of

energy conservation in buildings protected by the Cultural Heritage law. It is nonetheless

acceptance of some measures to ensure the use and resources for maintenance also on

these buildings.

The Directorate for Cultural Heritage has a corresponding responsibility for buildings

protected by the Cultural Heritage law, but where the responsibiity is not delegated to the

regional level.

The Directorate for Cultural Heritage do cooperate DiBK and provide input to the

formulation of regulations and guidance including related to the balance between energy

efficiency and conservation.


5. Please describe the national political goals for re ducing em issions (CO2 ) and



It is a national political goal to have more energy efficient buildings – with measures for

new construction and existing buildings. The government will tighten the requirements in

in TEK till passive house level by 2015 and almost zero energy house by 2020. The

decision on the level of requirements shall be made on the basis of surveys of socio-

economic and health consequences and expertise in the construction industry.

The diversity of cultural heritage should be preserved as resources for use and basis of

knowledge, experience and value creation.

In the Whitepaper for Building politic it is emphasized that buildings worthy of

preservation is not particularly looked into. There is now plans on making a own TEK for

existing buildings.

To days TEK for both new and existing buildings gives poorly definition in terms of

existing buildings. Part of the requirements is not possible to satisfy in the existing

buildings, the requirements are based on new construction situation, not in the actual

situation of existing buildings. To prepare this new TEK will include looking into how

energy efficiency requirements can be adapted for different building types (age,

construction, function) including the preservation listed buildings.



EFFESUS • 314678 • of 262

ENOVA was established in 2001 in order to drive forward the changeover to more

environmentally friendly consumption and generation of energy in Norway. They promote

more efficient energy consumption and increased production of “new” renewable energy.

This is done via targeted programmes and support schemes in the areas in which the

greatest effect in the form of saved, converted, or generated clean energy can be

documented. They are a public enterprise that is owned by the Ministry of Petroleum and

Energy. The goal is to strengthen the work in converting energy consumption and

generation into becoming more sustainable, while simultaneously improving supply

security. This is done primarily through financial support and counseling.

Barrierer for gjennomføring av energi effektivisering er under vurdering.

Up till now very little is done when it comes to buildings with cultural value. The law and

the practice are unclear. It is not discussed how to handle buildings with cultural value

and requirements for more energy efficiency in the future with generally stricter

requirements.


Through:

tighten the requirements in TEK

Financial support

Information

Barriers to implementation of energy efficiency are being considered in order to ensure

implementation of measures.


DIRECTIVES (EPBD)71

7. a) Describe the national and regional legal systems for protecting historic buildings.

Legal protection is done through 2 different acts:

Planning- and building act (PBL):

It has two main parts

Planning - decisions on over view planning, binding land-use planning and environmental

impact assessment. Consideration zones(hensynssoner), legally binding provisions, can

be linked to both municipal and zoning and includes zones for the conservation of cultural

heritage buildings.

Buildings - provisions on the duty of application, control and approval of construction

works etc. The provision in the PBA § 31-1 Preserving cultural values in work on existing

structures can be used to instruct the developer to maintain visual and cultural qualities of

71




EFFESUS • 314678 • of 262

the work on the existing building structure. The provision provides authority to deny

measure.

Ministry of Environment has the responsibility for the part concerning planning and the

Ministry of local government and regional development.

The Cultural Heritage Act (KML):

The purpose of cultural heritage management is described in the Cultural Heritage Act,

which lays down that it is a national responsibility to safeguard archaeological and

architectural monuments and sites and cultural environments "as part of our cultural

heritage and identity and as an element in the overall environment and resource

management".

Under the terms of the Act, the Directorate for Cultural Heritage may impose a protection

order on buildings, groups of buildings, cultural environment/cultural landscapes. There

are two types of protection given to monuments and sites, depending on whether they

date back to before 1537/1650. Monuments and sites prior to 1537/1650 are automatically

protected, while those dating from 1537/1650 onwards require a protection order, which is

granted on a case-to-case basis.

b) Describe the national and regional legal systems f or protecting historic

environments.

Very much the same as for single buildings. Se above


categorized? 72

Historic buildings are not categorized

beyond the various forms of protection

- Protected through The Planning and

building act

- Protected through The Cultural heritage

act

Buildings can also be listed (no legal

protection) as cultural heritage valuable by

the municipality.

In addition there are set special

consideration related to buildings pre 1850.



categorized?

As far as I know, they are not categorized.

20 farmland in agriculture have been

selected as particularly valuable. The

project follows up the national goal that

particularly valuable farmland should be

documented and given a special

administration in 2010.


categories.

72

For instance:







EFFESUS • 314678 • of 262

categories.

9.


The EPBD is not yet implemented in Norway, but will, I suppose, be soon. However most

of the requirements have been introduced. In the Planning and Building Act there are

requirements for U-values, energy demand and energy source. Existing buildings have to

meet the requirements when going through a major renovation. For smaller measures, the

measure in itself must meet the requirements. The possibilities for exceptions are not well

defined and practice varies from case to case. There are slightly lower requirements for

log buildings.

The possibility to exempt listed buildings and cultural buildings in the EPBD is followed up

in the Planning and Building Act in the requirements for existing buildings.

Energy certificates have been introduced: There are possibilities for exemptions from

energy certification for buildings with cultural value as in EPBD.

The labeling system is as follows:

Energy grade from A to G based on estimated energy requirements. How well is your

house insulated?

Heating grade - COLOUR - How environmentally friendly is the energy you use? Heating

grade determined by the proportion of the total heating requirements covered by electricity

and / or fossil fuel products, which must be below certain values to achieve the different

color grades.






All projects subject to application for existing buildings shall initially be designed and

constructed in accordance with the requirements for new construction, (Planning and

building act § 31-2 first paragraph).

It is essential that the claim is relevant, ie that it is a relevant part of the building, fulfills a

function and effect of the measure applies. The law allows, however, § 31-2 fourth

paragraph that the municipality may grant permission for change of use and the necessary

reconstruction and rehabilitation of existing structures even if it is not possible to adapt the

structure to current technical standards.

Buildings shall meet level specified in TEK § 14-3 or having a total net energy less than

the energy limits specified in TEK § 14-4. Minimum requirements in TEK § 14-5 shall be



EFFESUS • 314678 • of 262

met either by TEK § 3.14 or TEK § 4.14 shall apply (some exceptions).

14-3: Energy measures are grouped into three categories: transmission heat loss,

infiltration and ventilation heat loss and other steps.

14-4: Total net energy shall not exceed the specified power setting for the building

category, expressed in kWh / m² heated BRA per year.

5.14: The energy saving model and framework requirements model provides flexibility with

respect to the energy measures implemented. Minimum requirements relating to thermal

insulation and density are introduced to ensure an acceptable building structure in all new

buildings.

TEK open the possibility for buildings with cultural value to not fulfill the demands in TEK.

This provision applies to buildings that are: protected under the Heritage Act, zoned for

conservation or other form of protection in PBL or fills corresponding cultural heritage

criteria.

Energy supply: It is not allowed to install oil boilers of fossil fuels for base load. Building of

500 m² heated BRA shall be designed and constructed so that at least 60% of net heat

demand can be covered with different energy than direct-acting electricity or fossil fuels at

retail. (Building up to 500 m² heated BRA - at least 40%)




The rules on energy in the technical regulation (Teknisk forskrift), TEK10 Chapter 14, has

a provision that says that if the fulfillment of energy requirements are not consistent with

the preservation of cultural and historic value, the energy requirements shall be met as far

as possible within what is advisable in the interest of and the desire to maintain historical

and aesthetic qualities of the building.

Log houses has somewhat less stringent Performance requirements.

The possibilities for exceptions are not well defined and practice varies from municipality

to municipality.



There is no specific historic buildings-/environment-types that are excluded from the

requirement.

12. Describe the national legal methodology for the cal culation of the minimum energy

73





EFFESUS • 314678 • of 262


Heat loss figures are calculated by NS 3031 Calculation of energy performance of

buildings - Methods and data. The standard includes three calculation options:

Month calculation (stationary method) according to EN ISO 13790;

Simplified time calculation (dynamic method) according to EN ISO 13790;

Detailed calculation programs (dynamic method) validated according to EN 15265.

13.


buildings?

No






Main Reconstruction is defined as the alteration or repair of structures that are so

extensive that the whole structure is substantially renewed.

Minimum energy performance requirements in buildings will come info force.



Yes



Energy requirements are applicable in principle to all additions / supplement and all

changes defined as "measures" in the Act. Normal maintenance is not covered.

“Measures” according to planning and building legislation include the construction,

alteration, demolition, change of use and other measures relating to buildings, structures

and facilities (building). Normal maintenance is not a “measure”. For instance replacement

of a load-bearing element of the same dimensions and quality are considered normal

maintenance.

Application service starts only when a change or repair will be "significantly". Here, both

the extent and character of importance must be considered.

It is essential that the claim is relevant, ie that it is a relevant part of the building, fulfills a

75





EFFESUS • 314678 • of 262

function and effect of the measure applies. Requirements are limited as a rule to include

those parts of the structure to which the measure applies. If there is a question about the

renovation or change of use is basically the requirements applicable to the entire building.

According to the PBA. § 31-2, fourth paragraph, the municipality may allow change of use

and the necessary reconstruction and rehabilitation even when it is not possible to adapt

the structure to the technical requirements without disproportionate costs, if the user

changes or modifications are appropriate and necessary to ensure appropriate use.



are met?

Planning and Building Act contains provisions on supervision in Chapter 25. Local

authorities are given the duty to supervise the construction, both in general and

specifically where there are clear abuses, and there is already issued orders. The

municipality shall monitor the extent that it can detect violations. The municipality shall

monitor the already given orders and when it becomes aware of abuses beyond trivial

matters.

Quality assurance and control of design and construction

Responsible designers and responsible contractor shall have a system to ensure and

document that the legal requirements are met. In addition, it shall be conducted

independent audit of responsible control entity when:

a) there are important and critical areas and tasks

b) the municipality requires that after a specific assessment.



When major renovation – the whole building. Otherwise the renovated parts.

Se above

17. In what ways are the national legal requi rements for minimum energy performance


Through:



funding?

x There is funding available for buildings in

general with certain target on energy

saving. For protected buildings this targets

are seldom possible to reach and therefor

they seldom get subsidies.

b) advantages /


taxation?

x There are in some municipalities an

exception from real estate taxes, but not for

improving energy performance



EFFESUS • 314678 • of 262


x As far as I know, no.

d) information?

x General information for all existing

residential houses which very seldom gives

any good information on traditional building

technics or how to treat cultural valuable

buildings.

There are a few reports and some

information on internet on this theme

(Energy performance and historic

buildings). The Directorate of cultural

heritage has information on web.

e) energy perform ance

certificate? 77

x Yes – but with no regard to keep up cultural

values.


advice?

x x To some extend from regional and national

cultural heritage authorities.




Yes



Energy savings

Insolation - exterior for insulation is the most effectiv. The goal of passive and almost zero

energy house can only be reached through such measures. This leads to loss of heritage

values (significant alteration of the exterior). To reduce the change of the exterior, internal

insolation will often be implemented. This will change interiors and increases the risk of

building physical damage (colder / wetter walls)

Density - a prerequisite for balanced ventilation with heat recovery. Do not follow

77




EFFESUS • 314678 • of 262

traditional building technology and may lead to physical damages. But this requires also

extensive internal work that will damage valuable historic interiors. Density requires other

solutions to ventilation than natural ventilation which old buildings often are based upon.

Ventilation with heat recovery - with the air change requirements in TEK we must have

heat recovery. This requires systems that will require space in the interior and that will

require adverse impact on valuable historic building components.

The main focus is on energy conservation instead of looking more holistic when doing

measures to reduce impacts on the climate. It is the climate that really is the great "case".

Magnitude of GHG accounting, waste reduction and reuse are important keys.

The main directions when it comes to ventilation, construction, etc. are based on modern

technology. Older builds technical solutions and building characteristics are not used. This

leads to actions with greater impact on valuable historic building parts than necessary, and

the traditional knowledge is not utilized and not included in the new building.


To the person(s) who fills out the q uestionnaire, please provide:

Name: Marte Boro

Affiliations: Directorate for Cultural Heritage (Riksantikvaren)


e-mail: [email protected]

Telephone: 047 98228730

Address: Dronningens gate 13, Pb 8196 Dep, 0034 Osl o, Norway




EFFESUS • 314678 • of 262

QUESTIONNAIRE

BACKGROUND DATA.





Portugal



Heritage management is performed by DGPC (The General Directorate of Cultural

Heritage), which is the result of the merge of IGESPAR IP, IP and BMI Regional

Directorate of Culture in Lisbon and Tagus Valley. In particular, IGESPAR is the Institute

for the Management of Architectural and Archaeological Heritage.

It is a State agency, under the auspices of the Ministry of Culture, with responsibilities for

the architectural and archaeological heritage. The organization is divided into five

individual services:

Safeguarding Department, which is responsible for coordinating and initiating studies on

candidates for listing as national patrimony, the promotion of plans for safeguarding

buildings, restrict or invalidate construction projects that infringe on national patrimony,

and monitor, as well as implement projects to conserve national patrimony;

Inventory, Studies and Dissemination Department, the department responsible for the

physical analysis of the conditions, state and study of the national monuments or

architecture of national interest, and provide technical assistance for listed patrimony;

Projects and Works Department, follows the conservation process of existing buildings

and structures on site, providing solutions for existing degradation and promoting

preventative solutions for existing sites;

Law Department provides legal decisions and supports the legal intervention on behalf of

existing or on-going investigations;

Management Department, responsible for managing the on-going structure of the

organization and sustaining operations.

At the same time, it is also responsible for managing the operations of several of the

nation’s most important architectural sites, including: the Convent of Christ in Tomar, the

Monastery of Batalha in Batalha, the Monastery of Alcobaça, the Jeronimos Monastery

and Tower of Belém in Santa Maria de Belém, the National Pantheon in the Church of

Santa Engrácia, the Monastery of Santa Cruz in Coimbra and the Archaeological Park of

the Côa Valley.

The core structure of the General Directorate of Cultural Heritage (DGPC) integrates the

following units:



EFFESUS • 314678 • of 262

The Department of Cultural Property;

The Department of Museums, Conservation and Accreditation;

The Department of Studies, Projects, Construction and Supervision;

The Department of Planning, Management and Control.


a) national level

b) regional level

c) local level

d) other



At this moment the Portuguese Energy Performance Certification scheme comprises the

full implementation of the EPBD, meaning that all the required buildings are now

included: new buildings, major renovations, public buildings and all buildings when sold

or rented.

ADENE (the Agency for Energy) develops and manages the Buildings Certification and

coordinates the training of the qualified experts that will issue the certificates. All

certificates are registered in a web based central system, by the qualified expert issuing

the certificate.

All the licensing and selling processes that take place in Portugal are covered by the

certification. This is probably a consequence of the strong efforts that ADENE has put on

disseminating the Certification among the municipalities and promoters. At the time

being, all municipal services have effectively included the certificate in the list of

documents required in a licensing process and the promoters are now fully aware of the

need to comply with performance requirements.

The Energy Agency was born in September 2000 by transformation of the Center for the

Conservation of Energy (CCE), created in 1984. In December 2001 the mission, scope

and functions of the Agency for Energy were adjusted and its name changed to ADENE.

It is an institution of associative type of public nonprofit subsidiary majority (69.66%)

institutions by the Ministry of Economy and Employment.

To fulfil the mission assigned to it, ADENE is composed by the following operational

directorates:

Directorate of Energy Audit Industry (DI)

Department of Energy Auditing in Buildings (DE)

Marketing Management (DM)

Project Directorate (PD)

Technical Director (TD)

ADENE performs primarily public interest activities in the field of energy policy and public

service concession or licensed in the energy sector.



EFFESUS • 314678 • of 262

ADENE develops its activity among different economic sectors and consumers, in order

to rationalize their energy behaviours, applying new methods of energy management and

use of new technologies. Its current activities include:

Participation in the European Network of Energy Agencies (EnR);

Management of the National Energy Certification and Indoor Air Quality in Buildings

(SCE) and System Management Intensive Energy Consumption (SGCIE);

National priority areas, such as the National Action Plan for Energy Efficiency (PNAEE),

as well as interventions in the areas of Demand Management and Renewable Energy

with big market players Portuguese energy.

Energy Agency’s mission is to promote and carry out community service in the area of

energy and its interfaces with other sectorial policies.


a) national level

b) regional level

c) local level

d) other



The main Portuguese reference standard, when energy management is concerned, is the

Regulation of Characteristics of Thermal Performance of Buildings (RCCTE).

The Decree-Law 80/2006, of April 4, Regulation Characteristics of Thermal Performance

of Buildings (RCCTE) establishes quality requirements for new residential buildings and

small office buildings, particularly in terms of characteristics of the environment by limiting

heat loss and controlling excessive solar gains.

The regulation also imposes limits on energy consumption for air conditioning and hot

water production, a clear incentive to use efficient systems and energy sources with

lower impact in terms of primary energy. This legislation requires the installation of solar

panels and values the use of other renewable energy sources.

However, as explicitly stated in the “Field of application” section, this Regulation does not

apply to “refurbishment, restoration and expansion interventions of buildings in historic

areas or on classified buildings, where there are incompatibilities with the requirements

this Regulation”.


The Decree-Law n. º 140/2009 establishes the basis of politics and the system of

protection and recovery of cultural heritage, introducing a control mechanism in relation

to all works or interventions in cultural heritage.

In the legal system of urbanization and building, works of reconstruction, extension,

change and conservation of cultural properties include necessarily the prior report. The



EFFESUS • 314678 • of 262

prior report will cover the following aspects:

criteria to justify the intervention works or reconstruction, extension, alteration and

conservation proposals;

Adequacy of works and interventions in relation the characteristics of the building, taking

into account the degree of classification of national interest, public interest or city of

interest, as well as cultural the grounds, including the historic interest, architectural,

artistic, scientific, social or technical;

Compatibility of systems and materials proposed in relation to existing;

Assessment of the benefits and risks of the proposed works or interventions;

Consequences of works and work on the archaeological heritage;

The proposed use of the property;

Bibliography and documentary sources relevant to the proposed works or interventions;

Survey photographic or videographic general, assembly and detail of the interior and

exterior.

The competent administration of cultural heritage decides the request for authorization

within 40 days or more, where works or interventions are of great size or complexity.

5. Please describe the national political goals for re ducing emissions (CO 2) and



The building sector is responsible for a significant proportion of the consumption of

primary energy and electricity in Portugal, mainly associated to the thermal comfort of

their occupants. The European Union wants a 20% reduction by 2020, of the energy

consumption and consequent CO2 emissions by improving energy efficiency in public

and residential buildings. In Portugal, the National Plan for Energy Efficiency (PNAEE)

aims to achieve an annual energy savings of at least 1% by the year 2016, based on the

average final energy consumption, recorded between 2001 and 2005. In this context, the

buildings prior to 1990 (first version of RCCTE) may present a significant potential for

improving its energy efficiency based on their rehabilitation.

It is shown that the potential for reducing energy costs with cooling and active systems

for generating hot water, through the implementation of passive measures, is higher

50%, while the installation of solar heat systems can reach up to 10%.

Among the measures introduced, it is worth mentioning the Energy Performance of

Buildings Directive, originally introduced in 2002 and recast in 2010 (Directive

2010/31/EU); it is a directive of the European Commission that obliges EU Member

States to set minimum energy performance standards for new and reconstructed

buildings. Furthermore, the Directive obliges each Member State to introduce energy

performance certificates.

When an existing dwelling changes owner or tenant, the Energy Performance of

Buildings Directive (EPBD) requires that this energy performance certificate has to be

shown to the new owner or tenant. The certificate includes an energy performance label

and in most Member States it also includes recommendations for cost-effective energy



EFFESUS • 314678 • of 262

saving measures.

The European Directive 2002/91/CE was transposed to the Portuguese national law on

April 4, 2006 by means of a legislative package composed of three Decree-laws:

The Decree-law no. 78/2006, which defines the National Energy Performance

Certification System and Indoor Air Quality in Buildings (SCE) partially applies the

Directive 2002/97/CE of the European Parliament and of the Council, of 16 December

2002, regarding buildings energy efficiency.

The Decree-law no. 79/2006, which establishes the Regulation of Temperature Control

Systems in Buildings (RSECE).

The Decree-law no. 80/2006, Regulation of Thermal Behaviour Characteristics in

Buildings (RCCTE).

6. Please describe how the goals in question 5 are pro posed to be achieved.

The schedule to implement the EPBD in Portugal passed through three phases:

1 July 2007: application of the SCE to new buildings with a summed floor area larger

than 1000 m2, registered for construction (requesting for construction permit) after this

date.

1 July 2008: application of the SCE to new small buildings, independently of the area,

being registered for construction (requesting for construction permit) after this date.

1 January 2009: the requirement of an energy certification for all buildings entered into

force in January 2009. All buildings either residential and services buildings to be sold or

rented after January 2009 must have an Energy Efficiency Certificate, which states about

the efficiency level of the building.

At this moment the Portuguese Energy Performance Certification scheme comprises the

full implementation of the EPBD, meaning that all the required buildings are now

included: new buildings, major renovations, public buildings and all buildings when sold

or rented. The scheme will be revised, following the recast of the EPBD Directive, and

several experts, and working groups are involved in its revision.


DIRECTIVES (EPBD)78

7. Describe the national and regional legal systems fo r pr otecting historic buildings

and environments

Law 107/2001 establishes the foundations of politics and the protection regime and

promotion of cultural heritage.

This law establishes the basis of politics and the system of protection and promotion of

78




EFFESUS • 314678 • of 262

cultural heritage, as the reality of most relevance for understanding, stay and construction

of national identity and the democratization of culture.

The politics of cultural heritage includes the actions promoted by the State, Autonomous

Regions, local authorities and the rest of Public Administration, aiming to ensure, in

Portuguese territory, the realization of the right to culture and enjoyment and realization of

cultural values and other tasks and bindings imposed in this area by the Constitution and

international law.

The foreseen ways to protect cultural heritage are:

The legal protection of cultural property based on job classification and inventory.

Each kind of protection gives place to the corresponding logging level, and therefore there

will be:

The registration sheet classification;

The asset inventory register.

The application of precautionary measures under the law does not depend on prior

classification or inventory of cultural property.

The Law classifies cultural heritage in movable and immovable. The property may belong

to the categories of monument, ensemble or site, pursuant to which such categories are

defined in international law, and furniture, among others, the categories listed in the

following:

Archaeological heritage

The papers

Audio-visual heritage

Bibliographic heritage

Heritage phonographic

The photographic heritage

8. How are historic buildings and environments categor ized? 79

The choice of the structure of information elements comprising the records inventory and

pre-inventory should result from the weighting of the following conditioning factors:

objectives / functions, provided products and recipients; financial, technological and

human resources; period of time.

Classification therefore refers to 9 elements (examples are given for each category):

Category (buildings and built structures cultural and recreational, educational buildings

and built structures, residential buildings and built structures, archaeological site, historic

site).

Type (elementary school, home entertainment, museum, battlefield).

Identifier (PT010301010003: PT Portugal match code, code 01 to the Northern Region, 03

79

For instance:







EFFESUS • 314678 • of 262

in the district of Braga, 01 to the municipality of Braga, 01 Amares the parish; 0003 a code

assigned by the technicians of SIPA, considering a sequential order within each county.

PT050801010002: PT Portugal match code, code 05 to the region of Algarve, Faro district

to 08, 01 to the municipality of Albufeira, Albufeira 01 to the parish; 0002 a code assigned

by the technicians of SIPA, considering a sequential order within each county).

Appointment (Monastery of Santa Maria de Belém / Jeronimos Monastery and Church of

Mercy Hospital of Swindon / Ana Pereira Theatre, Building on the Street of Our Lady of

Fatima, n. 231).

Location (Lisbon and Vale do Tejo, Lisbon, Lisbon Prazeres. Viseu, Lamego, Britiande.

Region of Algarve, Faro, Albufeira, Guia. WGS84: 37 ° 28’46 .11 "N, 8 ° 18’27 .31" W).

Access (Rua Almirante Cândido dos Reis, n. 2. S. the town of Deliverance, with access

through AT 1337 from the intersection with EN 125, Lady of Deliverance direction.

Avenida Almirante Reis, n. 125, formerly Dona Amelia Avenue).

Protection (MN, Dec. n. No. 32/97, 150, DR 2 July 199. IIM, city council Resolution of

February 25, 2005. World Heritage - UNESCO, 2001. Enjoys a Protection Zone

established by the Ministries of Justice and Public Works for prisons and for

establishments guardianship of minors DL n. º 31,190, of March 25, 1941, and Decree. º

265/71 of 18 June. Included in the Special Protection Zone of the Cathedral of Lamego

Partly included in the protection zone of the Poet House António Guerreiro Included in the

Parque Natural da Ria Formosa. ZEP, DG 229, December 27, 1955 and Decree No.

251/70, DG 129, June 3, 1970 and Decree No. 516/71, DG 274, November 22, 1971.

Property as proposed by the PDM Public Interest Customs of the Faith, DR 241, 18

October 1994).

Period of construction (Century II, Century Sixteenth / seventeenth, Century. XII,

Medieval).

Placement (urban building, rural hermitage).


The EPBD was transposed to the Portuguese national law on April 4, 2006 by means of a

legislative package composed of three Decree-laws:

The Decree-law no. 78/2006, which defines the National Energy Performance Certification

System and Indoor Air Quality in Buildings (SCE) partially applies the Directive

2002/97/CE of the European Parliament and of the Council, of 16 December 2002,

regarding buildings energy efficiency.

The Decree-law no. 79/2006, which establishes the Regulation of Temperature Control

Systems in Buildings (RSECE).

The Decree-law no. 80/2006, Regulation of Thermal Behaviour Characteristics in

Buildings (RCCTE).






EFFESUS • 314678 • of 262

The main legislative references for energy performa nce in historic buildings are the

abovementioned SCE, RSECE, RCCTE, all deriving from the EPBD.



The maximum allowable Nic and Nvc must be met to no more than the limits of

thermal quality, set out in Article 16 of the RCCTE , and updatable by joint order of

the ministers responsible for the economy, public w orks, environment, land use

land and housing.

The limits of thermal quality referred to above are related to the following

parameters:

Ratios of maximum heat transfer of the opaque envel ope, which separate the

outdoors units, or spaces that do not require comfo rt conditions or other

neighbouring buildings;

Factors of solar horizontal and vertical glazing wi th a total area of more than 5% of

the floor area of pavement provided that no oriente d between northwest and

northeast.

For further information, the complete RCCTE is avai lable at:


11. a) In what ways are hi storic buildings and historic environments 80 excluded from or



As explicitly stated in the RCCTE “Field of application” section, this Regulation does not

apply to “refurbishment, restoration and expansion interventions of buildings in historic

areas or on classified buildings, where there are incompatibilities with the requirements

this Regulation”.



The most recurrent reason is the aesthetical impact of energy efficient refurbishment, or

the practical impossibility to fit typical retrofit elements to historical buildings. Aspects of

plastic facades, dictated by its architectural features, may make the process of applying

insulation and preclude its implementation from the outside, possibly with implications of

various kinds, namely, in the case of listed buildings (heritage) or relevant Architectural

interest.

12. Describe the national legal methodology for the cal culation of the minimum energy


80






EFFESUS • 314678 • of 262

The detailed procedure to compute the minimum energy performance of buildings is

reported in the complete RCCTE, available at:


The Portuguese Energy Agency also provides a fairly simple software to roughly assess

the energy performance of each building. This tool is available at the following address:

http://www.casamais.adene.pt/ and also provides some suggestions to improve the overall

energy efficiency of the dwelling.

13. Is life cycle assessment (LCA) a part of the evalua tion of the energy performance in

buildings?

No, it isn’t.






Major refurbishment or alteration means the interventions or the surrounding premises

whose cost exceeds 25% of the building, based on a reference value per square meter of

building typology and set annually by joint order of the ministers responsible the areas of

economy, public works, environment, spatial planning and housing, published in October

and valid for the next calendar year.

The Regulation applies to new buildings, large refurbishment or alteration interventions.


when the use/function of a building is changed? Ple ase explain.

The regulation applies only for newly constructed buildings and large refurbishment

interventions. No case of change in use/function is mentioned in the regulation.



N/A

15. After renovation or other situations (see question 14), how can the authorities


are met?

Before permitting inhabitation of buildings, a number of documents shall be provided to the

National authorities. The licensing procedure or building permit shall include:

A summary sheet of demonstrating regulatory compliance RCCTE the face of the building;

A dimensional survey for each unit, which includes a brief description of constructive

solutions used;

The calculation of nominal power needs of the building, Nic, Nvc, Nat and Ntc;

83




EFFESUS • 314678 • of 262

A certificate of proof of satisfaction of the minimum requirements, and construction details

of defining all situations thermal bridge.

Declaration of responsibility of the technician responsible for the project stating the

satisfaction of the requirements of the Regulation;

Statement of Regulatory Compliance signed by a qualified expert in the framework the

SCE.

Besides, the application for a license or authorization of use must include a certificate

issued by a qualified expert in the framework the SCE. This is the way the authorities

control whether the legal requirements for minimum energy performance are ac tually

met.



Minimum energy performance requirements are applied to the whole building or dwelling

unit (apartment).



Through:



funding?

X

b) advantages /


taxation?

X


X

d) information?

X Energy efficient refurbishment is

stimulated through information

campaigns on medias.


certificate? 84

X Very efficient tools are available for

certificate estimation. It is also

compulsory when there is a property

change.


advice?

X Refurbishment is encouraged by

companies operating in the field

(construction companies, suppliers,

etc.)

84




EFFESUS • 314678 • of 262


N/A

18. Are t here or can there be applied a requirement for comp etency or experience when


No specific requirement for competency or experience is applied when working with

historic buildings and energy efficiency.


efficient measures and their compatibility with her itage protection legislation.

The main concern of energy efficient measures applied to cultural heritage deal with

aesthetics and ease/possibility of installation. Exterior elements on facades are accepted

with difficulty because of their impact. The same applies also for indoor

equipment/components. Less invasive solutions shall be stimulated for their adoption in

historical buildings.


N/A


Name: Marta Ochoa

Affiliations: Active Space Technologies


Address: Rua Coronel Júlio Veiga Simão, 3025-307 Co imbra, Portugal

Tel: +351 304 505 505

Fax: +351 304 505 506

Mail: [email protected]




EFFESUS • 314678 • of 262

QUESTIONNAIRE

BACKGROUND DATA.





Spain / Galicia



Although there is a national body in the Ministry of Culture, Education and Sport of the

National Government of Spain, nearly all competences for historic heritage management

are transferred to the regional government authorities. Thus, in the regional Government

of Galicia, named "Xunta de Galicia", there is the Ministry of Culture, Education and

University planning, which has the competences in relation to the protection of the

heritage. The distribution of competences between the State and the Autonomous

Communities is addressed in Title VIII of the Spanish Constitution. The Spanish State

reserves the sole competence in the defence of cultural heritage, artistic and

monumental Spanish against the export and the plundering, and retains the

competences on monuments and assets which are the property of the Spanish State.


a) national level: Authority: Ministry of Education, Culture and

Sport(www.mecd.gob.es). The Ministry has in its structure two branches responsible for

the protection and conservation of the Spanish Cultural heritage, dependent of the

General Directorate of fine arts and cultural property and archives and libraries.

Subdirectorate-General for the protection of heritage. It is responsible for the

implementation of the legal regime of the protection of the Cultural heritage. In addition

this subaddress has associated with the coordination of the following bodies:

*Council of the Spanish historical heritage. Coordinating body between the

administration of the State and the autonomous communities whose purpose is to

facilitate communication and the exchange of programmes of action and information

relating to the Spanish Cultural heritage.

*Board of qualifications, assessment and export of goods of Spanish heritage .

Collegiate advisory body attached to the General Directorate of fine arts and cultural

property and archives and libraries responsible for the review of applications for export,

import and acquisition of goods.

Subdirectorate- General of the Institute of Cultural heritage of Spain. Its main



EFFESUS • 314678 • of 262

functions are the elaboration and implementation of plans for the conservation and

restoration of the Spanish Cultural Heritage; the study of methods and techniques

updated for the restoration and conservation of the same; Archive, technical processing

and dissemination of documentation available about this heritage and to projects;

interventions and work carried out in each particular case; the dissemination and

exchange with international organizations; the training of technicians that meet the

purposes of the Institute, and the proposal of conclusion of agreements with other public

administrations and public or private entities for the conservation of heritage.

b) regional level: Galicia. Authority: Ministry of Culture, Education and University

planning. (http://cultura.xunta.es). The protection of the heritage is the responsibility

of the Directorate General of cultural heritage.

c) local level: Authority: Municipality of Santiago de Compostela

(www.santiagodecompostela.org). In the municipal government there is a Department

of urban development and sustainability, with skill s in the following policies:

housing, urbanism, sustainability, infrastructure, rehabilitation of historic city and

heritage.

As there is approved and in force a Special Plan of Protection and Conservation of

the historic city (PEPCH), the municipal government has nearly all competences in

relation to the protection of the historic city.

The condition so that the municipal Government assu mes powers on records that

affect buildings or areas declared good of Cultural interest (BIC) is that the

Management Plan is approved and in force.

d) other: Consorcio de Santiago (www.consorciodesantiago.org) . The Consorcio de

Santiago is a public administration of cooperation between the Spanish Government, the

Government of Galicia and the local government, in order to manage and develop the

urban project. Among other activities, the Consorcio de Santiago manage the programs

of rehabilitation of the historic city, monuments and public space. The annual budgets of

the Consorcio de Santiago are financed with the contribution in 60% of the Government

of Spain, in 35% of the Government of Galicia and in 5% of the local Government of

Santiago de Compostela.



IDEA (www.idae.es): The Institute for the diversification and saving of Energy, IDAE, is

a body attached to the Ministry of industry, energy and tourism, through the Secretariat of

State for energy, from who depends on organically.

Contribute to the achievement of the objectives that Spanish Government has acquired in

the field of improvement of energy efficiency, renewable energy and other low carbon

technologies is the strategic framework for its activity.

In this sense, the IDAE carries out dissemination and training activities, technical support,

development of specific programmes and financing of projects of technological innovation



EFFESUS • 314678 • of 262

and replicable character. Likewise, the Institute leads an intense international activity in

the framework of various European programmes and cooperation with third countries.

INEGA (www.inega.es): The Instituto Enerxético de Galicia was created by law 3/1999,

of 11 March.

The Parlament of Galicia, once analyzed the Galician and international energy context,

saw fit to create an entity that carried out the functions, initiatives and energy

programmes developed until then by different bodies of the autonomous administration.

The legal configuration of the Inega is an entity of public law, with legal personality and

assets themselves. It is attached to the competent Department in the field of energy, the

Ministry of economy and industry of the Government of Galicia, and subject, in its

activities, programs and general guidelines of the Xunta de Galicia, but with functional

autonomy for studies, reports, surveys and educational or commercial activities for the

public administration, for businesses and for citizens.


a) national level Authority: Ministry of industry, energy and tourism.

b) regional level Galicia. Authority: Ministry of economy and industry.

c) local level Santiago de Compostela. There is no specific body for energy affairs.

d) other



There is currently no cooperation among heritage management and energy management

in Spain.





According to data collected in the "2001 population and housing census" of the National

Institute of statistics of Spain, pre-1940 buildings represent the 21% of total Spanish

buildings mainly for dwellings and the 50% of total Spanish ruined, bad state or deficient

buildings (15% and 38% respectively if we restrict it to the pre-1920 buildings). If we have

that in 2008 were declared BIC (good of cultural interest) in Spain 872 historical sites and

13 cities as world heritage, the problem of the energy rehabilitation in pre-industrial

building in general, and of the historical centers in particular, is an issue that must be

addressed.


According to official data on the last Spanish GHG emissions Inventory data for 1990-

2005, gross emissions have increased by 52.2% with respect to the base year.



EFFESUS • 314678 • of 262

This data reflects the need of urgent additional actions, even though the preliminary data

for 2006 show a trend change that started in mid-2005.

The Spanish Climate Change and Clean Energy Strategy aims to fulfil the commitments

of Spain in matters of climate change and support to clean energies, while improving at

the same time, social welfare, economic growth and environment protection. The

operational objectives are:

• To ensure the reduction GHG emissions in Spain, giving special importance to

measures related to the energy sector. According to the national inventory, and following

the IPCC classification, in 2005, emissions from energy process represented about

78.87% of total national emissions.

• To contribute to sustainable development and the fulfilment of our climate change

commitments by strengthening the use of flexible project-based mechanisms.

• To promote additional reduction measures in sectors concerned with diffuse pollution.

• To apply the National Climate Change Adaptation Plan (NCCAP) so as to integrate

adaptation measures and strategies in sectoral policies.

• To increase public awareness with respect to clean energy and climate change.

• To promote research, development and innovation in matters of climate change and

clean energy.

• To guarantee energy supply security by means of cleaner energies, mainly from

renewable sources, achieving other environmental benefits (for example, air quality) and

limiting the growth rate of external energy dependence.

• To boost the rational use of energy and saving of resources both for companies and

end users.


DIRECTIVES (EPBD)85



buildings.

All competences are transferred to regional

authorities.

Movable, immovable property and

intangible highlights of Galicia's cultural

heritage will be declared property of cultural

interest by Decree of the Board of Galicia,

on the proposal of the Ministry of culture,

and shall be entered in the register of



environments.

Historic environments declared of cultural

interest should develop and approve a

Special Plan of protection, rehabilitation

and conservation. The plan is the tool for

management of the historic city.

85




EFFESUS • 314678 • of 262

goods of Cultural interest in Galicia.


categorized? 86

The cultural interest statement answers to

the following classes: monument, historic

set (historic environment), historic garden,

site or historical territory, archaeological

site, place of ethnographic interest and

paleontological area.


categories.


categorized?


categories.

9.







The Technical Building Code (Código Técnico de la Edificación), hereinafter CTE, is the

regulatory framework for regulating the basic quality requirements to be met by buildings

in Spain, including their facilities to meet the basic requirements of safety and habitability,

developing expected in the second final provision of Law 38/1999, of November 5,

Building Management (Ley de Ordenación de la Edificación - LOE).

Basic Document DB HE Energy Saving (Documento Básico DB HE Ahorro de energía) is

to establish rules and procedures for fulfilling the basic requirements of energy saving.

86

For instance:







EFFESUS • 314678 • of 262

The sections of this DB correspond to the basic requirements HE 1 to HE 5.

The proper application of each section shall include compliance with the relevant basic

requirement. The correct application of all the basic document assumes that the basic

requirement is met "Energy Saving".

The goal of the basic requirement "Energy Saving" is to achieve a rational use of the

energy required for the use of buildings, reducing their consumption sustainable limits and

also get a portion of this consumption comes from renewable energy sources, as Because

of the characteristics of their design, construction, use and maintenance.

To meet this objective, the buildings are designed, constructed, used and maintained in a

way that meets the basic requirements set out in the following sections.

Basic Document "DB HE Energy Saving" parameter specifies compliance objectives and

procedures which ensures the satisfaction of basic needs and overcoming minimum

quality levels characteristic of the basic requirement of energy conservation.




Historic buildings and historic environments are excluded from minimum energy

performance requirements.



The heritage protection criteria are priority with respect to those relating to minimum

energy performance for existing buildings.

12.



Basic requirements of Basic Document DB HE Energy Saving

1. HE Basic Requirement 1: Limiting energy demand

Buildings shall have an envelope of characteristics that adequately limit the energy

demand needed to achieve thermal comfort depending on the local climate, building use

and the regime of summer and winter, as well as their insulation characteristics and

inertia, air permeability and exposure to solar radiation.

2. HE Basic Requirement 2: Performance of thermal installations

This requirement is currently developing the existing Regulation of Thermal Installations in

Buildings (Reglamento de Instalaciones Térmicas en los Edificios), RITE, and its

implementation will be defined in the building project.

3. HE Basic Requirement 3: Energy efficiency of lighting installations

Buildings shall have adequate lighting facilities to the needs of its users while optimizing

87






EFFESUS • 314678 • of 262

energy efficient use of natural light.

4. HE 4 Basic Requirement: Minimum solar contribution to domestic hot water

In buildings, a portion of the thermal energy needs derived from this demand will be met

by the incorporation therein of low-temperature solar energy.

5. HE 5 Basic Requirement: Minimum photovoltaic contribution of electricity

In buildings it is established in the CTE, will incorporate feedback systems and solar

energy conversion into electricity by photovoltaic procedures for own use or to the mains

supply.

13.


buildings?

No.












are met?

16 Are minimum energy performance requirements limited only to the renovated par ts




Through:

State Plan promote rental housing, for building ref urbishment, and regeneration

and urban renewal from 2013 to 2016.

Structured into eight programs, five of these are directly related to the topic at hand;

1. Development Programme for building refurbishment.

This program aims to finance the execution of works and maintenance and intervention

90




EFFESUS • 314678 • of 262

own fixtures and equipment, as well as proprietary elements and common spaces,

buildings of collective residential typology.

This program will be subject to actions in the buildings indicated that target Their

conservation, improved quality and sustainability, Making reasonable adjustments for

accessibility.

2. Programme to promote regeneration and urban renewal.

The building program of regeneration and urban renewal aims to finance the joint

execution of rehabilitation works on buildings and housing, development or redevelopment

of public spaces.

These works will be carried out in order to improve residential tissues and functionally

restore historic areas, urban centers, rundown neighborhoods and rural communities.

3. Programme to support the implementation of the evaluation report of the buildings.

The purpose of this program is the promotion of the implementation and generalization of

an evaluation report of the buildings including the analysis of the accessibility, energy

efficiency and conservation status thereof, through a grant to cover part of the expenses

professional fees for issuance.

4. Programme for the promotion of sustainable and competitive cities.

The purpose of this program is to fund the implementation of projects of special

importance, based on strategic topics, among others, Centres and historic centers:

Performances predominantly regenerating historic urban centers and rural helmets,

including performances residential rehabilitation and other uses that have some degree of

asset protection, public space improvement and promotion of social cohesion and

economic revitalization.

5. Program support for the implementation and management of the Plan.

The support program implementation and management of the Plan sets out the basic

conditions of funding for the creation and maintenance of computer systems for the control

and management in developing the Plan.

Ye

s

no Please explain:


funding?

X

b) advantages /


taxation?

x


x



EFFESUS • 314678 • of 262

d) information?

X


certificate? 91

X


advice?

X






The historic city of Santiago do not allow the installation of panels photovoltaic or solar.

The authorities responsible for the protection of the historical heritage are normally very

cautious in order to avoid risks.


I apologize for the delay and I will try to continue providing information in the future to

complete all the questions posed in the questionnaire.


Name: ANGEL PANERO PARDO.

Affiliations: Arquitect. Technical office. Consorcio de Santiago.



91




EFFESUS • 314678 • of 262

QUESTIONNAIRE

BACKGROUND DATA.





SWEDEN, Visby. Climate zone III.

2. Please explain how the heritage management (authorities) ar e organized and what


The Swedish National Heritage Board is the governmental agency, under Ministry of

Culture, responsible for matters concerning cultural environment preservation and

cultural heritage.

Sweden is divided into 21 counties, each of which has a County Administrative Board

and a County Governor. The Administrative Board is charged with ensuring that regional

environmental targets and environmental objectives decided by Parliament are

implemented in the county. This is done together with the municipal authorities (290

municipalities) and various sectors in society which are also responsible for the

environment. In some regions a Regional Assembly/Council also is responsible for

environmental targets and objectives as well as protection of cultural heritage. E.g. in the

region of Skåne (Malmö) it is called Skåne Regional Council.

According to the Heritage Conservation Act, the National Heritage Board overseeing

heritage sectors in the country. This includes the development of cooperation between

actors in the field and to analyze the impact of the cultural environment of change in

society. National Heritage Board is the central body of experts’ questions about Heritage

Conservation Act and is entitled to a certain extent make regulations about how the law

should be applied. County administrative boards have the practical responsibility for the

implementation of the Heritage Conservation Act, except for permitted the export of

cultural goods that is managed by different governmental agencies. Municipalities are

responsible for cultural environment issues in physical planning etc. against the

provisions of the Planning and Building Act (PBL).


a) national level

b) regional level

c) local level

d) other



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In Sweden, the implementation of the EPBD is the overall responsibility of the Ministry of

Enterprise, Energy and Communication together with the Ministry of Environment.

National Board of Housing, Building and Planning (Boverket) is the agency (under

Ministry of Health and Social Affairs(!)) for community planning, urban development,

building and housing who is the managing body for implementing the law on the energy

performance building directives. The mission of the Swedish Energy Agency (under

Ministry of Enterprise) is to promote the development of Sweden’s energy system so that

it will become ecologically and economically sustainable. Advisory not decisive.

On regional and local level: The City Council is the highest governing body of the

municipality. City Council decides which committees should exist and elect directors.

Since the municipalities themselves decide which committees they want to see it differs

around Sweden but common samples are Environment, Social Welfare and Cultural

committees. Council and committees are political appointments therefor eg. building

permits and physical planning are ultimately a political decision. However the state,

represented regional by County Administrative Board, are remittance office in physical

planning and in appealing building permits. Energy issues are treated by a technical

environment department and cultural issues under cultural environment department but

they are often organized under same unit - the city planning office - crewed by officers,

not politicians.


a) national level

b) regional level

c) local level

d) other



The heritage management, on all levels, is not invited in early stages of the process.

Therefor the influence of energy goals and consequence on heritage is often recognized

in a very late stage. The full potential of energy saving in cultural heritage is not

recognized!

National authorities (Boverket, RAÄ, Naturvårdsverket, Energimyndigheten etc) needs

more cooperation and coordination – exchange, information, fundings etc. Because

municipalities work differently with municipal developments plan and regulations there is

a difference in the protection of the built heritage that is under protection of plan- and

building act. The widths of the differences are difficult to monitor within the heritage

management sector. Therefor a national overview/inventory of buildings protected by

plan- and building act is incomplete. The buildings protected by Cultural Monuments

Ordinance and State Cultural Heritage Buildings Ordinance are under control.




EFFESUS • 314678 • of 262

http://www.swedishepa.se/

The national environmental goals under coordination of Swedish Environmental

Protection Agency is a cooperation of 16 identified goals where different authorities share

responsibility. Eg. Boverket is responsible for goal 15. “A good built environment” where

identification of the built heritage is one of the indicators, another is the municipalities

availability of antiquarian competence.

http://www.swedishepa.se/Environmental-objectives-and-cooperation/Swedens-

environmental-objectives/The-national-environmental-objectives/A-Good-Built-

Environment/

5. Please describe the national political goals for reducing emissions (CO2 ) and



Until 2020

40 percent reduction in greenhouse gas emissions.

at least 50 percent renewable energy.

20 percent energy efficiency.

The 40 percent climate target in comparison with 1990 and refers to the non-trading

sectors, ie the sectors not included EU ETS.

The program for energy efficiency in cultural and historical buildings “Spara och Bevara”

started in 2007 and focuses on older buildings with great historical value. The aim is to

develop and disseminate knowledge and technology solutions that contribute to

improving energy efficiency in historically important buildings without buildings and

equipment destroyed or corrupted. Swedish Energy Agency has allocated 40 + 40 million

during the periods 2006-2010 and 2011-2014 for the research program.


Changes in taxes and tougher economic instruments

Implementing joint EU decision

Emission reductions through green investments in developing countries or work in other

EU countries


DIRECTIVES (EPBD)92

7. a) Describe the national and regiona l


buildings.

National: Cultural Monuments Ordinance

protecting ancient monuments and

archaeological finds, historic buildings and



environments.

National: The Swedish Environmental Code

plays a major role in heritage preservation.

The Code mandates protection and

92




EFFESUS • 314678 • of 262

ecclesiastical monuments, as well as for

exports and exports of older artifacts. State

Cultural Heritage Buildings Ordinance, The

Planning and Building Act.

Regional: Municipal development plans and

regulations area (within The Planning and

Building Act)

preservation of valuable natural and historic

environments. The Code also allows for the

establishment of historic reserves on the

same terms as nature reserve.

Riksintressen och Kulturreservat see 8b.

Regional: see a


categorized? 93

A built environment (building) of

outstanding interest on account of its

cultural historic value or forming part of a

settlement of outstanding cultural value

may be designated a cultural heritage as

ecclesiastical monuments (all churches

before 1939 and modern after designation)

within the Cultural Monuments Ordinance

(Kulturminneslagen). Permanently abandon

buildings (ruins) belong to that same

Ordinance but another chapter.

Illustration: Skokloster castle - cultural

heritage of national interest (State Cultural

Heritage Buildings Ordinance –

Förordningen om statliga

byggnadsminnen).

Buildings protected in development plans.

Different methods among municipalities

how to document, and identify heritage.


categorized?

Riksintressen (environments of national

interest) and Kulturreservat (culture

reserve). 15 Unesco World Heritages.


categories.

Riksintresse: Södra Ängby, Stockholm.

Uniform design of 1930’s International Style

environment, the structure of the

development plan. Several of the buildings

in S Ängby are classified “blue” according

to Stockholm City Museum , see a.

http://www.kulturarvstockholm.se/sok/riksint

ressen/visa-riks/018001119/

Kulturreservat: Västeräng, Hälsingland a

small-scale agrar environment.

http://www.lansstyrelsen.se/gavleborg/Sv/s

amhallsplanering-och-

kulturmiljo/kulturreservat/Pages/Vasterang.

aspx

15 World Heritages:

http://www.raa.se/upplev-

kulturarvet/varldsarv/

93

For instance:







EFFESUS • 314678 • of 262

Illustration: the digital webmap of the

classicification made by Stockholm City

Museum. Blue is building of outstanding

interest, green of high cultural, architectural

value and yellow building of poisitv meaning

to the cityscape. Blue line indicate

Riksintresse, environments of national

interest, see b.

http://kartor.stockholm.se/bios/dpwebmap/c

ust_sth/kul/klassificering/DPWebMap.html

All existing buildings shall according to the

Planning and Building Act be treated by the

principle of “precaution”.

For example the famous Stockholm Town

Hall (where Nobel prize award is hold) is

only protected in the develop plan not by

the Cultural Monuments Ordinance

because the owner (City of Stockholm)

does not want to.

9.


Since 2012: In Energy chapter (Chapter 9 in building regulations – BBR Boverkets

byggregler) same requirements for energy performance as new buildings for upgrading or

modification of existing building. General guidance is that historic buildings may exceed

energy performance limits by 20%. Different limits for different climate zones in Sweden.

Protected building and historic buildings may not be altered in an unacceptably way.




The CEN standard for heating of churches and other places of worship. The future CEN

TK/346 WG8 standard for energy efficiency in historic buildings.

International conventions (like UNESCO, ICOMOS etc) are relevant but not part of the

national legal instrument, only recommendations.



EFFESUS • 314678 • of 262



See description under 9A)

Illustration: Limits energy performance for dwellings heated by electricity,

https://rinfo.boverket.se/BBR/PDF/BFS2011-26-BBR19.pdf BBR 19 chapter 9, page 140.




See description under 9a)

Since building permits and physical planning is ultimately a political decision it is unclear

how the new energy chapter will hit against the historic buildings protected in municipal

development plans. However the state, represented regional by County Administrative

Board, are remittance office in physical planning and in appealing building permits. But

administrative board is not only dealing with cultural environments – they have different

interests like traffic planning, access of water and energy, economic growth etc. Then the

cultural buildings and environments that are not protected by the Cultural Monuments

Ordinance have difficulties being acknowledged.



Riksintresse (environments of national interest) protected by The Swedish Environmental

Code or protected buildings by the Cultural Monuments Ordinance that demands

permission from County administrative boards to be altered. Measures would affect the

building or environment in an unacceptably way.

94





EFFESUS • 314678 • of 262

12.



SS-EN ISO 13789:2007 (W/m2K) Thermal performance of buildings -

Värmegenomgångskoefficienter –calculation BBR chapter 9:12, see 9a.

A om - Total area of the building component surfaces enclosing the heated indoor air (m2).

By enclosing building component means those parts of the building that limitsheated parts

of the building to the free air, ground or partially heated spaces.

13.

Is life cycle assess ment (LCA) a part of the evaluation of the energy p erformance in

buildings?

No, I don’t think so.






96





EFFESUS • 314678 • of 262

Something quite similar concept like “major renovation” does not exist in Swedish

legislation. However, due to demands triggered by significant change of use or

that the building will have a significantly extended service life.



Yes, see description under 9a.



The government has 2013 given Boverket and the Energy Agency mandated to work

together to develop a proposal for a national strategy for investment in renovations that

increase the energy performance of the national building stock. The contract is a result of

the requirements of the recently adopted Energy Efficiency Directive 2012/27/EU, EED.

The strategy will include residential and commercial buildings, both public and privately

owned.



are met?

Through energy certificates that is required of all buildings when sold or let out.

You must make an energy performance calculation when applying for building permit

( new house or changed/”major renovation”) otherwise you will not receive a permission

to start /startbesked.



Normally, only the changed building part or construction part must be covered by the

requirements in BBR. For example, it is the replacement of a part of a technical system

only the replaced part covered by the rules. However, should the change take into account

the impact of all requirements.

If a building or part of a building, such as an apartment, given a change of use may be

requested throughout the part given a change of use. For the purposes of the

requirements, also in that case consider including extent of the alteration.



Through:



funding?

x 2004-2009 energy efficient windows and

bio-fuel; 2006-2010 conversion from

electricity to renewable energy; until 2012

Solar cells and solar energy;



EFFESUS • 314678 • of 262

b) advantages /


taxation?

x CO2 taxes.

ROT –Maintenance, repair, or rebuild and

expansion, renovation. Tax credit for 50

percent of the cost of labor for the house

works performed in the home, or

recreational dwelling. The maximum tax

credit is 50 000 SEK per person per year.


x Different governmental programs eg.

LÅGAN - Applications for buildings with low

energy consumption, BELOK- technology

procurement, Hållbara städer - Delegation

for Sustainable Cities, ”OFFrot” energy

efficient measures in public premises.

d) information?

x Web platform (www.energiaktiv.se) for

building owners. Campaign and web

platform Energy smart renovation

(www.renoveraenergismart.se)


certificate? 98

x Yes, one of the instruments according to

the second national action plan for energy

efficiency from Ministry of Enterprise

http://regeringen.se/content/1/c6/17/20/99/4

8840613.pdf


advice?

x Municipal energy and climate adviser.


Research: CERBOF - Centre for Energy and Resource Efficiency in Construction and

Management; EFFSYS+ Cooling and heat pumps; National research program(Spara och

Bevara) Energy efficiency in historically valuable buildings, 40 + 40 million during the

periods 2006-2010 and 2011-2014.

18. Are there or can there be applied a req uirement for competency or experience when


Knowledge of protection laws only tested in certification of energy experts, no actual

competence in building contruction or building conservation is required.

KUL 1 and KUL 2 certification regarding antiquarian controller. An opportunity for

municipalities to demand in building permits but seldom used. Used in changes of

protected buildings.


98




EFFESUS • 314678 • of 262


Exchanging windows to more energy efficient instead of maintaining existing ones.

External insulation changes appearance, tighting facade may give a problem with humidity

if done wrongly. It also effects the air change of the buildings that must be considered.

Churches: when ceasing to heat churches and because of changed climate, humidity-

problems in the ground has created a request from several parishes to exchange the

original ground construction from wood/stone to concrete.

The sustainability of concrete is unknown and archeological remains may be covered.

Materials that are “free of maintaining” has been a common request – people do not want

to put time into maintaining and producers are trying to sell such products! That´s the

biggest threat.



Name: Therese Sonehag

Affiliations: Co2olBricks, University of Gotland, SuHiTo

Full contact details: tel +46 8 5191 8414

[email protected]




EFFESUS • 314678 • of 262

Questionnaire

BACKGROUND DATA.





Turkey

2. Please explain how the heritage manageme nt (authorities) are organized and what


Ministry of Culture and Tourism is responsible for historical and cultural heritage

protection in Turkey. Their main obligations are as following;

To investigate, protect, develop and disseminate national, spiritual, historical, cultural and

touristic values in Turkey,

To lead relevant agencies and institutes,

To improve public awareness about cultural and historical heritage.

General Directorate of Monuments and Museums is the foundation within the ministry.

The general directorate plays an important role in archaeological investigations,

restoration works, establishment of museums, ensuring the protections of

Turkish/Ottoman heritage outside Turkey, etc.

Additionally, for the maintenance, repairing, restoration, and administration of the

palaces, pavilions and museums there is Department of National Palaces, as a unit

within the structure of the General Secretariat of TBMM (Turkish Grand National

Assembly).

There are also non-governmental organizations founded for preservation of built

environment, cultural heritage and natural sources such as Foundation for the Protection

and Promotion of the Environment and Cultural Heritage, Union of Historical Towns, 'The

History, Archaeology, Art and Cultural Heritage Foundation.


a) national level

Responsible authority: Ministry of Culture and Tourism

b) regional level

Responsible authorities: Cultural and Natural Heritage Preservation Board under

Ministry; Protection Directorates of Historic Environment, Directorate of Protection,

Application and Control under urban municipalities where Cultural and Natural Heritage

Preservation Board is the decision making and Directorate of Protection, Application and

Control is the auditing body.

Additionally in Istanbul; Istanbul Cultural and Natural Sites Management Directorate,



EFFESUS • 314678 • of 262

Istanbul Heritage Committee

c) local level

d) other



Regulation of the energy performance of buildings published by Ministry of Environment

and Urbanization which is responsible for environment and urban planning in Turkey

aims to use energy and energy sources in buildings effectively and efficiently, to stop

energy waste, and to protect the environment.

Buildings are obliged to get Energy Performance Certificate provided by universities,

professional chambers and energy consulting firms whose authorities are given by

Ministry of Energy and Natural Resources, Renewable Energy Working Party.


a) national level

Responsible authority: Ministry of Energy and Natural Resources, Ministry of

Environment and Urbanization

b) regional level

Responsible authority: Provincial Directorate of Environment and Urbanization, Urban

Municipalities

c) local level

d) other



Currently, there is not any governmental cooperation between heritage management and

energy management in Turkey. However some private attempts have been realized. In

Istanbul, there is one historic building which has obtained LEED certificate.





The main political goal determined by Ministry of Energy and Natural Resources in

accordance with energy efficiency law is to reduce energy density 15 % by 2020. Some

goals are listed below;

To reduce energy demand and CO2 emission of energy efficient buildings, and to

promote sustainable and eco-friendly buildings that use renewable energy sources,

To promote thermal insulation, efficient heating and cooling systems in buildings obtained

construction permit before energy efficiency legislation,

To develop measures concerning demand side management with the aim of reducing

electrical energy density min. 20 % by 2023,

To increase the number of countrywide qualified/certified energy manager at least to



EFFESUS • 314678 • of 262

5000 and the number of energy consulting firms specialized in industry sector at least to

50 by the end of 2015,

To increase the number of novel design and/or product based on domestic R&D results

regarding energy efficiency and renewable energy resources at least 50 by the end of

2023,

To disseminate awareness and promotion activities within the scope of “National Energy

Efficiency Movement” in collaboration with public, private and non-governmental

organizations.


Actions planned to be achieved with respect to goals in question 5 are listed below;

Application of annually increasing CO2 emission tax beginning from 2015 to the buildings

which don’t have an appropriate thermal insulation based on building energy

performance legislation,

With revision of relevant legislation, making the use of credit for thermal insulation

attractive to building owners and decreasing taxes of insulation materials,

Restriction of sale of products which are not energy efficient and enabling market control;

application of smart grid, multiple counter system and step tariff based on energy and

power amount.

Authorizing energy consultancy firms to provide service in trainings, research, project and

consultancy; ensuring to provide certificate of authority after pre-licence application;

grading authorized firms,

Preparation of technology master plan in accordance with Energy R&D strategy which

will come into force via TUBITAK with collaboration of Ministry of Energy and Natural

Resources; signing coordination protocol between supportive public institution for

effective use of resources; creation of national technology inventory based on R&D

projects,

Preparation of a strategic communication plan including assessment and evaluation

activities with awareness and promotion activities where public, private and civil society

stakeholder can contribute with sense of social responsibility.


DIRECTIVES (EPBD)99



buildings.

Ministry of Culture and Tourism is

responsible for protecting historic buildings.



environments.

Ministry of Culture and Tourism is

responsible for protecting historic

environments.

99




EFFESUS • 314678 • of 262


categorized? 100

Two groups;

Historic buildings having architectural value

in global, national and local level,

Civil architectures composing urban

environment, built by traditional

construction techniques.


categories.

Palaces, ancient/mediaeval constructions,

architectural examples of religion and

military constructions, etc.

Ancient factories, warehouses, apartments,

buildings, etc.


categorized?

Two groups;

Historic environments having architectural

value in global, national and local level,

Civil architectures composing urban

environment, built by traditional

construction techniques.


categories.

Palaces, ancient/mediaeval constructions,

architectural examples of religion and

military constructions, etc.

Ancient factories, warehouses, apartments,

buildings, etc.

9.


Turkish national legislation regarding energy performance and minimum energy

requirements such as ventilation and air-conditioning systems, energy requirements for

the production of hot water has been regularized according to EPBD. All updated

specifications and standards are stated in Turkish Standards Institution (TSE) 3419. If

there is not any specification for any certain issue, standards in EPBD should be

considered.




No, there is not any other international charter, convention or principle that has relevance

for national legislation regarding energy performance in historic buildings or historic

environments.



Heat insulation calculations and applications of buildings and built environments must

obey procedures and principles described in TS 825 (Turkish Standards). The report

regarding maintenance and testing required for efficiency of lightening, electrical,

mechanical and architectural systems which affect energy performance of buildings should

100

For instance:







EFFESUS • 314678 • of 262

be prepared within the scope of the legislation and submitted to the approval.

Building owner, manager, administrative body and/or energy manager are responsible for

maintenance and testing of buildings.

The building envelop of an existing building cannot be changed in such a way that energy

performance will be influenced adversely.




There is only one restriction concerning energy performance in historic buildings and

environments, which is that feature and external appearance of historic buildings should

not be affected by energy efficiency enhancement applications.



12.



The national legal methodology for the calculation of the minimum energy performance of

buildings is defined in TS 825. The methodology in regulation of energy performance of

buildings (BEP-TR) is based on simple hourly method which has easier algorithm

compared to dynamic method.

13.


buildings?

No






Major renovation includes consolidation, liberation, reintegration, renovation,

reconstruction, and moving. Substantial repair of existing buildings must meet TSE 825

energy requirements.



Yes. Minimum energy performance requirements depend on the function of the buildings.


101







EFFESUS • 314678 • of 262


15. After renov ation or other situations (see question 14), how ca n the authorities


are met?

Ministry and/or organizations authorized by the ministry perform controls concerning

energy consuming equipments and periodic maintenance of the buildings.



Whole building



Through:

(They are not specific for

historic buildings)



funding?

x Provided by the Scientific and

Technological Research Council of Turkey

(TUBITAK)

b) advantages /


taxation?

x


x Turkey Sustainable Energy Financing

Facility (TURSEFF), European Bank for

Reconstruction and Development (EBRD),

Kreditanstalt für Wiederaufbau (KfW),

Global Environment Fund (GEF), United

Nations Development Programme (UNDP),

Agence Française de Développement

(AFD)

d) information?

x Seminars, workshops, conferences

organized by municipalities, ministries,

Istanbul Chamber of Commerce, Istanbul

Chamber of Industry, etc.



EFFESUS • 314678 • of 262


certificate? 105

x Energy performance certificate is provided

by authorized organizations which are

authorized architect and engineer for new

buildings, energy consultancy firms for

existing buildings.


advice?

x Energy consultancy firms


Useful links:

http://www.kultur.gov.tr/?_dil=2 Republic of Turkey Ministry Culture and Tourism

http://www.tarihikentlerbirligi.org/english/ Union of Historical Towns

http://www.cekulvakfi.org.tr/we-exist-through-nature-and-culture Foundation for the

Protection and Promotion of the Environment and Cultural Heritage

http://www.istanbulheritagecommittee.com/ Istanbul Heritage Committee

http://www.millisaraylar.gov.tr/portalmain-en/Default.aspx Department of National Palaces

http://www.enerji.gov.tr/index.php?dil=en Ministry of Energy and Natural Resources



Yes, there can be applied requirements for competency or experience when working with

historic buildings and energy efficiency. Authorized architect and/or engineer can work

with historic buildings and energy efficiency.



Even though energy performance legislation came into force in Turkey, there are not many

implementations concerning heritage protection and energy efficiency.

20. Please give any further comm ents or suggestions.


Name: Pınar Çakır Hatır

Affiliations: Sampas Nanotechnology



105




EFFESUS • 314678 • of 262

QUESTIONNAIRE

BACKGROUND DATA.





The sovereign state is the United Kingdom of Britai n and Northern Ireland (UK),

consisting of the four countries England, Northern Ireland, Scotland and Wales.

2. Please exp lain how the heritage management (authorities) are organized and what


This questionnaire has been completed with the heri tage management of the

historic environment in mind, as opposed to managin g heritage in collections, such

as archives, galleries and museums.

The heritage-management authorities, listed under i tem 2b below, are charged with

safeguarding and promoting the historic environment in the UK. They do this by

managing statutory heritage-designation and -protec tion systems, caring and

making accessible historic places in state care, pr oviding financial assistance and

technical advice and research, and outreach and tra ining.

Heritage designations, used in the UK, include: lis ted buildings; scheduled

monuments; conservation areas; designed landscapes and gardens; battlefields;

etc. For details, please see item 8 below.


a) national level

Not applicable, as heritage management is a ‘devolv ed matter’

b) regional level

England: English Heritage (non-departmental public body reporting to UK

government)

Northern Ireland: Department of the Environment, No rthern Ireland Executive

Scotland: Historic Scotland (agency of the Scottish Government)

Wales: Cadw (agency of the Welsh Government)



EFFESUS • 314678 • of 262

c) local level

The planning departments of local authorities manag e the heritage-protection

system ‘on the ground’ by administrating applicatio ns for Listed Building Consent,

Conservation Area Consent etc. In certain situation s, local authorities consult with

the relevant authority listed under item 2b above.

Where a building is in the ownership of a local aut hority, heritage management for

the concerned building is the responsibility of the authority listed under item 2b

above.

Heritage management of scheduled monuments is the r esponsibility by the

authorities listed under item 2b above.

d) other

No comments

3. Explain how the authorities which regulate energy p erformance in buildings (energy

management) are organized and their obligations.

The building regulations for England, Northern Irel and, Scotland and Wales set

minimum energy-performance requirements for newly c onstructed buildings and

for alterations, extensions and conversions (i.e. c hange of use) of existing

buildings.

Please note that in England, Northern Ireland and W ales the terms ‘building

regulations’ and ‘building control’ are used, but n ot ’building standards’; whereas

in Scotland the term ‘buildings standards’ is used to describe regulatory

requirements as well as the authority controlling t hem. Scotland’s building

standards are defined in, and form therefore part o f, Scotland’s building

regulations.

In this questionnaire the term ‘building standards’ has only been used where is

specifically refers to a Scottish context, otherwis e the term ‘building control’ has

been used.


a) national level

Department of Energy and Climate Change, UK governm ent (setting framework

policies)



EFFESUS • 314678 • of 262

b) regional level

England and Wales (also see ‘Wales’ below): Departm ent for Communities and

Local Government, UK government

Northern Ireland: Department of Finance and Personn el, Northern Ireland Executive

Scotland: Building Standards Division, Scottish Gov ernment

Wales (also see ‘England and Wales’ above): Enviro nmental and Sustainable

Development Directorate, Welsh Government

c) local level

The building-control departments of local authorit ies manage the building-control

system ‘on the ground’, for example by administrati ng applications for building

permission (in England, Northern Ireland and Wales) and building warrants (in

Scotland).

d) other

Within England and Wales, an applicant has the oppo rtunity to employ an

approved, private building-control organisation as opposed to the local authority.

In Scotland, an applicant has the opportunity to em ploy an approved private

building-standard organisation for some building-re gulation requirements,

including requirements concerned with energy perfor mance, as opposed to the

local authority.

4. Please describe the coopera tion between heritage management and energy


Heritage-management and building-control authoritie s consult with each other

when developing new governmental policies and legis lation. However, the division

into planning / heritage-conservation on one side a nd building control on the other

side means that ‘on the ground’ building developers / owners need to negotiate

with both authorities to find solutions satisfying the requirements of both

authorities.


An example for such cooperation is that the Buildin g Standard Division of the

Scottish Government had invited Historic Scotland i n 2012 to comment on

proposed 2013 amendments to Scotland’s building reg ulations.

Similarly, English Heritage has been part of previo us working groups for revisions

to certain parts of the English and Welsh buildings regulations under the UK

government’s Building Regulations Advisory Committe e.



EFFESUS • 314678 • of 262

Another example of cooperation is Historic Scotland’s publication Conversion of

traditional buildings: application of the Scottish Building Standards. This

publication was developed together with the Scottis h Government’s Building

Standards Division (and its predecessors) and has f or historic and traditional

buildings the same guidance status as the Technical Handbooks of the Building

Standards Division, namely illustrating solutions w hich comply with building

regulations.

http://www.historic-scotland.gov.uk/conversionoftraditionalbuildings1and2.pdf




Legislation has been introduced setting targets for the reduction of greenhouse gas

emissions by 2020 and 2050 against a baseline of 19 90 levels. For the UK, these

targets are set as 34% for 2020 and 80% for 2050. I n addition to this, a 2020 target of

42% is set for Scotland.

The 34% target is set by the Climate Change Act 200 8 (2020 Target, Credit Limit and

Definitions) Order 2009. The 80% target is set by t he Climate Change Act 2008.

Scotland’s 42% target is set by Climate Change (Sco tland) Act 2009.

No specific targets are in place for existing build ings, historic buildings or historic

environments.

6. Please describe how the goals in question 5 are pro posed to be achieved.

To help achieving the set targets for reductions of greenhouse-gas emissions

through reducing carbon-dioxide emissions from buil dings, legislation and

governmental support schemes have been put in place , as described below.

Regarding concerned legislation, the reduction of c arbon-dioxide emissions from

buildings is generally regulated through the buildi ng regulations for England,

Northern Ireland, Scotland and Wales. The building regulations set minimum

requirements for the energy performance for newly c onstructed buildings and for

alterations, extensions and conversion (i.e. change of use) of existing buildings.

The building regulations generally offer a flexible and practical approach to the

improvement of the energy efficiency in traditional and historic buildings.

In Scotland, the Sullivan Report, published in 2007 and entitled A low carbon

Building Standards strategy for Scotland, set out recommendations to drive

forward standards and innovation. This included the assessment and improvement



EFFESUS • 314678 • of 262

of existing buildings through regulation or incenti ves and it included the need for

building regulations to continue to set minimum sta ndards applicable where

building is proposed.

http://www.scotland.gov.uk/Resource/Doc/217736/0092 637.pdf

As part of the Scottish government’s commitment to reduce greenhouse-gas

emissions (as noted in item 5 above), the Climate C hange (Scotland) Act 2009

introduced a duty for the government to make regula tion requiring the assessment

and improvement of existing buildings. Section 64 f or that act addresses dwellings,

whilst section 63 addresses non-domestic buildings. Following consultation on

initial proposals under section 63 in 2012, draft r egulations will be issued for

consideration and comments in spring 2013 with the proposal that regulations be

introduced in 2013.

Further to putting relevant legislation in place, g overnments in the UK have also

implemented a variety of support schemes to help ac hieving set the emission-

reduction targets. Examples of such schemes are lis ted below.

The UK government has implemented in late 2012 the Green Deal, a financial

instrument supporting the energy-efficiency retrofi t of existing buildings, by

allowing building owners to improve their buildings with no upfront capitals cost

and instead pay for the improvement measures by ins talments on their future

electricity bills. As part of the Green Deal, finan cial subsidies are being made

available through the so-called Energy Company Obligations for some retrofit

measures in ‘vulnerable properties’, for example, s olid wall insulation in historic

buildings.

Prior to the Green Deal, other governmental schemes have been available, such as

Feed-in Tariffs (FIT) for renewable energy generati on; the Renewable Heat Incentive

(RHI); Carbon Reduction Commitment Energy Efficienc y Scheme (CRC).

Further to this various initiatives have been intro duced, mostly on regional and

local levels, such as free insulation retrofit sche mes, for example:

http://www.edinburgh.gov.uk/info/1031/improvements_ and_repairs-

general_information_and_advice/1735/free_loft_and_c avity_wall_insulation/1



EFFESUS • 314678 • of 262


DIRECTIVES (EPBD)106



buildings.

Historic buildings are, when heritage-

designated through ‘listing’, protected

through the requirement for seeking

Listed Building Consent prior to

commencement of any construction

works which might impact on the

‘character’ of the building. This

protection is to manage change in the

historic environment, rather than

preventing change from happening.



environments.

Historic environments are protected

through the planning system by

heritage-designations, such as

conservation area (i.e. heritage area),

battlefield site, designated garden or

design landscape, etc. This protection is

to manage change in the historic

environment, rather than preventing

change from happening.


categorized? 107

Historic buildings are not typically

categorised.

Listed buildings are categorised into 3

groups, which are sometimes described

as indicating if the building is of

international or national importance; of

regional importance; or of local

importance. However, these descriptions

are legally not set down.

England and Wales: Grades I, II* and II

Northern Ireland: Grades A, B+ and B1

Scotland: Categories A, B and C

Wales: see ‘England and Wales’ above


categorized?

Historic environments are categories, for

example, by inclusion in inventories for

conservation areas; gardens and

designed landscapes; and battlefields.


categories.

Guildhall Conservation Area, London,

England (example of a conservation

area)

Falkland Palace, Falkland, near Cupar,

Fife, Scotland (example of a designated

‘garden and designed landscape’;

Falkland Palace is also scheduled

monument and a listed building)

Bannockburn, near Stirling, Scotland

106


For instance:







EFFESUS • 314678 • of 262

Specialist categorisation exists e.g. for

religious buildings.


categories.

Category A: Forth Bridge (i.e. the railway

bridge), Edinburgh and Fife, Scotland

Category B: Canongate Housing,

Edinburgh, Scotland

Category C: Craigend Castle,

Dunbartonshire, Scotland

(example of both a heritage -designated

‘garden and designed landscape’ and a

heritage-designated ‘battlefield site’)

9.


Through implementation of the EPBD into national le gislation, in the form of, by

example, the Climate Change Act 2008 (for the UK), the Climate Change (Scotland)

Act 2009 and the Energy Performance of Buildings (S cotland) Regulations 2008.


relevance for national legislation regarding energy performance in historic buildings

or historic environments.

None with a specific focus on energy performance in historic buildings or historic

environments

10. Describe the national legal requirements for minimu m energy per formance in


There are no minimum energy-performance requirement s for existing building to

date, except where existing buildings are altered, extended or converted (i.e. change

of use). In such cases, building-regulations requir ements must to be met. However,

for historic and traditional buildings, meeting bui lding-regulation requirements must

only be met as far as is reasonably practical.

11. a) In what ways are historic buildings and historic environments 108 exclu ded from or



108




EFFESUS • 314678 • of 262

As stated in item 10. above, there are no minimum e nergy -performance

requirements for existing building, except where ex isting buildings are altered,

extended and converted (i.e. change of use). There are no exemptions for this

requirement for historic buildings, including liste d buildings, but with the exception

of buildings heritage-designated as scheduled monum ents.

However, recognition is given for traditional and h istoric buildings in that some

building-regulation requirements must be met only a s far as is reasonably practical.

This means that meeting requirements (in full) migh t not be necessary for such

buildings where this would impact negatively on the character of a building,

including its heritage significance. An example for this is insulating solid walls,

where it may not be appropriate to aim for a U-valu e of 0.3 W/(m 2·K), as prescribed

by the building regulations. However, it is require d to demonstrate that the level of

improvement in each area of the building has been f ully considered. For example,

where a building is being upgraded, there may be gr eater scope for improvement in

building services than in fabric or there may be mo re scope for fabric improvements

in parts of the buildings that are later additions or are of lesser heritage significance .



In Scotland, for example, buildings which are herit age-designated as ‘scheduled

monuments’ are excluded from having to meet buildin g regulations. Please note that

heritage designation as ‘scheduled monument’ is dis tinct from heritage designation

as a ‘listed building’, although a building can be given both designations.

12.



The national calculation method (NCM) in the UK is as listed below:

For new-build domestic: SAP2009 (derived from BREDE M)

For existing domestic: RdSAP

For new-build and existing non-domestic buildings: SBEM

https://www.gov.uk/standard-assessment-procedure

http://www.bre.co.uk/sap2009/

http://www.ncm.bre.co.uk/

109





EFFESUS • 314678 • of 262

Additionally, dynamic simulations models (DSM) can be used as an alternative to

SBEM for complex buildings. Equally, an alternative simple-method is available for

buildings in England, Northern Ireland and Wales.

Each of these NCMs is used to access current perfor mance and, where required by

regulations, anticipated future performance.

Please note that the exact procedure on how to use the legal methodologies varies

between England, Northern Ireland, Scotland and Wal es.

13.


buildings?

No

14. In the se questions we would like to know in which situati ons the requirements for



energy performance requirements in buildings come i nto force when it is applied for

“major renovation”? 111 Please explain.

The term ‘major renovation’ is current not defined in UK legislation.


when the use/function of a building is changed? Ple ase explain.

Change of use / function of a building is referred to in the UK as ‘building

conversion’. Minimum energy-performance requirement s come into force when a

building is converted. For historic and traditional buildings, many building-

regulation requirements have to only be met as far as is reasonably practical.



Where existing buildings are altered and/or extende d, minimum energy-performance

requirements must be met. However, meeting these re quirements might be

restricted to the affected building elements and mi ght, for historic and traditional

buildings, be restricted to as far as is reasonably practical.

15. After ren ovation or other situations (see question 14), how can the authorities

control whether the legal requirements for minimum energy performance actually

are met?

Where works are subject to building regulations, it is the responsibility of the

relevant person (normally the building warrant appl icant or building owner) to

111




EFFESUS • 314678 • of 262

ensure that works comply. Where works are the subje ct of a building warrant, the

applicant must certify this on completion of the wo rks and the local authority will

carry out ‘reasonable inquiry’ before accepting suc h a certificate.



Minimum energy-performance requirements are limited to the renovated parts,

unless the building also under-goes a conversions ( i.e. a change of use) when the

whole building must meet the set requirements. Howe ver, for historic and traditional

buildings must only meet the set requirements as fa r as is reasonably practical.

17. In what ways are the national leg al requirements for minimum energy performance


Through:



funding?

Through regional programmes, such as

free insulation retrofits (however, these

programmes are not specific to historic

buildings or historic environments)

b) advantages /


taxation?

No advantage for energy -efficiency retrofit;

advantages for replacing existing building

stock through newly constructed buildings

by VAT exemption for the latter, but not for

the repair of existing buildings.


With the Green Deal the UK government

has implemented in late 2012 a financial

instrument for supporting energy-

efficiency retrofit of existing buildings. It is

too early to judge if the Green Deal will be

seen by a majority of the population as

being financially attractive. As part of the

Green Deal so-called Energy Company

Obligations provide subsidies for the

installation of certain retrofit measures in

certain building types (including historic

buildings).

d) information?

Information from organisations such as

Carbon Trust, Energy Saving Trust,

Society for the Protection of Ancient

Buildings, Institute of Historic Building

Conservation, English Heritage, Historic

Scotland.

The UK government is commissioning a



EFFESUS • 314678 • of 262

guidance tool to assist Green Deal

specifiers and installer in the making of

appropriate decisions about whether to

install specific Green Deal measures. This

is targeted for use on certain building

types.


certificate? 112

Energy Performance Certificates (EPCs)

are required on newly constructed

buildings, buildings for sale and rental and

for certain categories of public buildings.

This is not specific to historic buildings or


In England, building regulations do not

require EPC for listed buildings. However,

EPC for listed buildings are, for example,

required to qualify for improvement

measures under the Green Deal scheme.

In Scotland, building regulations do

require EPC for listed buildings.

In addition, the Energy Act 2011 contains

provisions for a minimum standard for

private rented housing and commercial

rented properties from 2018, and the UK

government intends for this to be set at an

EPC rating of ‘E’.


advice?

as item 17d above


In England, Display Energy Certificates (DECs) are required for all public buildings

(including historic buildings) with a floor area be tween 500 and 1,000 m 2 every

decade and over 1,000 m 2 every year. This does not apply to Scotland.



There are professional building-conservation and -s ustainability accreditation-

schemes for architects, structural engineers, etc. There are accreditation schemes

for EPC and Green Deal assessors. There are no comb ined accreditations for energy

efficiency in historic buildings.

There are no legal requirements for using conservat ion- or sustainability-accredited

112




EFFESUS • 314678 • of 262

personnel for the planning or implementation of ene rgy -efficiency retrofits for

historic buildings.

Green Deal assessments must be carried out by perso nal accredited through the

Green Deal. Green Deal providers are obliged to ass ess whether a property is a

‘vulnerable property’ (which includes historic buil dings) and to seek appropriate,

specialist advice before recommending the measures to be installed. They also have

to ensure that installers are competent in such ins tallations.

Please note that in the UK there is no protection o f function in the construction

industry other than ‘architect’.


efficient measures and their compatibility with her itage protection legislation.

Over-cladding of the exterior of a building with ex ternal wall insulation is often

considered unacceptable in the case of historic bui ldings, as this would impact

negatively on the character and thereby the heritag e significance of the building.

Installing double glazing is a contentious issue fo r aesthetic reasons and because of

the loss of original window frames and glass. This can be resolved by a mixture of

refurbishment to reduce draughts, secondary glazing to preserve the exterior look of

the window and the resurrection of original shutter s.


No comments


Name: Carsten Hermann

Affiliations: Historic Scotland (an agency of the Scottish Govern ment)

Full contact details: Longmore House, Salisbury Place, Edinburgh EH9 1SH, UK

+44 131 668 8927, [email protected]

Your questionnaire respondee would like to thank, f or comments and input into this

questionnaire, Richard Atkins (sustainability-accre dited architect on behalf of the

Royal Incorporation of the Architects in Scotland); Richard Cartwright (Institute of

Historic Building Conservation), Mairi Davies (Hist oric Scotland), Anne-Marie

Hughes (Scottish Government’s Building Standards Di vision), Steven Jones (UK

government’s Department of Energy and Climate Chang e), Soki Rhee-Duverne

(English Heritage) and Dennis Rodwell (conservation architect, historic environment

consultant and EFFESUS project partner).



EFFESUS • 314678 • of 262

8.3 Section 3: EU No 244/2012: Cost-optimal methodology framework

IV

(Notices)

NOTICES FROM EUROPEAN UNION INSTITUTIONS, BODIES, OFFICES AND AGENCIES

EUROPEAN COMMISSION

Guidelines accompanying Commission Delegated Regulation (EU) No 244/2012 of 16 January 2012 supplementing Directive 2010/31/EU of the European Parliament and of the Council on the energy performance of buildings by establishing a comparative methodology framework for calculating cost-optimal levels of minimum energy performance requirements for buildings and building

elements

(2012/C 115/01)

TABLE OF CONTENTS

Page

1. OBJECTIVES AND SCOPE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

2. DEFINITIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

3. ESTABLISHMENT OF REFERENCE BUILDINGS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3

4. IDENTIFICATION OF ENERGY EFFICIENCY MEASURES, MEASURES BASED ON RENEWABLE ENERGY SOURCES OR PACKAGES/VARIANTS OF SUCH MEASURES FOR EACH REFERENCE BUILDING . . . . . . . . . 5

4.1. Possible energy efficiency measures and measures based on renewable energy sources (and their packages and variants) to be taken into account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

4.2. Methods for reducing combinations and thus calculations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4.3. Indoor air quality and other comfort-related issues . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

5. CALCULATION OF THE PRIMARY ENERGY DEMAND RESULTING FROM THE APPLICATION OF MEASURES AND PACKAGES OF MEASURES TO A REFERENCE BUILDING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

6. CALCULATION OF THE GLOBAL COST IN TERMS OF NET PRESENT VALUE FOR EACH REFERENCE BUILDING . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13

6.1. The concept of cost optimality . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 14

6.2. Cost categorisation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15

6.3. Gathering of cost data . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17

6.4. The discount rate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6.5. Basic listing of cost elements to be taken into account for calculating initial investment costs of buildings and building elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18

6.6. Calculation of periodic replacement cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20

6.7. Calculation period versus estimated lifecycle . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21

6.8. Starting year for the calculation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

EN 19.4.2012 Official Journal of the European Union C 115/1

9. Calculation of residual value . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

6.10. Cost development over time . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22

6.11. Calculation of replacement costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

6.12. Calculation of energy cost . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

6.13. Treatment of taxation, subsidies and feed-in tariffs in the cost calculation . . . . . . . . . . . . . . . . . . . . . . 23

6.14. Inclusion of earnings from energy production . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 23

6.15. Calculation of disposal costs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

7. DERIVATION OF A COST-OPTIMAL LEVEL OF ENERGY PERFORMANCE FOR EACH REFERENCE BUILDING 24

7.1. Identification of the cost-optimal range . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 24

7.2. Comparison with current requirements at Member State level . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 25

8. SENSITIVITY ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

9. ESTIMATED LONG-TERM ENERGY PRICE DEVELOPMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26

1. OBJECTIVES AND SCOPE

In accordance with Article 5 of, and Annex III to, Directive 2010/31/EU of the European Parliament and of the Council of 19 May 2010 on the energy performance of buildings ( 1 ), the Commission Delegated Regulation (EU) No 244/2012 ( 2 ) supplements Directive 2010/31/EU of the European Parliament and of the Council on the energy performance of buildings by establishing a comparative methodology framework for calculating cost-optimal levels of minimum energy performance requirements for buildings and building elements (hereinafter ‘the Regulation’).

The methodology specifies how to compare energy efficiency measures, measures incorporating renewable energy sources and packages of such measures in relation to their energy performance and the cost attributed to their implementation and how to apply these to selected reference buildings with the aim of identifying cost-optimal levels of minimum energy performance requirements. Annex III to Directive 2010/31/EU requires the Commission to provide guidelines to accompany the comparative methodology framework with the aim of enabling the Member States to take the necessary steps.

This document constitutes the guidelines as intended by Annex III to Directive 2010/31/EU. While these guidelines are not legally binding, they provide relevant additional information to the Member States and reflect accepted principles for the cost calculations required in the context of the Regulation. As such, the guidelines are intended for facilitating the application of the Regulation. It is the text of the Regulation which is legally binding and which is directly applicable in the Member States.

For ease of use by the Member States, this document closely follows the structure of the methodology framework as laid down in Annex I to the Regulation. The guidelines will – unlike the Regulation itself – be reviewed periodically as experience is gained with the application of the methodology framework, both by the Member States and by the Commission.

2. DEFINITIONS

Some of the definitions contained in Article 2 of the Regulation might benefit from further clarification.

For the purposes of the definition of global costs, the cost of land is excluded. However, if a Member State so wishes, the initial investment costs, and hence also the global costs, could take into account the cost of the useful floor area that is needed to install a certain measure, thus introducing a ranking of measures according to the space they occupy.

Primary energy for a building is the energy used to produce the energy delivered to the building. It is calculated from the delivered and exported amounts of energy carriers, using primary energy conversion factors. Primary energy includes non-renewable energy and renewable energy. If both are taken into account it can be called total primary energy.

EN C 115/2 Official Journal of the European Union 19.4.2012

( 1 ) OJ L 153, 18.6.2010, p. 13. ( 2 ) OJ L 81, 21.3.2012, p. 18.

As part of the definition of global costs, a Member State may choose to introduce other external costs (such as environmental or health costs) besides carbon pricing into the calculation of the macroeconomic cost optimum.

For the purpose of the calculation of annual costs, the methodology as presented by the Commission does not include a specific category to cover the cost of capital as it was considered to be captured already by the discount rate. If a Member State wants to specifically capture the payments that occur over the entire calculation period, Member States could for example include capital costs within the category of annual costs as to ensure that they are also discounted.

The method for calculating the useful floor area is to be defined at national level. It should be clearly reported to the Commission.

For the purpose of the cost-optimal evaluation, the non-renewable part of primary energy is considered. It has to be noted that this does not contradict the definition of primary energy given in the Directive — for overall building performance, both the non-renewable part and the total quantity of primary energy related to building operation should be reported. The corresponding primary energy (conversion) factors are to be set at national level, taking into account Annex II to Directive 2006/32/EC. ( 1 )

Energy efficiency measures can be a single measure or constitute a package of measures. In its ultimate form a package of measures will constitute a variant of a building (= a full set of measures/packages needed for the energy-efficient supply of a building and including measures on the building envelope, passive techniques, measures on building systems and/or measures using renewable energy sources).

Energy costs include all costs for energy uses as covered by Directive 2010/31/EU associated with all typical uses in a building. Energy used for appliances (and their cost) is therefore not included, although Member States are free to include also these in their national application of the Regulation.

3. ESTABLISHMENT OF REFERENCE BUILDINGS

In accordance with Annex III to Directive 2010/31/EU and Annex I(1) to the Regulation, Member States are required to define reference buildings for the purpose of the cost-optimal methodology.

The main purpose of a reference building is to represent the typical and average building stock in a certain Member State, since it is impossible to calculate the cost-optimal situation for every individual building. Hence, the reference buildings established ought to reflect as accurately as possible the actual national building stock so that the methodology can deliver representative calculation results.

It is recommended that reference buildings be established in one of the two following ways:

(1) Selection of a real example representing the most typical building in a specific category (type of use with reference occupancy pattern, floor area, compactness of the building expressed as a envelope area/ volume factor, building envelope structure with corresponding U-value, technical services systems and energy carriers together with their share of energy use).

(2) Creation of a ‘virtual building’ which, for each relevant parameter (see 1) includes the most commonly used materials and systems.

The choice between these options should be made on the basis of expert enquiries, statistical data availability, etc. It is possible to use different approaches for different building categories. Member States should report how the building category reference case was chosen (see also point 1.4 of reporting template as given in Annex III to the Regulation).

Member States are free to use and adjust already existing catalogues and databases of reference buildings for the purpose of the cost-optimal calculations. Moreover, work carried out under the Intelligent Energy Europe programme can be used as input, in particular:

— TABULA – Typology approach for building stock energy assessment: http://www.building-typology.eu/ tabula/download.html

— ASIEPI Project – A set of reference buildings for energy performance calculation studies: http://www. asiepi.eu/wp2-benchmarking/reports.html ( 2 )


( 1 ) Directive 2006/32/EC of the European Parliament and of the Council of 5 April 2006 on energy end-use efficiency and energy services and repealing Council Directive 93/76/EEC (OJ L 114, 27.4.2006, p. 64).

( 2 ) The ASIEPI project only defines the buildings’ geometry and would not be sufficient for the purposes of the calculation.

http://www.building-typology.eu/tabula/download.html

http://www.building-typology.eu/tabula/download.html

http://www.asiepi.eu/wp2-benchmarking/reports.html

http://www.asiepi.eu/wp2-benchmarking/reports.html

The Regulation asks Member States to identify at least one reference building for new buildings and at least two for existing buildings subject to major renovation for each of the following categories:

— Single-family buildings;

— Apartment blocks/multi-family buildings;

— Office buildings; and

— The other non-residential categories listed in Annex I(5) to Directive 2010/31/EU for which specific minimum performance requirements exist.

The Regulation gives Member States a choice to either:

— Establish reference buildings (again one for new built, two for existing) for every category of non- residential buildings separately, at least for those for which minimum energy performance requirements are in place; or

— Define reference buildings for the other non-residential categories in a way that one reference building represents two or more categories. In this way a reduction of necessary calculations and hence administrative burden can be achieved. It might even be possible to derive all reference buildings of the non- residential sector from a basic reference building for offices.

That means that if a Member State defines office buildings in a way that these reference buildings could be applicable to all other non-residential building categories that Member State would need to define 9 reference buildings in total. If not, the number of reference buildings would obviously be higher.

To note: In accordance with Annex III to Directive 2010/31/EU and Annex I(1) to the Regulation, Member States are not obliged to establish subcategories, but only to establish reference buildings. However, dividing a building category into subcategories can be an intermediate step in determining the most representative reference buildings.

Different building stocks might require different categorisation. In one country, differentiation based on construction materials might be most appropriate, while in another country this may be the age of the building. It will be important for the report to the Commission to indicate clearly why the chosen criteria guarantee a realistic picture of the building stock. With regard to the existing building stock, the importance of the average characteristics is underlined.

The following remarks can be made on criteria for sub-categorisation of building categories:

Age This criterion might make sense in a country where so far the existing building stock has not undergone refurbishment and hence the original age of the building still constitutes a good proxy for the energy performance of the building. In countries where the building stock has already to a large extent been renovated, the age groups have become too diverse to be captured simply by age.

Size Size categories are interesting insofar as they can represent subcategories for both energy and cost-related characteristics.

Climate conditions

In several Member States, national requirements distinguish between different climate zones or regions of the country.

It is recommended that if this is the case the reference buildings should be representative of the specific climate zones or regions and that the energy consumption of the reference buildings should be calculated for each climate zone.

It is recommended that climate conditions be described and used in accordance with EN ISO 15927- ‘Hygrothermal performance of buildings - Calculation and presentation of climatic data’ applied as a country average or per climate zone, if this distinction is made in the national building regulation. Heating degree days are available from EUROSTAT. It is recommended that where appropriate, cooling degree days should also be included (specifying the base temperature and time step used for the calculation).


Orientation and shading

Depending on the geometries of the building and size and distribution/ orientation of window surfaces, the orientation of a building as well as shading (from nearby buildings or trees) can have a significant influence on energy demand. It is however difficult to derive an ‘average’ situation from this. It might make sense to define a ‘likely’ situation for a building situated in the countryside and a likely situation for one in an urban setting if this criterion is considered in the national minimum requirements.

The typical location of the reference building(s) should be reflected also in the impacts of orientation, solar gains, shading, demand for artificial lighting, etc.

Construction products in load carrying and other structures

Construction products in the envelope contribute to the thermal performance and have an impact on the energy demand of a building. For example, a high building mass can reduce the energy demand for cooling in summer. It is probable that a distinction needs to be made between different kinds of buildings in the definition of reference buildings (e.g. massive buildings and light-weight constructions or full glass façade vs. partly glass facade) if reasonable shares of both are found in a specific country.

Heritage protected buildings

Member States who have not excluded heritage protected buildings (Article 4(2) of Directive 2010/31/EU) might wish to establish subcategories that reflect the characteristics of typically protected buildings.

As a general rule it can be assumed that the building stock will be reflected more realistically with a higher number of reference buildings (and subcategories), but there is obviously a trade-off between the administrative burden resulting from the calculation exercise and the representativeness of the building stock. If the building stock is diverse, more reference buildings will probably be required.

The approach taken towards establishing reference buildings for new and existing buildings is basically the same, with the exception that for existing buildings the description of the reference building provides a full qualitative description of the typical building and of the typical building systems installed. When it comes to new buildings, the reference building establishes only the basic building geometry, typical functionality and typical cost structure in the Member State, geographic location and indoor and outdoor climatic conditions.

4. IDENTIFICATION OF ENERGY EFFICIENCY MEASURES, MEASURES BASED ON RENEWABLE ENERGY SOURCES OR PACKAGES/VARIANTS OF SUCH MEASURES FOR EACH REFERENCE BUILDING

In accordance with Annex III to Directive 2010/31/EU and Annex I(2) to the Regulation, Member States must define energy efficiency measures to be applied to the established reference buildings. Measures that are submitted to the calculation will have to cover the technologies listed under Article 6 of Directive 2010/31/EU and repeated under Article 7 (last paragraph), namely decentralised supply, cogeneration, district heating and cooling and heat pumps. In accordance with paragraph 3 of Annex I(2) to the Regulation, Member States must also include measures based on renewable energy sources in the calculation exercise. It should be noted that RES-based solutions might not solely linked be to achieving the nearly zero energy target.

Moreover, measures acting on one system can affect the energy performance of another system. For example, the insulation level of the envelope affects the capacity and dimensions of the building systems. This interaction between different measures has to be addressed when defining packages/variants.

It is therefore recommended that measures be combined in packages of measures and/or variants, since meaningful combinations of measures can create synergy effects that lead to better results (regarding costs and energy performance) than single measures. Variants are defined for the purpose of the delegated act as a "global result and description of a full set of measures/packages applied to a building that can be composed of a combination of measures on the building envelope, passive techniques, measures on building systems and/or measures based on renewable energy sources".

Whilst it might therefore be difficult to exactly draw the line between a package of measures and a variant, it is clear that the variant refers to complete sets of solutions needed to fulfil existing high performance buildings etc. Variants to be considered can include well-established concepts that are used to construct e.g. a certified Eco-labelled building, a Passive house, a 3-litre house or any other set of measures that has been


established to achieve very high energy efficiency. It should however be noted that the purpose of the cost optimal methodology is to ensure a fair competition between different technologies and is not confined to calculating the global cost of already established and proven packages/variants.

Within a package/variant of measures, efficiency measures that are cost-effective may allow the inclusion of other measures that are not yet cost-effective, but which could add substantially to primary energy usage and CO 2 savings associated with the total building concept – provided that the overall package still provides more benefits than costs over the lifetime of the building or building element.

The more packages/variants are used (and variations of the measures included in the assessed package), the more accurate the calculated optimum of the achievable performance will be.

The determination of the finally selected packages/variants will probably be an iterative process in which a first calculation of selected packages/variants reveals the need to add further packages to allow finding out where exactly sudden "jumps" in global costs occur and why these occur. Hence it might be necessary to define an additional package to find out which technology is responsible for the higher global cost.

To describe each package/variant, information on energy performance is needed. Table 3 of the reporting template annexed to the Regulation provides an overview of the basic set of technical parameters necessary to perform an energy performance calculation.

It is recommended that when Member States fix their national calculation methodology, the order of appearance of the defined measures/packages/variants should not predetermine the outcome. Thus Member States should try to avoid establishing rules whereby a measure on the building envelope is always applied first and only then is a measure on a building system allowed.

4.1. Possible energy efficiency measures and measures based on renewable energy sources (and their packages and variants) to be taken into account

Many measures could be considered as a starting point for establishing measures/packages/ variants for the calculation exercise. The list provided below is not comprehensive. Nor can it be assumed that all measures will be equally appropriate in different national and climatic contexts.

Against the background of Article 9 of Directive 2010/31/EU and its definition of a nearly zero-energy building, which covers both energy efficiency and also renewable energy sources, it will be necessary to also consider measures based on renewable energy sources for the calculation exercise. These measures will in particular be necessary in future to meet the nearly zero-energy requirements as established by Article 9 of Directive 2010/31/EU, and may already be cost-optimal solutions before.

The list below aims only to provide an indication of the possible measures to be considered.

Building structure:

— Total wall construction of new buildings or additional insulation system of existing walls ( 1 ).

— Total roof construction of new buildings or additional insulation system of existing roofs.

— All parts of slab subjected to insulation system of new buildings or additional insulation system of existing slabs.

— All parts of ground floor construction and foundation (being different from the reference building’s construction) or additional insulation system of existing floor construction.


( 1 ) Usually the thickness of insulation is varied stepwise and gradually. There would usually be a maximum applicable thickness per building element. The corresponding U-value level required and recommended in national legislation/ national technical standards should be considered. Insulation can be applied internally or externally or on both sides at various positions within the walls (care should be taken for risk of interstitial or surface condensation).

— Increased thermal inertia with usage of exposed massive building materials at the interior space of buildings (for some climate situations only).

— Better framing of doors and windows.

— Better sun shading (fixed or movable, operated manually or automatically and films applied to windows).

— Better air tightness (maximum air tightness corresponding to the state of technology).

— Building orientation and solar exposure (can constitute a measure for new buildings only).

— Change of share transparent/opaque surfaces (glazed area to facade area ratio optimisation).

— Openings for night ventilation (cross or stack ventilation).

Systems:

— Installation or improvement of heating system (based on fossil or renewable energy, with condensing boiler, heat pumps, etc.) at all sites.

— Monitoring and metering devices for temperature control of space and water temperature.

— Installation or improvement of hot water supply system (based on fossil or renewable energy).

— Installation or improvement of ventilation (mechanical with heat recovery, natural, balanced mechanical, extraction).

— Installation or improvement of active or hybrid cooling system (e.g. ground heat exchanger, chiller).

— Improvement of utilisation from daylighting.

— Active lighting system.

— Installation or improvement of PV systems.

— Change of energy carrier for a system.

— Change of pumps and fans.

— Insulation of pipes.

— Direct water heaters or indirect water storage heated by different carriers, can be combined with solar thermal.

— Solar heating (and cooling) installations (of different sizes).

— Intensive night ventilation (for non-residential buildings with massive structures and for some climate situations only).

— Micro CHP with different carriers.

— Important: Renewable energy produced nearby (e.g. through combined heat and power, district heating and district cooling) can be taken into account only when the production of energy and consumption of a specific building are linked strongly to each other.

— Alternative systems such as the ones listed in Article 6 of 2010/31/EU including decentralised supply systems, district heating and cooling cogeneration, etc.

Established variants:

— Existing packages/variants such as national Eco-labels and other established low-energy or nearly zero-energy buildings such as e.g. passive house.

It is important to underline that existing variants should not be taken for granted as the only cost-optimal solution even if they have been cost-efficient or even cost optimal so far.


4.2. Methods for reducing combinations and thus calculations

One of the main challenges of the calculation methodology is to ensure that on the one hand all measures with a possible impact on the primary or final energy use of a building are considered, whilst on the other hand the calculation exercise remains manageable and proportionate. Applying several variants to several reference buildings can quickly result in thousands of calculations. However, test runs performed for the Commission did reveal that the number calculated and applied to each reference building should certainly not be lower than 10 packages/variants plus the reference case.

Various techniques can be used to limit the number of calculations. One is to design the database of energy efficiency measures as a matrix of measures which rules out mutually exclusive technologies so that the number of calculations is minimised. For example, a heat pump for space heating does not have to be assessed in combination with a high efficiency boiler for space heating as the options are mutually exclusive and do not complement each other. The possible energy efficiency measures and measures based on renewable energy sources (and packages/variants thereof) can be presented in a matrix and unfeasible combinations eliminated.

Usually the most representative technologies in a given country for a given reference building would be listed first. Proven variants on the overall energy performance level should be considered here as a solution package fulfilling the expected target, expressed in a set of criteria to be fulfilled, including primary energy from non-renewable sources.

Stochastic methods for energy performance calculation can be used effectively for presenting the effects of particular measures and their combinations. From that, a limited number of combinations of most promising measures can be derived.

4.3. Indoor air quality and other comfort-related issues

As stipulated in paragraph 6 of Annex I(2) to the Regulation, the measures used for the calculation exercise must meet the basic requirements for construction products (Regulation (EU) No 305/2011) and for indoor air comfort in line with existing EU and national requirements. Also, the cost-optimal calculation exercise has to be designed in such a way that differences in air quality and comfort are made transparent. In case of a serious violation of indoor air quality or other aspects, a measure might also be excluded from the national calculation exercise and requirement setting.

Concerning indoor air quality, a minimum air exchange rate is usually set. The rate of ventilation set can depend on, and vary with, the type of ventilation (natural extraction or balanced ventilation).

Regarding the level of summer comfort it might be advisable, in particular for a southern climate, to deliberately take into account passive cooling that can be obtained by a proper building design. The calculation methodology would then be designed in such a way that it includes for every measure/package/ variant the risk of overheating and of a need for an active cooling system.

5. CALCULATION OF THE PRIMARY ENERGY DEMAND RESULTING FROM THE APPLICATION OF MEASURES AND PACKAGES OF MEASURES TO A REFERENCE BUILDING

The objective of the calculation procedure is to determine the annual overall energy use in terms of primary energy, which includes energy use for heating, cooling, ventilation, hot water and lighting. The main reference for this is Annex I to Directive 2010/31/EU which applies fully also to the cost-optimal framework methodology.

According to Directive 2010/31/EU definitions, electricity for household appliances and plug loads may be included, but this is not mandatory.

It is recommended that Member States use CEN standards for their energy performance calculations. CEN technical report TR 15615 (Umbrella Document) gives the general relationship between the EPBD Directive and the European energy standards. Moreover, standard EN 15603:2008 provides the overall scheme for energy calculation and the following definitions:


Energy-performance related definition as used in EN 15603:2008:

— Energy source: source from which useful energy can be extracted or recovered either directly or by means of a conversion or transformation process.

— Energy carrier: substance or phenomenon that can be used to produce mechanical work or heat or to operate chemical or physical processes.

— System boundary: boundary that includes within it all areas associated with the building (both inside and outside the building) where energy is consumed or produced.

— Energy need for heating or cooling: heat to be delivered to or extracted from a conditioned space to maintain the intended temperature conditions during a given period of time.

— Energy need for domestic hot water: heat to be delivered to the needed amount of domestic hot water to raise its temperature from the cold network temperature to the prefixed delivery temperature at the delivery point.

— Energy use for space heating or cooling or domestic hot water: energy input to the heating, cooling or hot water system to satisfy the energy need for heating, cooling or hot water respectively.

— Energy use for ventilation: electrical energy input to the ventilation system for air transport and heat recovery (not including the energy input for preheating the air).

— Energy use for lighting: electrical energy input to the lighting system.

— Renewable energy: energy from sources that are not depleted by extraction, such as solar energy (thermal and photovoltaic), wind, water power, renewed biomass. (definition different from the one used in Directive 2010/31/EU).

— Delivered energy: energy, expressed per energy carrier, supplied to the technical building systems through the system boundary, to satisfy the uses taken into account (heating, cooling, ventilation, domestic hot water, lighting, appliances, etc.).

— Exported energy: energy, expressed per energy carrier, delivered by the technical building systems through the system boundary and used outside the system boundary.

— Primary energy: energy that has not been subjected to any conversion or transformation process.

Under Annex I(3) to the Regulation, the calculation of energy performance involves first the calculation of final energy needs for heating and cooling, then the final energy needs for all energy uses, and thirdly the primary energy use. That means that the 'direction' of the calculation is from the needs to the source (i.e. from the building’s energy needs to the primary energy). Electrical systems (such as lighting, ventilation, auxiliary) and thermal systems (heating, cooling, domestic hot water) are considered separately inside the building’s boundaries.

For the purpose of the cost optimal methodology, on-site energy production using locally available renewable energy sources is not considered part of delivered energy which implies a need for modification of the proposed system boundary in EN 15603:2008.

Under the cost optimal methodology, the modified system boundary allows expressing all energy uses with a single primary energy indicator. As a result, the RES-based active technologies enter into direct competition with demand-side solutions, which is in line with the purpose and intention of the cost optimal calculation to identify the solution that represents the least global costs without discriminating against or favouring a certain technology.

This would lead to a situation where certain RES-based measures show better cost efficiency than some energy demand reduction measures, whilst the general picture should still be that measures reducing energy demand will be more cost effective than measures adding RES-based supply. Thus, the overall spirit of the EPBD (i.e. reduce energy use first) would not be compromised and the nearly zero-energy definition (i.e. a building with a very high energy performance and the nearly zero or very low amount of energy still needed to be covered to a large extent by renewables) is complied with.


If a Member State would want to clearly avoid the risk that active RES installations replace energy demand reduction measures, the calculation of cost optimality could be done in steps gradually expanding the system boundary to the four levels given in Figure 1 below: energy need, energy use, delivered energy and primary energy. With this, it will become clear how each measure/package of measures contributes to the buildings energy supply in terms of costs and energy.

Delivered energy includes e.g. electric energy drawn from the grid, gas from the grid, oil or pellets (all with their respective primary energy conversion factors) transported to the building for feeding the buildings technical system.

It is recommended that the energy performance calculation be done as follows:

Calculation of energy performance from net energy needs to primary energy use:

(1) Calculation of the building’s net thermal energy needs to fulfil the user’s requirements. The energy need in winter is calculated as energy losses via the envelope and ventilation minus the internal gains (from appliances, lighting systems and occupancy) as well as ‘natural’ energy gains (passive solar heating, passive cooling, natural ventilation, etc.);

(2) Subtraction from (1) of the thermal energy from RES generated and used on-site (e.g. from solar collectors) ( 1 );

(3) Calculation of the energy uses for each end-use (space heating and cooling, hot water, lighting, ventilation) and for each energy carrier (electricity, fuel) taking into account the characteristics (seasonal efficiencies) of generation, distribution, emission and control systems;

(4) Subtraction from electricity use of the electricity from RES, generated and used on-site (e.g. from PV panels);

(5) Calculation of the delivered energy for each energy carrier as sum of energy uses (not covered by RES);

(6) Calculation of the primary energy associated with the delivered energy, using national conversion factors;

(7) Calculation of primary energy associated with energy exported to the market (e.g. generated by RES or co-generators on-site);

(8) Calculation of primary energy as the difference between the two previous calculated amounts: (6) - (7).


( 1 ) Please note that soon a methodology on the accounting of energy from heat pumps will be made available by the Commission under the framework of Directive 2009/28/EC of the European Parliament and of the Council (OJ L 140, 5.6.2009, p. 16).

Figure 1

Schematic illustration of the calculation scheme

In order to achieve reliable results it is recommended to:

— Clearly define the calculation methodology, also in relation to national laws and regulations;

— Clearly define the boundaries for the system established for the energy performance assessment;

— Perform the calculations by dividing the year into a number of calculation steps (e.g. months, hours, etc.): performing the calculations for each step using step-dependent values and summing the energy consumption for all the steps over the year;

— Estimate the energy need for hot water following the approach in EN 15316-3-1:2007;

— Estimate the energy use for lighting with the quick method proposed by the standard EN 15193:2007 or more detailed calculation methods;

— Use standard EN 15241:2007 as the reference for calculating the energy use for ventilation;

— Take into account, where relevant, the impact of integrated controls, combining the control of several systems, in accordance with standard EN 15232.

In respect of the energy needs for heating and cooling, the energy balance of the building and its systems is the basis of the procedure. According to standard EN ISO 13790, the main calculation procedure consists of the following steps:

— Choice of type of calculation method;

— Definition of boundaries and thermal zones of the building;

— Definition of internal conditions and external input data (weather);

— Calculation of the energy need for each time step and zone;


— Subtraction of recovered system losses from energy needs;

— Consideration of interactions between zones and/or systems.

For the first and the last steps, a choice of different methods is suggested in the CEN standards, namely:

— Three different calculation methods:

— A fully prescribed monthly quasi-steady-state calculation method;

— A fully prescribed simple hourly dynamic calculation method;

— Calculation procedures for detailed (e.g. hourly) dynamic simulation methods.

— Two different ways of dealing with interactions between a building and its systems:

— Holistic approach (the effect of all heat gains associated with a building and its technical building systems are considered in the calculation of the energy needs for heating and cooling);

— Simplified approach (recovered system heat losses, obtained by multiplying recoverable thermal system losses by a fixed conventional recovery factor, are directly subtracted from the thermal loss of each technical building system considered).

For the purpose of the cost-optimal calculation, to achieve reliable results it is recommended to:

— Perform the calculations using a dynamic method;

— Define boundary conditions and reference use patterns in conformity with the calculation procedures, unified for all series of calculation for a particular reference building;

— Provide the source of the weather data used;

— Define thermal comfort in terms of indoor operative temperature (e.g. 20 °C in winter and 26 °C in summer) and targets, expressed for all series of calculation for a particular reference building.

Moreover it is suggested to:

— Consider the interactions between a building and its systems using the holistic approach;

— Verify with dynamic simulations the impact of day-lighting strategies (using natural light);

— Show the electric energy use for appliances.

For calculating energy use for space heating, hot water and space cooling, as well as the energy generation (thermal and electrical) from RES, it is necessary to characterise the seasonal efficiencies of systems or to use dynamic simulation. The following CEN standards can be used as reference:

— Space heating: EN 15316-1, EN 15316-2-1, EN 15316-4-1, EN 15316-4-2;

— Hot water: EN 15316-3-2, EN 15316-3-3;

— Conditioning systems: EN 15243;

— Thermal energy from RES: EN 15316-4-3;

— Electric energy from RES: EN 15316-4-6;

— Co-generation system: EN 15316-4-4;

— District heating and large volume systems: EN 15316-4-5;

— Biomass combustion systems: EN 15316-4-7.

District heating and cooling and decentralised energy supply can be dealt with in a similar fashion as can electricity supplied from outside the system boundary, which would hence be attributed a specific primary energy factor. The establishment of these primary energy factors are outside the scope of the present cost optimal guidance document and would have to be determined separately.


To calculate primary energy, the most recent national conversion factors should be used, also taking into account Annex II to Directive 2006/32/EC ( 1 ). These will have to be reported to the Commission as part of the reporting referred to in Article 5 of Directive 2010/31/EU and Article 6 of the Regulation.

Calculation example:

Consider an office building located in Brussels with the following annual energy needs:

— 20 kWh/(m 2 a) for space heating;

— 5 kWh/(m 2 a) for hot water;

— 35 kWh/(m 2 a) for space cooling;

and with the following annual energy uses:

— 7 kWh/(m 2 a) electricity for ventilation;

— 10 kWh/(m 2 a) electricity for lighting.

The building has a gas boiler for heating (space heating and hot water) with a total seasonal efficiency of 80 %. In summer, a mechanical cooling system is used: the seasonal efficiency of the entire cooling system (generation, distribution, emission, control) is 175 %. Installed solar collectors provide thermal energy for hot water of 3 kWh/(m 2 a) and a solar PV system provides 15 kWh/(m 2 a), of which 6 are utilised in the building and 9 are exported to the grid. For electricity a delivered/primary conversion factor of 0,4 is assumed (primary/delivered = 2,5).

Energy calculation results:

— fuel energy use for space heating is 25 kWh/(m 2 a): 20/0,80;

— fuel energy use for hot water is 2,5 kWh/(m 2 a): (5 - 3)/0,80;

— electric energy use for space cooling results in 20 kWh/(m 2 a): 35/1,75;

— delivered fuel energy is 27,5 kWh/(m 2 a): 25 + 2,5;

— delivered electric energy is 31 kWh/(m 2 a): 7 + 10 + 20 - 6;

— primary energy is 105 kWh/(m 2 a): 27,5 + (31/0,4);

— primary energy associated with energy exported to the market is 22,5 kWh/(m 2 a): 9/0,4;

— net primary energy is 82,5 kWh/(m 2 a): 105 – 22,5.

6. CALCULATION OF THE GLOBAL COST IN TERMS OF NET PRESENT VALUE FOR EACH REFERENCE BUILDING

In accordance with Annex III to Directive 2010/31/EU and Annex I(4) to the Regulation, the cost-optimal framework methodology is based on the net present value (global costs) methodology.

The calculation of global cost considers the initial investment, the sum of annual costs for every year and the final value as well as disposal costs if appropriate, all with reference to the starting year. For the calculation of the macroeconomic cost optimum, the category of global costs is to be expanded by a new category, the cost of greenhouse gas emissions defined as the monetary value of environmental damage caused by CO 2 emissions related to the energy consumption in a building.

Global cost calculations result in a net present value of costs incurred during a defined calculation period, taking into account the residual values of equipment with longer lifetimes. Projections for energy costs and interest rates can be limited to the calculation period.


( 1 ) A proposal for a revised ESD Directive was presented by the Commission on 22 June 2011 (COM 2011(370) final. The conversion factors are to be found in Annex IV to the proposal.

The advantage of the global cost method is that it allows the use of a uniform calculation period (with long- lasting equipment taken into account via its residual value) – as opposed to the annuity method – and that it can make use of lifecycle costing (LCC) which is also based on net present value calculations.

The term ‘global costs’ is taken from standard EN 15459 and corresponds to what generally in the literature is called 'lifecycle cost analysis'.

It should be noted that the global cost methodology as prescribed in the Regulation does not include costs other than energy (e.g. water costs) as it follows the scope of Directive 2010/31/EU. The global cost concept is also not fully in line with a complete life cycle assessment (LCA) that would take into account all environmental impacts throughout the lifecycle including so-called 'grey' energy. Member States are however free to extend the methodology towards full life cycle costing and might consider for this purpose also EN ISO 14040, 14044 and 14025.

6.1. The concept of cost optimality

In line with Directive 2010/31/EU, Member States are required to establish cost-optimal levels of minimum energy performance requirements. The methodology is addressed to national authorities (not to investors) and the cost optimal level is not calculated for each case, but for developing generally applicable regulations at national level. In reality, there will be a multitude of cost-optimal levels for different investors depending on the individual building and the investor’s own perspective and expectations of what constitute acceptable investment conditions. It is therefore important to underline that the cost-optimal levels identified will not necessarily be cost-optimal for every single building/investor combination. However, with a solid approach to determining the reference buildings, Member States can ensure that the requirements in place are appropriate for the majority of buildings.

Whilst one should keep in mind the specific situation of rented buildings, for example regarding the split incentives problem or situations where the rent is fixed and cannot be increased beyond a certain limit (e.g. for social policy reasons), it is not desirable to have different requirements for buildings depending on whether these are rented out or not, as the status of the occupant is independent of the building which is the focus of the calculation.

However, there might be certain groups of investors who will not be able to take full advantage from a full cost optimal investment. This issue, often called the 'owner-tenant dilemma', will need to be addressed by Member States as part of wider energy efficiency and social policy objectives and not within the cost optimal methodology. The calculation exercise can however provide Member States’ authorities with the information on the financial gap that exists for certain investor groups and hence can inform policies. For example, the difference between the cost optimum at macroeconomic level and the cost optimum at financial level might give hints regarding the necessary funding and financial support that might still be needed to make energy efficiency investments economically interesting for the investor.

Besides the fact that various, and possibly numerous, individual perspectives and investment expectations exist, there is also the question of scope of costs and benefits that are taken into account. Does one only consider the immediate costs and benefits of the investment decision (i.e. financial perspective), or does one also look at other indirect costs and benefits (often called externalities) that are triggered by an energy efficiency investment and that apply to other market actors than the investor (macroeconomic perspective)? Both of these perspectives have a specific rationale and inform on different issues.

The purpose of the calculation exercise at macroeconomic level is to prepare and inform the setting of generally applicable minimum energy performance requirements, and encompass a broader public good perspective where the investment in energy efficiency and its associated costs and benefits are assessed against policy alternatives and where externalities are factored in. As such, the investment into energy efficiency in buildings is compared against other policy measures that reduce energy use, energy dependency and CO 2 emissions. Such a broader investment perspective aligns also relatively well with primary energy as the ‘currency’ of energy performance, whereas a purely private investment perspective can be aligned with either primary energy or delivered energy.

However, in practice it will not be possible to capture all societal direct and indirect benefits, as some are intangible or non-quantifiable, or cannot be monetised. Nevertheless, some external benefits and costs have recognised quantification and costing approaches that allow them to be captured.


On the other hand, the microeconomic perspective will show the limitations to the investor when e.g. stricter energy efficiency requirements might be desirable from a societal point of view, but are not cost effective for the investor.

The Regulation requires Member States to calculate cost optimality once at macroeconomic level (excluding all applicable taxes (such as VAT), and all applicable subsidies and incentives, but including carbon costs) and once at financial level (taking into account prices as paid by the end consumer including taxes and if applicable subsidies, but excluding the additional greenhouse gas abatement costs).

To note: Once both calculations are performed, it is up to the Member States to decide which of the calculations is to be used as the national cost optimal benchmark.

As for the calculation of the cost optimum at macroeconomic level, the Regulation requires the consideration of greenhouse gas emissions costs by taking the sum of the annual greenhouse gas emissions multiplied by the expected prices per ton CO 2 equivalent of greenhouse gas emission allowances issued in every year, using initially as a minimum lower bound at least 20 Euro per ton of CO 2 equivalent until 2025, 35 Euro until 2030 and 50 Euro beyond 2030 in line with current Commission projected ETS carbon price scenarios measured in real and constant prices for 2008, to be adapted to the calculation dates and methodology chosen.

Updated scenarios shall be taken into account every time a review of the cost optimal calculations is carried out. Member States are free to assume higher carbon costs than these minimum levels, such as the one suggested 0,03-0,04 Euro per kg provided in Directive 2009/33/EC ( 1 ), Annex, Table 2.

Finally, Member States are free to expand the category of costs greenhouse gas emissions from capturing only CO 2 emissions to covering a wider range of environmental pollutants again in line with Directive 2009/33/EC Annex Table 2 as given below:

The present value of the minimum environmental costs per unit of emissions to be used in calculations of the environmental costs:

NO x NMHC PM

0,0044 EUR/g 0,001 EUR/g 0,087 EUR/g

It has to be noted that, for the financial perspective calculation, the inclusion of available support schemes (along with taxes and all available subsidies) would usually be required to reflect the real financial situation. However, given that such schemes often change quickly it is also possible for a Member State to calculate without subsidies for a private investor point of view.

Moreover at financial level, the calculation may be simplified by fully excluding VAT from all cost categories of the global cost calculation, if in that Member State no VAT-based subsidies and support measures exist. A Member State that already has or intends to put in place VAT-based support measures should include VAT as an element in all cost categories so as to be able to include the support measures into the calculation.

6.2. Cost categorisation

Under Annex I(4) to the Regulation, Member States are required to use the following basic cost categories: Initial investment costs, running costs (including energy costs and periodic replacement costs) and, if appropriate, disposal costs. In addition, the cost of greenhouse gas emissions is included for the calculation at macroeconomic level.

Due to their importance in the given context, energy costs are listed as a separate cost category although usually they are seen as part of the operational cost. Furthermore, replacement cost is not seen as part of maintenance cost (as is sometimes the case in other cost structures) but as a separate cost category.

This cost categorisation for the calculation of cost-optimal levels of minimum requirements is based on standard EN 15459. It differs slightly from cost categorisation systems usually used for lifecycle cost assessment (compare standard ISO 15686-5:2008 on Buildings and constructed assets - Service-life planning - Part 5 Lifecycle costing). The following illustration summarises the cost categories to be applied.


( 1 ) Directive 2009/33/EC of the European Parliament and of the Council of 23 April 2009 on the promotion of clean and energy-efficient road transport vehicles (OJ L 120, 15.5.2009, p. 5).

Figure 2

Cost categorisation according to the framework methodology

It has to be stressed that the enumeration of cost categories given in the Regulation is comprehensive. Nevertheless, if other cost categories are considered important in the context of the calculation of cost- optimal levels of minimum requirements (such as costs related to other environmental pollutants), they can also be taken into account (for more details, please see Chapter 6.1.).

Moreover, the cost of the capital needed to finance energy efficiency investments is not included as a separate category in the Regulation. However, Member States may include it, for example within the category of annual costs to ensure that they are also discounted.

Energy costs are based on consumption, size of the building, current rates and price predictions, and are directly linked to the result of the energy performance calculation. This means that energy costs depend on the system characteristics of the building. Most other cost items such as investment cost, maintenance cost, replacement cost, etc. are largely allocated to specific building elements. Therefore, global costs have to be calculated with buildings sufficiently disaggregated into separate building elements, so that differences in measures/packages/variants are reflected in the result of the global cost calculation.

Non-fuel-related operational and maintenance costs are often more difficult to estimate than other expenditures since operating schedules vary from building to building. There is a great variation even among buildings of the same category. Some data gathering and screening might therefore be needed to determine a reasonable average cost per square meter for certain categories and subcategories.

The Regulation prescribes in principle a full cost approach for new construction as well as for major refurbishment. This means that for each assessed measure/package/variant applied to a reference building, the full cost of construction (or major renovation) and the subsequent use of the building should be calculated. However, since the focus of the exercise is the comparison of measures/packages/variants (and not the assessment of total costs for the investor and building user), the following cost items may be omitted from the calculation:

— Costs related to building elements which do not have an influence on the energy performance of the building, for example: cost of floor covering, cost of wall painting, etc. (if the energy performance calculation does not reveal any differences in this respect);


— Costs that are the same for all measures/packages/variants assessed for a certain reference building (even if the related building elements have or could have an influence on the energy performance of the building). Since these cost items do not make a difference in the comparison of the measures/packages/ variants, it is not required to take them into account. Examples could be:

— For new construction: Earthworks and foundation, cost of staircases, cost of lifts, etc. – if these cost elements are the same for all measures/packages/variants assessed;

— For major renovation: cost of scaffolding, demolition cost, etc. – once again under the precondition that no differences in these cost items can be expected for the measures/packages/variants assessed.

It has to be noted that the Regulation does not allow for the so-called 'additional cost' calculation approach ( 1 ). For calculating the cost optimality of minimum energy performance requirements, the additional cost calculation approach is not suitable for the following reasons:

— The characteristics of the standard building have an impact on the results of the assessment of cost optimality;

— The additional cost calculation approach cannot reflect fully the scope of assessed measures/packages/ variants: Many energy efficiency measures are to be seen as an integral part of the building design. This is particularly true for measures that are related to ‘passive cooling’ approaches, such as the choice of share of window area and the placement of window areas according to the orientation of the building, the activation of thermal mass, the package of measures related to night cooling, etc. The additional cost calculation approach makes it difficult to show inter-linkages between certain building characteristics, e.g. the choice of a certain type of façade requires certain static preconditions; thermo-active building systems for heating and cooling require a certain level of net energy demand, etc. Trying to allow for all these potential inter-linkages in an additional cost calculation approach would make the calculation confusing and non-transparent;

— The additional cost calculation approach requires a detailed cost attribution between costs for the standard renovation and costs that are associated with the additional energy efficiency measures. This separation is sometimes not very easy to make.

6.3. Gathering of cost data

The Regulation states that cost data must be market-based (e.g. obtained by market analysis) and coherent as regards location and time for the investment costs, running costs, energy costs and if applicable disposal costs. This means that cost data need to be gathered from one of the following sources:

— Evaluation of recent construction projects;

— Analysis of standard offers of construction companies (not necessarily related to implemented construction projects);

— Use of existing cost databases which have been derived from market-based data gathering.

It is important that the cost data sources reflect the disaggregation level which is required to compare different measures/packages/variants for a given reference building. Therefore, so-called ‘top-down’ benchmark databases such as BKI ( 2 ) or OSCAR ( 3 ), which are commonly used for rough estimates of the investment and operating cost of buildings, cannot be used for the purpose of cost-optimal calculations because their data are not sufficiently related to the energy performance of the building. Their disaggregation level is too low to be able to derive cost differentiations of different measures/packages/variants.


( 1 ) An additional cost calculation approach starts from a standard building (e.g. a building that is in line with the actual minimum requirements), to which additional measures (e.g. better insulation, shading, a ventilation system with heat recovery, etc.) are added. The cost comparison is based on additional investment costs and differences in running costs.

( 2 ) Baukosteninformationszentrum Deutscher Architekten (BKI): Statistische Kostenkennwerte für Gebäude, 2010, www. baukosten.de.

( 3 ) Jones Lang LaSalle: Büronebenkostenanalyse OSCAR 2008, Berlin, 2009. Can be ordered from www.joneslanglasalle. de.

http://www.baukosten.de

http://www.baukosten.de

http://www.joneslanglasalle.de

http://www.joneslanglasalle.de

6.4. The discount rate

The discount rate is expressed in real terms, hence excluding inflation.

The discount rate used in the macroeconomic and financial calculation is to be established by the Member State after performing a sensitivity analysis on at least two rates for each calculation. The sensitivity analysis for the macroeconomic calculation shall use one rate of 4 % expressed in real terms. This is in line with the current Commission’s 2009 Impact Assessment guidelines, which suggests 4 % as societal discount rate ( 1 ).

A higher discount rate – typically higher than 4 % excluding inflation and possibly differentiated for non- residential and residential buildings – will reflect a purely commercial, short-term approach to the valuation of investments. A lower rate – typically ranging from 2 % to 4 % excluding inflation – will more closely reflect the benefits that energy efficiency investments bring to building occupants over the entire investment’s lifetime. The discount rate will be different from Member State to Member State as it reflects to a certain extent not only policy priorities (for the macroeconomic calculation), but also different financing environments and mortgage conditions.

To make the discount rate applicable, usually a discount factor will have to be derived that can be used in the global cost calculation. R d (i), the discount factor for year i based on discount rate r, can be calculated as:

R d ðpÞ ¼ 8 > > > : 1

1 þ r=100 9 > > > ;

p

Where;

p is the number of years from the starting period; and

r is the real discount rate.

It is to be noted that as an effect of the financial calculation principle, the amount of global costs is higher when lower discount rates are applied, since future costs (mainly energy costs) are discounted at a lower rate, leading to a higher present value of the global costs.

6.5. Basic listing of cost elements to be taken into account for calculating initial investment costs of buildings and building elements

The listing below is not necessarily comprehensive or up-to-date and is intended purely as an indication of elements to be taken into account:

For the building envelope

Insulation of building envelope:

— Insulation products

— Additional products for application of the insulation to the building envelope (mechanical fixings, adhesive, etc.)

— Design costs

— Installation costs of insulation (including water vapour barriers, weather membranes, measures to ensure air-tightness and measures to reduce the effects of thermal bridges)

— Energy-related costs of other building materials, if applicable

Windows and doors:

— Glazing and/or glazing enhancement

— Frame

— Gaskets and sealants

— Installation costs

The technical systems, products and building elements are described for example in various standards under CEN/TC 33 - Doors, windows, shutters, building hardware and curtain walling and CEN/TC 89 (see above).


( 1 ) http://ec.europa.eu/governance/impact/commission_guidelines/docs/ia_guidelines_annexes_en.pdf. The US Department of Energy Federal Energy Management Program 2010 edition of energy price indices and discount factors for performing life-cycle cost analysis which suggests 3 %. http://www1.eere.energy.gov/femp/pdfs/ashb10.pdf.

http://ec.europa.eu/governance/impact/commission_guidelines/docs/ia_guidelines_annexes_en.pdf

http://www1.eere.energy.gov/femp/pdfs/ashb10.pdf

— Other building-related measures with impact on thermal performance. This can include e.g. external shading devices, solar control systems, and passive systems not covered elsewhere.

The technical products and systems are described for example in various standards under CEN/TC 88 – Thermal insulating materials and products and CEN/TC 89 – Thermal performance of buildings and building elements.

For building systems

Space heating:

— Generation and storage equipment (boiler, storage tank heat generation controls)

— Distribution (circulator, circuit valves, distribution controls)

— Emitters (radiators, ceiling floor heating, fan coils, emission controls)

— Design costs


The technical systems are described for example in various standards under CEN/TC 228 - Heating systems in buildings and CEN/TC 57 - Central heating boilers, e.g. EN 15316-2-1 CEN/TC 247, EN 12098, EN 15500, EN 215, EN 15232

For reference comfort conditions, EN15251 ‘Indoor environmental input parameters for design and assessment of energy performance of buildings addressing indoor air quality, thermal environment, lighting and acoustics’ or equivalent should be taken into account.

Domestic hot water:

— Generation and storage (including solar thermal systems, boiler, storage tank, heat generation controls)

— Distribution (circulator, circuit valves/mixing valves, distribution controls)

— Emitters (tap valves, floor heating, emission controls)

— Design costs

— Installation (including insulation of the system and pipes)

The technical systems are described for example in various standards under CEN/TC 228 - Heating systems in buildings, CEN/TC 57 - Central heating boilers and CEN/TC 48 - Domestic gas- fired water heaters.

Ventilation systems:

Concerning investments, the costs of mechanical ventilation systems are to be assessed. Possibilities for natural ventilation are covered with the definition of reference buildings.

Investment costs should include:

— Heat generation and recovery equipment (heat exchanger, pre-heater, heat recovery unit, heat generation controls)

— Distribution (fans, circulators, valves, filters, distribution controls)

— Emitters (ducts, outlets, emission controls)

— Design costs


Cooling:

As a comfortable indoor temperature needs to be ensured, passive or active cooling measures or a combination of both (supplying remaining cooling demand) need to be taken into account, depending on the specific climate conditions. In this category, the costs of active cooling systems are referred to. Passive cooling measures are either covered with the choice of reference buildings (e.g. building mass) or covered in the category ‘thermal insulation’ (e.g. insulation of roofs to reduce cooling demand) or the category ‘Other building-related measures with impact on thermal performance’ (e.g. external shading). Investment costs of active cooling systems include:


The technical systems are described for example in various standards under CEN/TC 156 - Ventilation for buildings. EN15251 or equivalent should be taken into account for reference comfort conditions and requirements for ventilation.

— Generation and storage equipment (generator, heat pump, storage tank, heat generation controls)

— Distribution (circulator, circuit valves, distribution controls)

— Emitters (ceiling/floor/beams; fan coils, emission controls)

— Design cost

— Installation

The technical systems are described for example in various standards under CEN/TC 113 - Heat pumps and air conditioning units. EN15251 should be taken into account for reference comfort conditions.

Lighting:

Concerning investments, active systems for artificial lighting or applications to increase use of daylight are to be assessed. Measures that refer to the design and geometry of the building envelope (size and position of windows) are being covered with the choice of the reference buildings. Investment costs should include:

— Type of light sources and luminaires

— Associated control systems

— Applications to increase use of daylight

— Installation

EN 12464 ‘Light and lighting - lighting of workplaces - Part 1 indoor work places’ should be taken into account for reference comfort conditions and requirement levels. The energy requirements for lighting systems are described in EN 15193.

Building automation and control:


— Building management systems which introduce supervising functions (separate system controls are accounted for within the specific system)

— Technical intelligence, central controller

— Controls (generation, distribution, emitters, circulators)

— Actuators (generation, distribution, emitters)

— Communication (wires, transmitters)

— Design costs

— Installation and programming costs

The technical systems are described for example in various standards under CEN/TC 247 - Building Automation, Controls and Building Management

Connection to energy supplies (grid or storage):


— Costs for first connection to the energy network (e.g. district heat, PV-system)

— Storage tanks for combustion fuels

— Necessary related installations

Decentralised energy supply systems based on energy from renewable sources:


— Generation

— Distribution

— Control devices

— Installation

6.6. Calculation of periodic replacement cost

Besides initial investment costs and running costs, periodic replacement costs are the third cost driver. Whereas smaller repair work and consumables are usually subsumed under maintenance costs, periodic replacement refers to the necessary substitution of a whole building element as a result of ageing, and is therefore treated as a separate cost category.

The point in time of periodic replacement depends on the lifetime of the building element. At the end of that lifetime a replacement has to be provided for in the global cost calculation.

Example: The cost of a heat recovery unit with an estimated economic lifetime of 15 years has to be calculated twice in the global cost calculation with a calculation period of 30 years: once at the beginning as initial investment cost and again as replacement cost after 15 years.


It is up to Member States to determine the estimated economic lifetime of building elements as well as the entire building, but they may wish to use the guidance given in standard EN 15459 (for energy systems in buildings) and other standards. In any case, the lifetime of the building elements used for the calculation must be plausible. In general the replacement cost will be the same as the initial investment cost (in real terms!). However, where major price developments may be expected over the next 10-15 years, the Regulation allows and also encourages the adaptation of the level of replacement cost to take into account the expected price developments when technologies ripen.

6.7. Calculation period versus estimated lifecycle

The use of a calculation period as part of a net present value approach does not impede Member States’ choice of estimated economic lifecycles for buildings and building elements. The estimated lifecycle can either be longer or shorter than the calculation period.

If a reference building category for existing buildings were to be established in a way that the reference building’s remaining lifecycle is shorter than the calculation period, the maximum remaining lifetime could in this case become the calculation period.

In fact, the technical lifespan of building elements has only limited influence on the calculation period. The calculation period is, rather, determined by the so-called refurbishment cycle of a building, which is the period of time after which a building undergoes major refurbishment, including improvement of the building as a whole and adaptation to changed user requirements (in contrast to simple replacement). The reasons for major refurbishment are usually diverse, with ageing of important building elements (e.g. façade) being just one of them. Refurbishment cycles differ widely between building types (which is why different calculation periods are set for residential/public and non-residential/commercial buildings in the delegated act) and Member States, but are almost never below 20 years.

Figure 3 illustrates the approach for a building element which has a longer lifetime than the calculation period (e.g. the façade or the bearing structure of the building). With an assumed lifespan of 40 years and a straight-line depreciation, the residual value after 30 years (end of the calculation period) is 25 % of the initial investment cost. This value has to be discounted to the beginning of the calculation period.

Figure 3

Calculation of the residual value of a building element which has a longer lifetime than the calculation period

Figure 4 shows how the residual value has to be calculated for a building element which has a shorter lifespan than the calculation period (e.g. heating boiler). With an assumed lifespan of 20 years the element has to be replaced after that period of time. Once the element has been renewed a new depreciation period starts. In this case, after 30 years (end of the calculation period) the residual value of the element is 50 % of the replacement cost. Once again this value has to be discounted to the beginning of the calculation period.


Figure 4

Calculation of the residual value of a building element which has a shorter lifetime than the calculation period

6.8. Starting year for the calculation

The Regulation requires that Member States use as a starting point for the calculation the year in which the calculation is being carried out. The main purpose of this is to ensure that the current price and cost levels are reflected when the cost optimality of various measures/ packages/variants is identified (to the extent that such data are already available). However, it is possible for Member States to base the calculation on the starting year (year of calculation, say 2012 for the first exercise), but use as a reference for the minimum energy performance requirement those requirements that are already established and foreseen for the near future, for example those that would become applicable in 2013.

6.9. Calculation of residual value

The Regulation requires including the residual value in the global cost calculation. The residual value of a building at the end of the calculation period is the sum of residual values of all building elements. The residual value of a certain building element is dependent on the initial investment cost, the depreciation period (which reflects the lifetime of this building element) and, if appropriate, any costs for removing a building element.

6.10. Cost development over time

Except for energy cost and replacement cost, the Regulation does not include any other real term cost increases or decreases. This means that for the other cost categories (i.e. operational cost and maintenance cost) price development is assumed to be equal to the overall inflation rate.

Experiences have shown that prices of new technologies can quickly decrease when the market takes them up, as was the case with new and more efficient boilers or double glazing. Given that most investments occur only at year 1, future decreases in technology prices will not have a huge impact on the cost calculations. Nevertheless, it will be very important to consider such price decreases during a review and update of the input data for the next calculation exercise. Member States might also include an innovation or adaptation factor into their calculation that ensures that the dynamic evolution of costs over time is taken into account.

With respect to the development of costs for energy carriers and carbon costs over time, Annex II to the Regulation provides information that Member States can use for their calculations, although Member States are free to use other forecasts. Based on this and other information sources, Member States need to develop their own scenarios for cost development over time. Energy cost developments are to be assumed for all energy carriers used to a significant extent in a Member State and might include, for example, bio energy in all its aggregations, LPG, district heating and cooling.


It is important to note that scenarios for different fuel sources have to have a plausible correlation. Also, the electricity price trends for a Member State should be plausibly correlated with overall trends, i.e. with the trends for the main underlying fuels used at national level for producing electricity. Price developments might also be assumed, if appropriate, for peak load tariffs.

6.11. Calculation of replacement costs

For replacement costs there is the possibility of adapting the initial investment cost (which serves as a basis for fixing the replacement cost) for selected building elements if major technological development is expected during the upcoming years.

Example: The replacement cost for a photovoltaic system can be assumed to be lower than the initial investment cost since major cost reduction is expected due to technological progress. The same might be true for other RES technologies, building automation, new generation boilers, etc.

6.12. Calculation of energy cost

Energy costs shall reflect both the cost of necessary capacity and necessary energy. Moreover, if possible, energy costs should be based on a weighted average of the basic (variable cost) and peak load (normally fixed cost) tariffs paid by the final customer including all costs, taxes and profit margins of the supplier. All energy uses covered by Annex I to Directive 2010/31/EU are to be considered.

6.13. Treatment of taxation, subsidies and feed-in tariffs in the cost calculation

Inclusion of all applicable taxes (VAT and others), support schemes and incentives is necessary for the calculation of the cost optimum at financial level, while they are not considered for the calculation at macroeconomic level. This refers in particular but not exclusively to:

— Energy and/or CO 2 taxation of energy carriers;

— Investment subsidies for (or depending on) the use of energy-efficient technologies and of renewable energy sources;

— Regulated minimum feed-in tariffs for energy produced from renewable energy sources.

Whereas the Regulation obliges Member States to consider the taxes paid by customers for the financial level cost calculation, it allows Member States to exclude subsidies and incentives, since these might change very quickly. Therefore, the applicable incentives and subsidies cannot be taken into account for the entire period the cost optimal calculation is supposed to be the national benchmark. Moreover, reviewing the benchmarks every time a change in subsidies or incentives occurs will also not be possible. To avoid a perpetuation of the subsidy scheme that is currently in force, a Member State might find it helpful to also calculate the real private costs without subsidies to identify the difference and thus steer future subsidy policies.

When Member States leave out subsidies from the calculation at financial level, they should ensure that not only subsidies and support schemes for technologies, but also possibly existing subsidies for energy prices are taken out.

6.14. Inclusion of earnings from energy production

If a Member State wishes to include in the calculation the earnings from renewable energy produced "where applicable" (as per Annex III to Directive 2010/31/EU), it should endeavour to include all available subsidies and support schemes (for both electricity and thermal, and also for renewable energy and energy efficiency). If, for example, only a feed-in tariff for produced electricity were considered in the equation, other subsidies and support schemes, and the technologies benefiting from these, would be disadvantaged and the results would imply an inherent bias in favour of the subsidies considered. In particular, a bias towards electricity production at the expense of reduced demand for heating and cooling should be avoided.

Earnings from energy produced might be deducted from the category of annual costs. The option to include earnings from energy produced would naturally result in the inclusion of all other taxes, fees and subsidies in order to complete the financial perspective for which it is best suited.


6.15. Calculation of disposal costs

According to the Regulation the inclusion of disposal costs in the global cost calculation is not a requirement. Member States may include disposal costs if they think they are relevant and if they are able to make plausible estimates of their amount. Disposal costs need to be discounted back to the end of the calculation period. In principle there are two places where disposal costs can be taken into account in the global cost calculation:

— Firstly, and most commonly, through the end-of-life cost of the building, i.e. the cost for demolition and disposal of material including decommissioning cost (see standard ISO 15686 for a more precise definition of end-of-life cost items). The influence of the end-of-life cost depends on two factors: the absolute amount of costs and – even more importantly – the point in time when they are assumed to occur. In this context, it is important to note that end-of-life costs do not occur at the end of the calculation period but at the end of the lifetime of the building. Therefore an estimate of the lifetime of the building as a whole (and not of single building elements) is required. This may depend on the type of construction on the one hand (e.g. prefabricated house versus solid construction) and on the type of use on the other (e.g. retail properties usually have shorter lifetimes than residential buildings). Member States are free to choose building lifetimes, but the lifetimes used should show plausible relationships when comparing different building categories.

— Secondly, disposal costs may be introduced in connection with replacement costs, since the dismantling or demolition of an old building element creates some cost. This cost is usually not included when fixing the replacement cost at the same level as the initial investment (no cost increase/decrease in real terms). Therefore, the addition of some extra disposal costs related to replacement activities may be included in the global cost calculation.

The major challenge with respect to the consideration of disposal costs is the acquisition of reliable and market-based cost data. Usually disposal costs in the construction sector are only taken into account through an approximation based on the volume of the building, differentiated (in some cases) by construction type.

To note: If the assumed lifetime of the building exceeds 50 to 60 years, the influence of disposal costs on the final result will be marginal due to discounting.

7. DERIVATION OF A COST-OPTIMAL LEVEL OF ENERGY PERFORMANCE FOR EACH REFERENCE BUILDING

7.1. Identification of the cost-optimal range

Based on the calculations of primary energy use (step 3) and global costs (step 4) associated with the different measures/packages/variants (step 2) assessed for the defined reference buildings (step 1), graphs can be drawn per reference building that describe primary energy use (x-axis: kWh primary energy/(m 2 useful floor area and year)) and global costs (y-axis: EURO/m 2 useful floor area) of the different solutions. From the number of measures/ packages/variants assessed, a specific cost curve (= lower border of the area marked by the data points of the different variants) can be developed


Figure 5

Different variants within the graph and position of the cost-optimal range ( 1 )

The combination of packages with the lowest cost is the lowest point of the curve (in the illustration above, package ‘3’). Its position on the x-axis automatically gives the cost-optimal level of minimum energy performance requirements. As stipulated in paragraph 2 of Annex I(6) to the Regulation, if packages have the same or very similar costs, the package with the lower primary energy use (= left border of the cost-optimal range) should if possible guide the definition of the cost-optimum level.

To note: Even with similar results it should be borne in mind that the necessary investment needs might differ even if the energy performance is similar and more incentives might therefore be needed.

For building elements, cost-optimal levels are assessed by fixing all parameters (option 1: starting from the variant that has been identified as cost-optimal; option 2: starting from different variants and using an average of the resulting values) and varying the performance of a specific building element. Graphs can then be developed to show the performance (x-axis, e.g. in W/(m 2 K) for building elements like the roof of a building) and global costs (y-axis, in EURO/m 2 useful floor area). The building element properties with the lowest cost will provide the cost-optimal level. If different building element properties have the same or very similar costs, the building element property with the lower primary energy use (= left border of the cost- optimal range) should guide the definition of the cost-optimum level (the fact that higher upfront investment needs occur should be taken into account).

It is important to note that minimum performance requirements for boilers and other installed appliances and equipment are being set under the framework of the Ecodesign Directive ( 2 ).

7.2. Comparison with current requirements at Member State level

The current requirements at Member State level need to be compared to the calculated cost-optimal level. Therefore, the current regulations need to be applied to the reference building, leading to a calculation of the primary energy consumption of the building according to the rules set out in step 3.

In a second step, the difference between the current level and the identified cost-optimal level is calculated according to equation in the box below.


( 1 ) Source: Boermans, Bettgenhäuser et al., 2011: Cost-optimal building performance requirements - Calculation methodology for reporting on national energy performance requirements on the basis of cost optimality within the framework of the EPBD, ECEEE.

( 2 ) Directive 2009/125/EC of the European Parliament and of the Council of 21 October 2009 establishing a framework for the setting of ecodesign requirements for energy-related products (OJ L 285, 31.10.2009, p. 10.)

Identification of the gap

Gap % (reference building level) = (cost-optimal level [kWh/m 2 a] – current minimum performance requirements [kWh/m 2 a]) / cost-optimal level [kWh/m 2 a]) x 100 %

For building elements, the gap is calculated according to the following equation:

Gap % (for building elements) = (cost-optimal level [unit of performance indicator ( 1 )] – current minimum performance requirements [unit of performance indicator]) / cost-optimal level [unit of performance indicator]) x 100 %

The difference between the calculated cost-optimal levels of minimum performance requirements and those in force should be calculated as the difference between the average of all the minimum energy performance requirements in force and the average of all the calculated cost optimal levels resulting from the variants applied to all the comparable reference buildings and building types used. It is up to the Member State to introduce a weighing factor representing the relative importance of one reference building (and its requirement) in a MS over another. However, such approach should be made transparent in the reporting to the Commission.

In line with recital 14 of Directive 2010/31/EU, a significant discrepancy between the outcome of the cost optimal cost calculation and the minimum requirements currently in force in a Member State exist if the latter are 15 % lower than the cost-optimum.

8. SENSITIVITY ANALYSIS

Sensitivity analysis is standard practice in ex-ante assessments when outcomes depend on assumptions on key parameters of which the future development can have a significant impact on the final result.

The Regulation therefore requires some sensitivity analyses to be undertaken by the Member States. The Regulation requires Member States to perform at least a sensitivity analysis on different price scenarios for all energy carriers of relevance in a national context, plus at least two scenarios each for the discount rates to be used for the macroeconomic and financial cost optimum calculations.

For the sensitivity analysis on the discount rate for the macroeconomic calculation, one of the discount rates shall be set at 3 % expressed in real terms ( 2 ). Member States have to determine the most appropriate discount rate for each calculation once the sensitivity assessment is performed. This is the one to be used for the cost-optimal calculation.

Member States are encouraged to perform such analysis also on other input factors such as the projected trends in future investment costs for building technologies and building elements or on any other input factor that is deemed to have significant influence on the result (e.g. primary energy factors, etc.).

Although it is true that a future price development will not impact on the upfront investment costs occurring at the start of the calculation period, the assessment on how the market uptake of technologies might influence their price level is very useful information for policy makers. In any event, such technology price developments are crucial for informing the review of the cost optimal calculations.

Besides undertaking a sensitivity analysis for these two key parameters, Member States are free to conduct additional sensitivity analyses particularly for the main cost drivers as identified in the calculation, such as the initial investment cost of major building elements or costs related to the maintenance and replacement of energy systems in buildings.

9. ESTIMATED LONG-TERM ENERGY PRICE DEVELOPMENTS

The energy price development trends provided in Annex II to the Regulation give information about the estimated long-term price developments for oil, gas and coal, as well as electricity. Member States must take this information into account when determining the costs for energy carriers for the purpose of their cost- optimal calculations.


( 1 ) E.g. U-value of a roof [W/m 2 K] ( 2 ) This rate is used in the Commission's Impact Assessment Guidelines of 2009 and broadly corresponds to the average

real yield on longer-term government debt in the EU over a period since the early 1980s.

The information provided in Annex II to the Regulation is taken from energy trend scenarios developed with the PRIMES model (a modelling system that simulates a market equilibrium solution for energy supply and demand in the EU 27 and its Member States). The European Commission publishes biannual updates of these trends and the latest version can be found on: http://ec.europa.eu/energy/observatory/trends_2030/ index_en.htm.

The latest update ( 1 ) implies a 2,8 % annual increase in gas prices, a 2,8 % annual increase in oil prices and a 2 % annual increase in coal prices. These trends may be extrapolated beyond 2030 until more long-term projections become available.

These projections are based on a relatively high oil price environment compared with previous projections and are similar to reference projections from other sources. The baseline price assumptions for the EU27 are the result of world energy modelling (using the PROMETHEUS stochastic world energy model) that derives price trajectories for oil, gas and coal under a conventional wisdom view of the development of the world energy system.

International fuel prices are projected to grow over the projection period with oil prices reaching 88 USD’08/bbl (73 EUR’08/bbl) in 2020 and 106 USD’08/bbl (91 EUR’08/bbl) in 2030. Gas prices follow a trajectory similar to oil prices, reaching 62 USD’08/boe (51 EUR’08/boe) in 2020 and 77 USD’08/boe (66 EUR’08/boe) in 2030, while coal prices increase during the economic recovery period to reach almost 26 USD’08/boe (21 EUR’08/boe) in 2020 but then stabilise at 29 USD’08/boe (25 EUR’08/boe) in 2030.

Regarding electricity, the projected changes in the EU27 power sector will have significant impacts on energy costs and electricity prices. Total cumulative investment expenditure for power generation in the period 2006-2030 is projected to reach 1,1 trillion EUR’08 with electricity prices increasing substantially both relative to present levels and in comparison to the 2007 Baseline. Auction payments and increasing fuel prices and higher capital costs (for renewable energy and CCS) are among the factors explaining the electricity price rise.

The average price of electricity, net of auction payments, increases to 108,4 EUR/MWh in 2020 and 112,1 EUR/MWh in 2030 (in real terms, i.e. in money of 2005), a consistent rise compared to current values due to higher capital and O&M costs, and higher fuel and variable costs. The auction payments account for 9,4 % of the average pre-tax electricity price.

Table

Estimated long-term after-tax electricity price developments in EUR/MWh (baseline 2009)

2000 2005 2010 2015 2020 2025 2030

Average 96 104 110 127 140 146 144

Industry 59 71 77 92 101 104 98

Services 123 124 124 139 152 159 159

Households 127 133 144 164 180 191 192

It is recommended that for residential buildings the households price predictions are used, whereas for non- residential buildings the commercial prices might be more appropriate.

Member States can also develop the assumed energy prices for the calculation period from current cost levels, as for example provided by EUROSTAT. The information from EUROSTAT differentiates prices for domestic and industrial use, depending on delivered volume. Accordingly, different price levels need to be taken into account for the reference buildings described in Chapter 3.


( 1 ) Source: EU Energy Trends to 2030; update 2009. European Union, 2010. See: http://ec.europa.eu/energy/observatory/ trends_2030/doc/trends_to_2030_update_2009.pdf.

http://ec.europa.eu/energy/observatory/trends_2030/index_en.htm

http://ec.europa.eu/energy/observatory/trends_2030/index_en.htm

http://ec.europa.eu/energy/observatory/trends_2030/doc/trends_to_2030_update_2009.pdf

http://ec.europa.eu/energy/observatory/trends_2030/doc/trends_to_2030_update_2009.pdf

Other energy carriers can be coupled to these assumed developments (e.g. natural gas being linked to the oil price) or can be derived from other national or international forecasts. As the prices of many energy carriers are subject to a strong national, regional or even local influence, such as biomass, district heating and geothermal, these forecasts should take into account expected longer-term political as well as economic developments. For example, regarding district heating, possible effects stemming from necessary changes in the infrastructure (size of district heating systems, energy delivered per m of grid, etc.) should be taken into account.

Heating oil:

Heating oil is a low viscosity, flammable liquid used in building furnaces and boilers. Being a distillate product of crude oil, its price is intrinsically linked with the crude oil price. Moreover, other factors, such as supply and demand, seasonal influences, the dollar-Euro exchange rate and logistical costs influence the price of heating oil.

Example: Estimates from the United Kingdom ( 1 ) indicate that the heating oil price is around a quarter above the Brent crude price but this will be different in other Member States.

The efficiency of electricity production depends on the types of primary fuels consumed and the specific equipment that is used. These characteristics are unique to specific power plants and differ across Member States. For example, some countries have a higher percentage of hydroelectric power, while others consume greater quantities of coal or use significant amounts of nuclear energy. Member States will have to adopt conversion factors to convert the electricity used in their reference buildings into primary energy.


( 1 ) See http://heating-oil.blogs-uk.co.uk/

http://heating-oil.blogs-uk.co.uk/



EFFESUS • 314678 • of 262

8.4 Section 4: 3encult 2011: Suggestions on energy performance calculations for historic

buildings

EUROPEAN COMMISSION

DG ENVIRONMENT

Seventh Framework Programme

Theme [EeB.ENV.2010.3.2.4-1]

[Compatible solutions for improving the energy efficiency of historic buildings in urban areas]

Collaborative Project – GRANT AGREEMENT No. 260162

D 7.7 Relation historic buildings, EPBD

and EPBD CEN Standards

Deliverable D7.7 Relation historic buildings, EPBD and EPBD CEN Standards

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Technical References

Project Acronym 3ENCULT

Project Title Efficient ENergy for EU Cultural Heritage

Project Coordinator Alexandra Troi EURAC research, Viale Druso 1, 39100 Bolzano/Italy [email protected]

Project Duration 1 October 2010 – 30 September 2013 (36 Months)

Deliverable No. D7.7

Dissemination Level PU

Work Package WP 7 Design Tools & Quality Assurance

Lead beneficiary 12 TNO

Contributing beneficiary(ies)

Author(s) Marleen Spiekman, TNO

Co-author(s) Dick van Dijk, TNO

Date 23 September 2011

File Name WP7_D7.7_20110923_P12_Historic Buildings_EPBD_CEN.doc


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Table of Content

1 Introduction and abstract .................................................................................................................. 4

2 EPBD and historic buildings ............................................................................................................. 5

3 EPBD and EPBD CEN Standards .................................................................................................... 6

4 Historic buildings and CEN EPBD Standards .................................................................................. 7

5 Our suggestions on energy performance calculations for historic buildings .................................... 9

6 References ..................................................................................................................................... 10


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1 Introduction and abstract

This document introduces the recasted Energy Performance of Buildings Directive (EPBD), especially where it concerns old and historic buildings. The link between the EBPB and the EPBD CEN Standards is discussed and also the relation between the EPBD CEN Standards and historic buildings. Finally our suggestions regarding a CEN Standard on the energy performance of historic buildings is given. Questions, comments and suggestions on this document are welcome at: [email protected].


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2 EPBD and historic buildings

The Recast of the EPBD (Directive 2010/31/EU) has been published in May 2010 and is a revision of the first version of the EPBD (Directive 2002/91/EC). The Member States of the EU are now in the process of implementing the recasted EPBD and because the Directive is relatively new, the interpretation isn’t completely crystallised. Therefore the following summary of the requirements listed in the recasted EPBD concerning old and historic buildings is our interpretation of it.

The most important requirements that the recatsed EPBD states about existing buildings are the following:

When existing buildings undergo major renovation, the renovated building or renovated parts have to meet minimum energy performance requirements. In addition or as an alternative, requirements may be set for the renovated building elements.

If a significant part of a building envelope is retrofitted or replaced, the energy performance of this building element needs to meet minimum energy performance requirements.

If building systems (heating systems, hot water systems, air-conditioning systems, large ventilation systems) are installed, replaced or upgraded, system requirements shell be met. Intelligent metering should be encouraged when a building undergoes major renovation, as might be the installation of active control systems.

Energy performance certificates are required when a building is constructed, sold or rented out to a new tenant and for all buildings bigger than 500m2 which are occupied by a public authority and frequently visited by the public (in the latter case, the certificate also needs to be displayed).

Large heating and air-conditioning systems need to be inspected regularly.

In principle these requirements are applied to historic buildings as well, but there are exceptions. Except for the system inspections, Member States may decide not to apply the requirements listed above to (among other things) “buildings officially protected as part of a designated environment or because of their special architectural or historical merit, in so far as compliance with certain minimum energy performance requirements would unacceptably alter their character or appearance” and “buildings used as places of worship and for religious activities”.

For all minimum requirements goes that differentiation between new and existing buildings will take place and they are only applied in so far as they are technically, functionally and economically feasible. Individual countries/regions need to set the requirements based on calculated cost optimal levels.

Note that the level of the requirements is set by the individual Member States and therefore will differ from country to country. Also the methodology to determine the energy performance of a building or building element can differ per country. With the revision of the CEN EPBD Standards in the upcoming years, it is expected that the methodology used in the Member States will be further harmonised, but complete harmonisation can’t be expected in the upcoming years.


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3 EPBD and EPBD CEN Standards

The EPBD is a European Directive that obliges The Member States of the EU to implement various energy saving and energy efficiency regulations. The EPBD sets the framework of this legislation and the Member States individually fill in the details. The CEN EPBD Standards are developed mainly to facilitate the implementation of the EPBD in the Member States and describe calculation (and some measurement) procedures to assess the energy performance level of a building or building part. To facilitate the implementation, the CEN EPBD Standards do not prescribe a single methodology to derive the energy performance of buildings, but give a limited number of options. On national level one or more of these options can be selected and implemented. Another goal of the CEN EPBD Standards is to harmonise the methodologies developed in the individual countries.

The EPBD CEN Standards focus on:

energy needs for heating and cooling and energy use for space heating, cooling, ventilation, domestic hot water heating and lighting, inclusive of system losses and auxiliary energy

ways of expressing energy performance (for the energy certificate) and ways of expressing requirements (for regulations) and content and format of energy performance certificate

boiler and air-conditioning inspections

It is important to realise that the EPBD CEN Standards only provide calculation procedures (formula structures, measurement procedures, etc). Boundary conditions and input parameters (such as national climate data, general product/material/system data, user behaviour patterns, etc) are filled in nationally, as are the requirement levels. Also note that the EPBD CEN standards are aimed at calculating and checking the energy use of a building. They are not aimed to be design tools which provide a optimalisation assessment between for instance energy saving and comfort or health.

For more information on the EPBD CEN Standards see the Umbrella Document (CEN/TR 15615:2008). In the upcoming two years the EPBD CEN Standards will be revised to take the harmonisation a step further.


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4 Historic buildings and CEN EPBD Standards

The calculation procedures in the EPBD CEN Standards are based on physics and are therefore generally valid, so in principle the calculation of the energy performance of historic buildings is covered within the scope of the CEN EPBD Standards.

Some questions/discussing points regarding historic buildings and EPBD CEN Standards might be:

Does the EPBD CEN method take into account dynamic effects of moister flows on the energy use?

Answer: No, but if required a correction per month or season on the U-value is possible, or flexibility could be provided to use the adjusted U-value, based on in situ measurements.

Does the EPBD CEN method take into account thermal mass?

Answer: Yes, temporary storage of heat which is released at a later stage is taken into account via the utilisation factor of the heat gains, based on the heat capacity of the construction materials.

Does the EPBD CEN method take into account thermal bridges?

Answer: Yes, but note that the focus of the calculation procedure is energy use only and not condensation risk.

Does the EPBD CEN method take into account alternative energy saving regimes, like closing heavy curtains which prevents draught and gives extra insulation?

Answer: Yes, the EPBD CEN Standards provide formula structures in which all kinds of user behaviour can be taken into account as input data. Note that on national level input data can be restricted, leaving no room (yet) for alternative energy saving regimes. The reason behind this is that national legislation often is restricted by principles of controllability and verifiability. What building elements are constructed can be checked, but user behaviour cannot be verified and can easily differ from user to user. So related to building regulations user behaviour strategies often cannot be taken into account as energy saving measures. Which doesn’t mean that in practice this might not be a good solution.

Does the EPBD CEN method take into account traditional materials?

Answer: Yes, in the sense that the EPBD CEN Standards provides the formulas in which the physical parameters of traditional materials needs to be filled in. But note that the EPBD CEN Standards don’t provide databases with input data of any material (not of modern material either).

Does the EPBD CEN method give proper advice on energy saving measures related to historic buildings?

Answer: Giving advice on energy saving measures is out of the scope of the CEN EPBD Standards. The Standards provide the procedures to calculate the energy performance of a building, but does not advice which measures to take (not for new buildings either). The method can be used though to determine current energy and estimate energy use reductions for several sets of saving measures.

Does the EPBD CEN method give component requirements or requirements for the building as a whole?

Answer: The EPBD CEN Standards do not give requirements at all. Requirements are set on national level. It is a national choice whether requirements for existing buildings are set on component or building level.

(Note that in renovation situations setting requirements on building level is not always evident: a requirement should be set at a realistic level, but what is realistic when only the insulation of a house is replaced versus a situation in which both insulation and heating system are replaced? This might lead to unrealistic high insulation levels in the first case or much less than possible insulation in the second case. Therefore Governments might choose to set requirements on component level only.


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Also note that requirements are only a way of control. It doesn’t discharge anyone of his duty to thoroughly think trough a renovation design.)


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5 Our suggestions on energy performance calculations for historic buildings

Based on the above we have the following suggestions (note that these suggestions are suggestions from TNO and were not discussed with the EPBD CEN working groups):

There are several reasons why we’d advise against developing a separate CEN Standard with a complete calculation procedure for the energy performance of historic buildings:

o Developing energy performance procedures is complex and involves a lot of different subjects and expertises. Within the CEN EPBD working groups there have been (and are) dozens of technical experts working on the development of general energy performance standards (see the Umbrella Document: CEN/TR 15615:2008). It seems a waist of resources to start this process again especially for historic buildings, while the existing standards are in principle (maybe with some additions) valid for historic buildings as well.

o Realise that historic buildings which are not officially recognised as such need to follow the EPBD requirements. This means that the official national tools need to be used. Guidance and tools that build upon these official methods prevent double work. Also building upon these tools is much more transparent for the local authority/builder/owner than developing different ones autonomously.

Instead of a complete specific energy performance method for historic buildings, additions to the existing EPBD CEN Standards are more evident, if indeed necessary.

Evaluating the CEN EPBD Standards integrally (instead of e.g. only the insulation Standard) is a must for this, to prevent corrections which are already taken into account in other parts of the calculation procedure. To prevent this consultation between the Technical Committees of the CEN working groups involved is essential.

Based on our experience with developing energy calculation tools for non-energy experts: be careful with complex tools. Dynamic calculations might seem necessary for achieving a certain amount of accuracy, but

o a) you need an expert to make such calculations because non-experts easily (no offence, since it is not their expertise) make mistakes which cancel out the accuracy and worse.

o b) dynamic/complex calculations often require many detailed input parameters which often are unknown. The accuracy gained on one aspect might be counterbalanced by the arbitrary choices made for these unknown parameters.

The trade-off among calculation accuracy, risk of mistakes, inevitable arbitrary input, verifiability and transparency learned us that choosing complex method over simple methods is not evident.

Since the CEN EPBD Standards leave many aspects to the national methods (like input data of user behaviour, material data, etc) providing guidelines and examples how national annexes can include historic buildings within the implementation of the CEN EPBD Standards on national level might be very useful. As are guidelines how to improve the energy performance of historic buildings.

If aspects or gaps in the CEN EPBD Standards are detected which make them unusable to historic buildings, the upcoming period is a good period to start a dialog with the working groups of the CEN EPBD Standards, because they’ll become active due to the planned update of the Standards by the EU.


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6 References

CEN/TR 15615:2008 Explanation of the general relationship between various European standards and the Energy Performance of Buildings Directive (EPBD) - Umbrella Document

Directive 2002/91/EC of the European Parliament and of the Council of 16 December 2002 on the energy performance of buildings

Directive 2010/31/EU of the European Parliament and of the Council of 19 May 2010 on the energy performance of buildings (recast)

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