1
Position Paper on EC Consultation on Sustainable Buildings
Introducing our Network
Green Building Councils are not-for-profit, member-based organisations that are driving the transformation of
buildings, communities and users’ behaviour towards sustainability. The World Green Building Council is a
coalition of over 90 national Green Building Councils around the world, making it the largest international
organisation influencing the Green Building marketplace.
Our Europe Regional Network consists of over 30 national Green Building Councils and works in collaboration with
more than 3,500 member companies across Europe, which represent the full breadth of stakeholders in the
buildings industry. A crucial part of Green Building is bringing the whole value chain in our industry together to
provide better solutions, and this is exactly what we are doing through our members.
Executive Summary
This paper presents the views of the Europe Regional Network on the European Commission’s consultation on
sustainable buildings. We look forward to a dialogue with the Directorate Generals of the European Commission
and other stakeholders regarding the results of this consultation, and the direction that is consequently to be set
for the sector under the Commission’s upcoming Communication on Sustainable Buildings.
The contents of this paper broadly follow the structure of the Commission’s consultation questionnaire:







Part 1 (Introduction): This section contextualises the Commission’s present initiative, highlighting the
elements needed to achieve market transformation, the costs and benefits of sustainable buildings, and the
importance of the initiative to the European construction sector’s competitiveness.
Part 2 (Defining the Concept of Sustainable Buildings): This section addresses Section A of the
consultation, and comments on the scope and the focus of the concept of sustainable buildings as
presented in the Commission’s consultation questionnaire, which is restricted to resource efficiency.
Part 3 (Problems to Tackle): This section addresses Section B of the consultation, and comments upon
current and future demand for sustainable buildings, as well as the most appropriate levels of policy
intervention to drive sustainability regarding construction products and different building types.
Part 4 (Key Product Level Policy Recommendations): This section presents our key policy
recommendations for driving the sustainability of construction products, primarily through a staged phasein of Environmental Product Declarations across the single market.
Part 5 (Key Building Level Policy Recommendations): This section presents our key policy
recommendations for driving the sustainability of buildings. Foremost is the agreement of an EU framework
of lifecycle common indicators and calculation methodologies for sustainable buildings, followed by the
introduction of Green Public Procurement requirements based upon these. These measures would allow
for a period of data collection, benchmarking and incentivising before the potential introduction of other
policies, such as a basic sustainability labelling scheme for the residential sector.
Part 6 (Material Management): This concluding section comments briefly on the material management and
end of life sections of the consultation.
Annex: This contains our responses to the Commission’s multiple choice consultation questionnaire.
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1.
Introduction
1.1. Achieving Market Transformation
The transformation of the buildings sector towards sustainability will require the coordination of a number of key
elements:
(i)
(ii)
(iii)
Best Practice by Market Leaders: Organisations such as Green Building Councils and their market leading
members will need to constantly evolve and embed sustainability best practice through efforts such as
education, data collection and green building rating tools.
Required Practice by Policy Makers: Policy makers will need to translate sustainability practices which
prove feasible and scalable, to the whole sector, through a clear and long-term framework of policy and
regulatory obligations. This should create an enabling pathway towards best practice over time, including
the removal of market barriers to such practice and incentives to look beyond typical building practices.
Sustained Information Campaigns and Education by Central Actors: The associations and institutions
which represent those within Europe’s buildings sector will need to provide a sustained cycle of
information and education to help them make and profit from this transition. Public awareness-raising will
also be necessary to help people understand the benefits of and need for more sustainable buildings.
As an advocate of sustainable buildings, the Europe Regional Network warmly welcomes the European
Commission’s current initiative, which represents an important opportunity to ensure that the central building
blocks are in place for this market transformation.
We support the milestone aims for the buildings sector that are outlined in the Commission’s ‘Roadmap to a
Resource Efficient Europe’, which informs the aims of this consultation. Namely that: ‘By 2020 the renovation and
construction of buildings and infrastructure will be made to high resource efficiency levels. The Life-cycle approach
will be widely applied; all new buildings will be nearly zero-energy and highly material efficient, and policies for
renovating the existing building stock will be in place so that it is cost-efficiently refurbished at a rate of 2% per
year. 70% of non-hazardous construction and demolition waste will be recycled.’1
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COM(2011) 571
3
Indeed, many of our members are actively proving that even greater ambition is possible, though the challenges
for the whole sector to reach and then surpass these milestones are significant.
One of the crucial challenges for the Commission and for our sector will be to look beyond the resource efficiency
focus of this initiative, as this scope will serve to hold back efforts to drive demand for more sustainable buildings.
Only a built environment which is high performance in social, economic and environmental terms can be
considered sustainable. From decades of experience within the Green Building Council movement, we know that
initiatives narrowly focused on a single one of these elements will fail to transform the market.
1.2. The Costs and Benefits of Sustainable Buildings
The World Green Building Council’s report ‘The Business Case for Green Building’ examined international peer
reviewed research on the costs and benefits associated with sustainable buildings2. Amongst its findings, the
report highlighted that there are currently significant misconceptions about the costs associated with
sustainable buildings. The diagram below shows the gap between the actual cost of delivering sustainable
buildings and the significantly greater costs that the wider industry perceives are involved.
Global trends show these costs being driven down over time, as the construction value chain gets more
accustomed to delivering sustainable solutions. Moreover, there are manifold operational cost benefits to green
buildings, aside from energy costs, that offset construction premiums during the lifecycle of the building,
alongside a multitude of other business benefits to developers, owners and tenants/users (see diagrams
overleaf).
2
Those that are certified by rating tools or another national green standard above regulatory minimum standard.
4
5
1.3 The Green Building Market is Global: Inaction will Impact the EU’s Competitiveness
Despite ‘The Business Case for Green Buildings’ proving that many construction businesses are realising the
bottom line benefits of building more sustainably, many in the European buildings sector have yet to make this
transition. European companies risk being left behind in the global green building market.
This year’s ‘Global Green Building Trends’ report shows levels of green building project activity3 on the rise
worldwide (see ‘Levels of Green Building Activity by Firms Around the World’ below). Some of the world’s leading
sustainable building markets are in the EU, but other countries are seeing the number of firms focused on
sustainable project work grow steadily (see ‘Percentage of Firms With more Than 60% of Work Green’ below).
The European Commission’s current initiative therefore represents an important challenge for our region, and it is
one that is crucial to the European construction sector’s competitiveness in the global economy: how do we
achieve market transformation?
Lack of political support/incentives is one of the key challenges to increasing green building activity4. Incentives,
and long-term certainty and clear timescales in the form of policy and regulation, will be needed to overcome
current market barriers and inertia, and move towards more sustainable and competitive practices in Europe.
Industry needs to be at the forefront of shaping this collaboratively with policy makers, to ensure it is the right fit
for a globally competitive green building market that is good for business as well as people and the environment.
In the following sections, we have outlined the shape we believe that future policy for the sector needs to take, in
response to the various sections of the Commission’s consultation questionnaire. These proposals are put
forward as a basis for further debate, and we welcome comments by other stakeholders on them.
Our full responses to the Commission’s multiple choice questionnaire are contained in the Annex to this paper,
and referenced throughout the body of this response where relevant.
3
Projects built to a rigorous green building rating system or those that are energy efficient, water efficient and address other
aspects of sustainability.
4
Page 12, Global Green Building Trends, McGraw-Hill Construction in association with UTC, World GBC and USGBC.
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2. Defining the Concept of Sustainable Buildings
As noted in our response to Question 1 (see Annex), we have ranked all listed aspects of environmental
performance as important or somewhat important, based on their relative lifecycle impacts. In addition to these
responses, we would like to raise the following points regarding the scope and focus of the concept of sustainable
buildings in the context of EU policy.
2.1 Scope
We understand that the scope of the sustainable buildings concept is limited to resource efficiency under this
Commission initiative, primarily led by DG Environment. However, from our experience with green building rating
tools, the market is already demanding information and improvements regarding additional elements of building
performance. Importantly, we know that some performance aspects which sit outside pure environmental
performance are actually key elements for driving demand for more sustainable buildings. Therefore, any
initiative which focuses solely on resource efficiency risks failure in terms of driving demand in the market.
Policy in this arena will therefore need to represent a joined-up effort across the Commission.
Other considerations that impact resource efficiency include:

Transport and Amenities: If a new building is designed without due regard to transport considerations and
proximity to other relevant amenities, it may require that its users use resources and create emissions in
providing their own personal transport. Distance also creates inconvenience, and thus impacts demand.
However, as user behaviour is a significant factor, this may be difficult to account for in any regulation.
Other considerations concerning environmental performance include:




Land Use: Encouraging use of land previously subject to development (contaminated or remediated) before
undeveloped land.
Biodiversity: Whilst dealt with under EU law, discouraging the reduction of biodiversity and encouraging its
promotion is absent and is an important design consideration.
GHG intensity of energy use: Given the environmental impact concern associated with energy use is
climate change, GHG intensity is an important measure of how sustainable any energy used is.
Toxicity/Hazardous Materials and Health Impacts: The toxicity and potential health impacts of building
materials are important areas where greater data and transparency is being demanded by the market.
Other considerations that help drive demand amongst end users for more sustainable buildings include:




Indoor Air Quality: This is crucial to creating a healthy and productive indoor environment.
Daylight: This can improve environmental performance of a building through resource efficiency, and views
and daylight are proven to improve user experience and productivity.
Acoustic Quality: Particularly in buildings where user concentration is important (schools, offices etc.), an
environment that helps decrease noise/distractions is important.
Use of Space: Ensuring space is well utilised to suit user needs and ensure reduction of wasted resource.
The above categories should be part of any dialogue around sustainable buildings. It is crucial that economic and
social performance issues are considered in order to help drive demand for better buildings. The business case
for resource efficiency is significant, but the real business case for sustainable buildings lies beyond this.
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2.2. Focus
It is good to see the aspects of environmental performance listed in Question 1 broadly mirror the building
lifecycle. However, there are a few important points to note regarding the focus of any EU sustainable buildings
policy:




Assessment must be focused at the building scale: The focus in Question 1 appears wrongly placed on
product/process scale. Building level lifecycle analysis (LCA) provides the only accurate view on whether the
solutions provided for a building (in terms of product/process) are the most sustainable over its whole
lifecycle given its context and function (see below). Indeed, building assessment often needs to look
beyond the building scale to a development’s surroundings in order to properly assess the most
sustainable solutions.
Building performance should not be assessed without reference to context: A building in Southern Spain
may require a high level of water efficiency during its lifecycle to be considered a sustainable building. In
Sweden, where water scarcity is not an issue, water efficiency is far less relevant. Context is key when
considering what is important, and whilst our overall response to the questionnaire reflects the general
sense across the region, it should be noted that answers from different countries across our Network vary.
Building performance should not be assessed without reference to function: A highly resource efficient
building that does not perform its designated function well constitutes resource waste. It is for this reason
that green building rating tools have evolved to cater for different building typologies (e.g. offices, schools,
logistics centres etc.). An assessment of a hospital and a logistics centre would not be expected to take the
same approach to category weightings – their users are fundamentally different in terms of their needs.
The in-use phase should be a significant area of focus: Due to numerous market barriers (such as split
incentives) impeding progress in this area, this should be a significant area of policy focus.
3. Problems to Tackle
3.1 Current and Future Demand for Sustainable Buildings
Please see our answers to Questions 2A and 2B (see Annex).
In some of the EU’s leading green building markets, the use of green building rating tools is growing rapidly,
which is currently the best measure of demand. This growth is mostly in the non-residential sector, though
markets like France and Sweden are seeing rapidly growing demand for residential rating tools (HQE in France and
Miljöbyggnad in Sweden).
Recent IVG Research found that the number of non-residential projects certified to BREEAM, DGNB, HQE or LEED
in Europe had tripled between 2011 and 2013.5 Current figures for the number of green certified non-residential
and residential projects in Europe are as follows:
5
IVG Resarch LAB 3/2013, ‘Completed Certifications in Europe’, p6
8
Rating System
Non-residential Certified Projects
Residential Certified Projects
Total
7,163
16,232 (to Ecohomes/Code for
Sustainable Homes)
23,395
371
32
403
HQE
1,539
33,000 (housing units rather
than projects)
1,539 (plus
residential
projects)
LEED
481
22
503
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7
15
BREEAM
DGNB
VERDE
Demand for voluntary green building rating tools is typically strongest in the offices sector, with industry and
retail following. Figures below are taken from the Netherlands, where offices pursuing the local green building
rating tool BREEAM-NL now represent approximately 75% of the total new build market (by square meters).
Rapid growth in the number of buildings that are registered or certified as sustainable under existing assessment
schemes is also occurring in other markets. The graph below shows the rapid growth in demand for the Swedish
assessment scheme Miljöbyggnad in Sweden, alongside LEED and BREEAM, which has been concentrated over
the last two years. Similar growth patterns in a number of European countries show green building rating tools
starting to be widely used in certain parts of the market.
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Whilst demand is increasing in certain sectors such as offices, it is not generally well documented in others where
the market for sustainable buildings is still in its infancy, such as the residential sector in the majority of EU
countries. The graphic below shows expected levels of activity across various project types in Europe and other
regions, noting the percentage of respondent firms with planned green projects in each area. Demand in the
residential sector is far considerably lower overall than demand in the non-residential sector.
3.2 Appropriate Levels/Forms of Intervention
Please see our answers to Question 2C (see Annex). There is no single level of policy/regulatory intervention
that will be entirely appropriate by itself to drive demand, and appropriateness entirely depends on the form
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of intervention. We have indicated the primary level of intervention that we feel is appropriate in our answers to
the Commission’s questionnaire, though also indicated secondary levels at which some coordination/intervention
may also be needed or help to drive demand. This situation also differs from country to country.
In general, we would advise the following as the most appropriate levels of intervention:


At product level: As products travel across borders, an EU approach to policy/regulation is the most
appropriate, and an international one would be the ideal solution, so should be pursued. However, given
the time international agreements take, this may not be the most appropriate level of intervention if the
goal is to drive the market in the near-term.
At building level: The most appropriate level of intervention is national, so that context and functional
specifics can be accounted for, and further regional/local tailoring may be necessary. Nevertheless, some
forms of EU intervention in the near-term are appropriate in our view. Over the longer-term EU policymakers may need to intervene further if too little action is taken at national level to ensure the EU’s
resource efficiency and competitiveness goals are met. A ‘carrots first, sticks later’ approach is preferable.
The following diagram indicates what we believe should form the Commission’s priority list in terms of EU policy
interventions based upon likely future demand (in a business as usual scenario) and other factors such as the
prevalence of market barriers.
Highest priority for EU intervention (on
basis of demand and other factors)
1. Construction Products
2. Public Buildings
Lowest priority for EU intervention (on
basis of demand and other factors)
3. Residential Buildings
4. Non-residential Buildings
We have previously stated a concern that the EU Ecolabel for Office Buildings project is not adding value as an EU
initiative in terms of driving demand and tackling market barriers where this is most needed, and still hold this
view. However, EU policy will be needed, and in the following Sections of our response we have outlined our
recommendations for EU policy interventions firstly at product level, and secondly at building level. These
include recommendations to deal with issues that the Ecolabel work was aiming to deal with, namely the
convergence and comparability of existing initiatives.
4. Key Product Level Policy Recommendations
Please see our answers to Questions 3C, 3D, 4F, 9A, 9B, 10A, 10B, 12A and 12B insofar as these are relevant to
product level considerations (see Annex).
4.1. Phase-in of Environmental Product Declarations
Central Recommendation: Environmental Product Declarations based on EN15804 should eventually be
mandated across the EU through a ‘phase-in’ approach.
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Environmental Product Declarations (EPDs) are necessary to provide LCA data for building level LCA. They are also
necessary to create a virtuous circle for the supply chain. The key industry need is to have open, transparent
environmental data readily available throughout the supply chain, so the supply of EPDs must eventually be a
supply chain obligation for anyone placing construction products on the single market, though manufacturers will
have the primary obligation to draft them.
We must firstly consult widely to have a harmonised EU LCA standard that is fit for purpose and widely endorsed.
A lack of certainty over the standard for EPDs has held companies back from commissioning them. Large
European companies are now ready for the transition to EPDs, and a harmonised standard and a timeline for
consequent regulation will provide certainty for the investments required. For European SMEs, a phase-in will be
needed, which allows time for EPD business services to scale and reduce in cost, and which provides the needed
support and incentives for SMEs to make this transition.
The following provides an indicative timeline of our recommended EU interventions to ensure a move towards
lifecycle analysis by 2020. Clear timelines and horizons will be needed to help the market scale-up and help
businesses prepare adequately, so the transition to EPDs does not impact their competitiveness.
Phase 1
Phase 2
Phase 3
Phase 4
Phase 5
Information
dissemination
followed by public
consultation on
EN15804 to agree
robust
harmonised LCA
standard for
construction
products
Support work to EPD
Platform to be
completed so
infrastructure for crossborder EPD recognition
in place (based on
EN15804). Commission
set clear framework for
generic EPDs
EU Green Public
Procurement
requirements to be
introduced at building
level, including
requirement for EPDs
(based on EN15804)
from public sector
supply chain
EU and national
EPD support
schemes in
operation,
including support
for SMEs.
Incentives for EPDs
put in place (e.g.
tax)
Mandatory EU
EPD requirement
to be introduced
for companies
placing
construction
products on the
market
4.2. Phase-in Stages
Phase 1
A harmonised LCA standard for construction products needs to be agreed. EN15804, the product level standard
developed under the CEN/TC 350 framework, should be the basis of this. This standard will need to be consulted
on more widely to ensure it is sufficiently robust and accepted by all stakeholders, so any consultation will need
to be preceded by appropriate information dissemination to engage stakeholders both inside and outside the
expert LCA industry. EN15804’s scope will need extending to include equipment and service providers, and end of
life and other current issues will also need to be resolved (also see Section 6.4 below). The results of this process
would of course also be important for informing the new Construction Products Regulation Basis Work
Requirement 7 regarding the sustainable use of natural resources.
We understand that the Commission’s new Product Environmental Footprint seeks to deal with outstanding
issues with EN15804. These are issues that need resolving, however, we do not understand the approach of
creating a new initiative to resolve them, as this has so far served to confuse the market. These issues should be
resolved through stakeholder consultation and through the CEN process.
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Phase 2
A Core-EU EPD must be agreed, based on a revised EN15804. A platform will be needed to serve as the
transparent and open data portal and quality control mechanism for the EU Core-EPD, and to develop common
quality management and verification procedures to enable mutual recognition across the region. This should
ideally be a platform that represents a public-private collaboration, in which industry is in the driving seat as the
expert, and the EU is involved to ensure that commercial and proprietary concerns do not lead to a lack of
transparency over data.
Good work has already been done by the ‘ECO Platform’ towards achieving much of this, and this platform should
be trialled further to see if it is an appropriate platform for the Commission’s support and collaboration rather
than instigating a new EU platform. The creation of multiple platforms should be avoided.
Further support will be needed at EU level to help reduce the costs associated with EPDs for all those required to
commission them. Setting a clear framework for generic EPDs, alongside providing appropriate software support,
are ways in which the European Commission could help reduce associated costs for all companies.
Phase 3
EPDs should be introduced initially through demand-side EU Green Public Procurement (GPP) measures, to
prepare the market for regulation. Ensuring that the public sector leads in order to scale-up the market is a
principle that has proved successful under EU energy efficiency regulation for buildings. We have commented
further on the need for EU GPP measures in Section 5 (‘Building Level Policy Recommendations’).
Phase 4
Before mandatory EU EPD legislation can be introduced, EU and national level support schemes will need to be in
place to encourage and assist companies with the transition to EPDs. As well as information and education
services for smaller companies, these could also include forms of financial and fiscal incentives, such as tax breaks
for products which have EPDs compliant with the existing schemes.
Phase 5
The final phase will be to mandate EPDs for the whole market.
5. Key Building Level Policy Recommendations
Please see our answers to Questions 2A, 2B, 2C, 3C, 3D, 4M, 7A, 7B, 8A, 8B, 8D, 8E, 8G, 8H, 13A, 13B insofar as
these are relevant to building level considerations (see Annex). In overview, we believe that EU building level
policy will need to include the following elements, which are explained in detail in the following sections:
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Phase 1
Phase 2
Phase 3
Phase 4
Phase 5
Phase 6
Information
dissemination
followed by
public
consultation on
CEN/TC 350 and
other relevant
initiatives, to
create robust EU
framework of
LCA common
indicators and
calculation
methodologies
Publish EU
framework of
LCA common
indicators and
calculation
methodologies
to enable
existing
initiatives (e.g.
green building
rating tools) to
align with this.
Launch
information
campaign on
benefits of
performance
improvements
under indicators
EU Green Public
Procurement
criteria to be
introduced at
building level,
based on EU
framework of
LCA common
indicators and
calculation
methodologies.
Provision of
public sector
lifecycle costing
training to be a
Member State
requirement. EU
funding made
conditional on
applying GPP
criteria
Collection of
data across
national GPP
programmes.
Data used to
inform
benchmarking
on a national
basis,
supported by
Commission.
Feasibility of
basic EU
labelling
scheme (based
on certain key
indicators) for
residential
sector to be
assessed
Member
States
introduce
financial/fiscal
incentive
schemes for
sustainable
buildings
based on
country
benchmarks
(informed by
Commission
guidance).
Existing
initiatives (e.g.
rating tools)
used to
demonstrate
eligibility
Basic
residential
labelling
scheme (based
on common
indicators)
introduced if
feasibility
studies prove
viable. Used to
demonstrate
eligibility for
national
financial/fiscal
incentive
schemes
5.1 An EU Framework of Common Indicators and Calculation Methodologies (Phases 1 & 2)
Central Recommendation: Agree an EU framework of common indicators and calculation methodologies for the
lifecycle performance of sustainable buildings based on the work of CEN/TC 350 and other relevant initiatives.
Assessment tools only work effectively to guide the design of better, more sustainable buildings if they are
context and function specific (see Section 2.2 above), so creating an EU definition or set of weightings through an
EU assessment tool (such as an Ecolabel) would be a step in the wrong direction.
However, an EU ‘framework’ consisting of common indicators (e.g. GHG, water, waste etc.) and associated
calculation methodologies for LCA performance under each indicator would be a step in the right direction – for
both new and existing buildings. National initiatives (market driven or regulatory) required to converge with such
a framework would therefore be comparable with regard to these key indicators, and the concept of a sustainable
building would be more readily accessible from a policy perspective.
This work is already underway, and was in fact directed by the Commission under a mandate in 2004. CEN/TC 350
“Sustainability of Construction Works” has started the process of creating a common EU framework of indicators
and calculation methodologies for both product and building level. It has the advantage of covering
environmental, social and economic aspects, which is crucial for any EU initiative on sustainable buildings. Any
common indicators should not be restricted to resource efficiency if they are to be successful in driving demand
for better buildings (see Section 2 above).
It is our belief that the work of CEN/TC 350 should be built upon as a foundation, though not uncritically,
particularly given the fact the mandate was set nearly a decade ago. The CEN process has also been largely
restricted to industry LCA specialists, and there is a need to consult more widely on the conclusions it has reached
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and modify the standards as necessary to ensure that they are robust, as well as widely understood and endorsed
by all relevant stakeholders (businesses, NGOs, the public sector etc.).
Alongside the CEN work, much valuable work has been done around the theme of common key indicators and
calculation methodologies by projects such as SBAlliance, Open House and SuPerBuildings. In terms of creating a
EU framework that appropriately enables dialogue and functions from a policy (and not just a purely technical)
perspective, this work should also be widely disseminated and examined under stakeholder consultation.
Good quality indicators are already available for the lifecycle performance of buildings, we are simply missing
convergence around key indicators for the region. So, the Commission’s aim going forward should be to
disseminate, strengthened and converge the existing work, and help stakeholders come to a collective view on
the most appropriate common indicators and calculation methodologies for sustainable buildings. The result
should:

Provide a common language for all stakeholders;

Reinforce trust by ensuring transparency; and

Be relatively easy to communicate.
A concerted regional information campaign, aimed both at industry and the public will be necessary to
accompany these new indicators, evidencing and educating on the benefits (social, economic, environmental) of
performance improvements in these areas. This should help drive public demand, both in people’s personal and
professional lives. This information campaign should identify national routes for data collection, which can be
brought together across the region and disseminated. Data collection will be able to progress far more rapidly
once initiatives converge around an EU framework.
5.2 Green Public Procurement (Phase 3)
Central Recommendation: The public sector should lead the market. Introduce mandatory EU Green Public
Procurement criteria based on the agreed EU Framework of Common Indicators and Calculation
Methodologies.
The key aims of any EU sustainable buildings initiative should be to create transparency and comparability,
improve performance, collect data and enable benchmarking. In the move towards country level data collection
and benchmarking, this is an area where the public sector can and should have a leading role. We can learn much
from experience with the Energy Performance of Buildings Directive here. New practices for the market are
more appropriately phased in through demand side Green Public Procurement (GPP) measures rather than
regulating the wider market as a first step.
As existing overview studies have demonstrated6, there is already good GPP work being undertaken in various EU
countries, but common performance criteria do not exist across the region. Monitoring of data and results at EU
level, and effective sharing of best practice has therefore proved extremely difficult. Mandating the
implementation of national GPP requirements based on an EU framework of lifecycle common indicators and
calculation methodologies (see Section 5.1 above) would therefore greatly assist in improving the sector’s
sustainable competitiveness as a Lead Market.
6
‘Best practice on green or sustainable public procurement and new guidelines’ published in February 2012 under the Open
House FP7 project is a useful summary.
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Additionally, this would further encourage the alignment of national voluntary green building rating tools with the
EU framework, as these are often used as a means of complying with sustainable procurement standards, and
would only be eligible as a GPP compliance tool if aligned with the EU framework. Such existing tools may have an
important role in GPP, as third party/independent audit requirements are usually a feature, and this is so far
lacking in most national GPP schemes. An independent auditor requirement, as under the EPBD, will need to be
introduced alongside any GPP scheme to ensure that it is robust and that good quality data is being produced.
There are public sector concerns about the increased cost of procuring sustainable buildings. Training in lifecycle
costing would enable the public sector to determine what represents the most economically advantageous
tender on a lifecycle basis. As stated in Section 1.2 above (‘The Costs and Benefit of Sustainable Buildings’) and in
‘The Business Case for Green Buildings’, lifecycle cost benefits offset construction stage premiums for sustainable
buildings, and their user health and productivity benefits are significant. The value lost to taxpayers and public
sector workers through a ‘lowest price’ default criteria is significant.
There are also other concerns which governments resistant of GPP should be aware of. In the current climate,
many public services are downsizing. Numerous studies have demonstrated that the growth of the green building
market we are seeing across Europe is generally associated with an increasing ‘brown discount’ on sales of nongreen properties, as they become increasingly less desirable assets.7 In a climate where the public sector may
need to dispose of property assets, management of their portfolio’s sustainability will be important to decrease
the risk of incurring significant financial losses on these assets.
Many public construction projects are beneficiaries of EU funding. The need for the public sector to lead is a
principle of much Community legislation on the basis it is often a country’s largest construction client. As
indirectly through EU funding, the EU is the region’s largest construction client, this same principle must apply.
Any EU funding for public projects must therefore become conditional upon applying GPP criteria.
5.3 Data Collection, Benchmarking and Incentivising (Phases 4 & 5)
Data collection and reporting should be a requirement under national GPP programmes, so that this can be
systematically collated to enable countries and the Commission to start the process of accurately benchmarking
performance for different building typologies.
Based upon this exercise, the Commission should be able to formulate guidance to Member States about the
level of lifecycle building environmental ‘footprint’ that should be incentivised by national financial/fiscal
incentive schemes (i.e. the highest performers).
The requirement for such schemes will probably need to be voluntary in nature initially, but the Commission’s
data collection under GPP schemes should also aim to explore and demonstrate the economic case for
performance improvements. Where there is proven to be a robust economic case, a requirement to introduce
national incentive schemes could be made mandatory.
Existing or new schemes that have third party auditor requirements could be a means of robustly demonstrating
eligibility under such incentive schemes.
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‘The Business Case for Green Building’, World Green Building Council, 2013
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5.4 Basic EU Labelling Scheme for Residential (Phases 4 & 6)
Similarly based upon the lessons learned during the benchmarking exercise for the public sector, the Commission
should assess the feasibility of introducing a basic EU labelling scheme for residential that examines performance
across certain key indicators from the EU framework. In administrative terms, this would need to build on the
existing infrastructure in place for Energy Performance Certificates rather than creating a separate layer of
administration.
Given current sensitivities in terms of pricing pressures and provision of housing in many Member States, very
robust analysis and consultation on the options will be needed before any such scheme is progressed. However,
we are firmly of the belief that finance rather than environmental requirements is by far the bigger issue in terms
of Europe’s housing sector. Given the increasing evidence that sustainability performance positively impacts the
risk profile of property as an investment (for both institutional investors and home buyers), we believe that the
administrative burdens of any such scheme could be considerably offset in terms of de-risking investment in this
sector.
6. Material Management
Please see our answers to Questions 5A, 5B, 12A and 12B (see Annex).
6.1 Issues are material/product specific so it is hard to generalise
It is difficult to generalise about many of the options in the Commission’s questionnaire given the situation varies
based upon the specific material or product that is in question. Certain material (e.g. copper) is of higher value, so
there are greater economic incentives to reuse/recycle it, and conversely there are lesser incentives for materials
of lower value.
However, across all areas in the Commission’s questionnaire, some degree of improvement is needed. The most
appropriate levels of intervention are considered to be at national and/or industry level, though there are
appropriate areas for EU intervention which are noted below.
6.2 Landfill Tax will help level the playing field for secondary materials
In terms of levelling the playing field at the lower value end, periodic increases in landfill tax have had significant
positive impact on the market for secondary materials, and the tax regime may be a useful and simple instrument
for Member States to provide economic incentives where these are absent. Under the Commission’s current
review of waste management and recycling targets, targets under the Landfill Directive ought to be assessed and
made more ambitious if this is determined not to cause significantly material negative economic impacts. Other
tax incentives could also be explored, such as a decreased VAT rate for the use of secondary materials.
As an overall target, we fully support the target in the Roadmap to a Resource Efficient Europe of reducing landfill
of non-hazardous construction and demolition waste by 70% by 2020. Some of our members are looking to
achieve zero waste-to-landfill significantly before this date, and so there may in fact be room to raise the level of
ambition here dependent on how the market progresses.
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6.3 Lifecycle Analysis should Determine the Best Solutions
Taking the example of recycled content in products, it is easy to simply request more on the basis that recycling
sits high-up the EU’s waste hierarchy. However, LCA must be used to determine suitability of proposals. There is
often a trade-off between higher rates of recycled materials and embodied energy/carbon that we must be aware
of, and lifecycle costing should be used to help cost optimisation and to build the business case for more
sustainable solutions.
6.4 The EU Should Develop End-of-Life Criteria
The development of end-of-life criteria in relation to construction products will be another key area where the EU
has an important role to play, already identified under the Roadmap to a Resource Efficient Europe. This will be
particularly important for materials which are hard or impossible to recycle.
Again, CEN TC/350 has developed end-of-life criteria within EN15804, which will need to be thoroughly reviewed
over time. Designing for deconstruction is currently thinking which is poorly embedded across the sector, and
could also potentially be designed into any end-of-life considerations revisions of EN15804.
6.5 Closed Loop Thinking should be Encouraged
In terms of ‘Other’ categories, closed loop thinking and processes are significant omissions from this part of the
consultation. Any EU work around end-of-life criteria should as a minimum encourage a closed loop approach in
order to move towards a circular economy.
World Green Building Council – Not at limited company (Business No. 842737454) – 5 Shoreham Drive, Downsview Ontario, M3N 1S4, Canada –
www.worldgbc.org – For further information about this response please contact europe@worldgbc.org
EU Transparency Register ID Number: 482897410370-35
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Annex – Europe Regional Network’s responses to the Commission’s multiple choice questions
We have completed the Commission’s multiple choice questionnaire as indicated throughout this Annex. As our Network contains Green Building Councils (GBCs)
from many countries across the region, we have used individual answers from national GBCs and further discussions within our Network of GBCs to arrive at answers
that we feel are the most appropriate for the EU as a whole. It should therefore be noted that there is country-to-country variance on a number of the issues.
The symbol
represents the answer we have provided in the Commission’s online form as the most appropriate, as only one answer is allowed.
However, it is our belief that many questions do not have one simple answer, and in some cases the structure of the questionnaire led us to give potentially
misleading or unclear answers. For this reason, the symbol
represents other answers that may also be appropriate.
The main body of this paper provides further details on our position on each area by reference to the question numbers, as well as providing clarifications where we
felt the structure of the questionnaire did not allow us to provide the most appropriate response.
Given the structure of the questionnaire, we feel that some caution must be applied when interpreting stakeholder responses.
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NOTE: The boundaries between the first and second aspects are unclear. We have counted material use for products such as concrete/steel etc. as that used for
producing them, even though they are also materials used on the construction site.
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Note: European Green Building Councils work with a number of green building assessment schemes, including BREEAM, DGNB, HQE, LEED, Miljöbyggnad and VERDE,
amongst others.
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