Climate Positive Europe Alliance
CPEA
The Climate Positive Europe Alliance (CPEA) and its member organisations all share a common purpose: to collaboratively embed sustainability principles and practices within core built environment activities – ranging from planning and design, financing, construction, use and operation, and deconstruction by taking a whole life cycle view.
ID: 865678148148-67
Lobbying Activity
Response to EU taxonomy - Review of the environmental delegated act
3 Dec 2025
Find attached the feedback of CPEA
Read full responseResponse to European Affordable Housing Plan
2 Jun 2025
The Climate Positive Europe Alliance (CPEA) welcomes the initiative of the European Commission for supporting Member States housing policies through the development of a European Affordable Housing Plan to address the current housing crisis. First and foremost, we believe it is crucial to define affordable housing. We propose adopting the definition from the OECD publication Building for a Better Tomorrow. In line with this definition, financial interventions utilising public funds for the construction and renovation of homes, particularly for vulnerable groups, should aim to ensure that housing costs do not exceed 30% of the household's gross income. In addition, we feel that the initiative needs a clear commitment to exploring and promoting alternative approaches to solving the housing crisis. At present, the debate is heavily focused on new construction and building costs, without prioritising or highlighting alternative solutions. We strongly advocate that more emphasis must be placed on the use of existing buildings. The renovation, repurposing and adaptation of existing buildings and the tackling of (vacant) buildings, including second and holiday homes, both in urban and in rural areas, are key to solving to the housing crisis. More urban densification and infill projects are needed to avoid further urban sprawl. Permitting for zoning, extensions, conversions, splitting of existing spaces and change of use should be made easier. Incentives for repurposing and vertical extensions are needed, while removing administrative barriers (e.g., exemptions for rooftop extensions, even beyond current building height limits, especially in areas with predominantly one- or two-storey buildings).This should be coupled with improving sustainable transport connections between demographically deprived areas and centres that are offering better employment and education opportunities as well as revitalising village districts and inner cities. These options not only generate housing more quickly, significantly reduce land consumption, preserve established urban and rural structures, and considerably lower environmental impact but can also serve as a lever for subsequent private investment. Given that the Plan envisions incentive schemes to increase the supply of available housing, our general position is that all buildings that are (co)financed with public funds must be constructed and renovated in accordance with high standards of measurable sustainability (e.g., EU Taxonomy, Level(s), DGNB System) Furthermore, digitalisation in real estate management in cooperation with municipalities need to be encouraged. The introduction of digital solutions, such as Digital Building Logbooks and the creation of (vacancy) databases can enable more effective processes which also provide evidence of good sustainability performance. This in turn can also speed up the issuing of building permits. Affordability and rentability of projects are typically opposing project goals if market mechanisms are applied. Reducing the costs of construction and renovation can be achieved by lowering excessive or inadequate standards, e.g. adding parking spaces, fire safety or the un-reflected application of standards of new buildings to renovation projects. This is why new standards are needed for the conversion of existing buildings that enable cost-optimised and sustainable conversions. In addition to adaptable and long-lasting buildings, the aim is to create well-designed and participatory meeting places both indoors and out-doors. These must also and especially apply to people who, for financial or other reasons, are unable to create their own safe space. Affordable housing and living must not just be about accommodation but must also include adequate housing. People who have no permanent residence also need more protection and consideration. This aspect of society is completely ignored in the political debate, even though the number of homeless people is rising.
Read full responseResponse to Taxonomy Delegated Acts – amendments to make reporting simpler and more cost-effective for companies
25 Mar 2025
The EU Taxonomy provides a substantial tool for gaining insight into corporate investments by classifying turnover, capital expenditure, and operational expenditure, thereby also delivering critical insight into the sustainability aspects of debt-financed investments. However, first-movers are being penalized despite having invested significant effort in understanding and implementing regulations, adapting processes, and digitalizing their operations. For the calculation and practicability of the green asset ratio, we refer to the work done by the Sustainable Finance Advisory Committee of the Federal Government of Germany, available on their website. Via our close cooperation with GBCs across Europe, particularly in Denmark, Austria, Spain, Germany, France, Ireland, Hungary, and Croatia, we have gained significant insight in the application of technical screening criteria in the construction and real estate. The focus in further developing the significant contribution technical screening criteria should be on selecting methodologies and key performance indicators that align with the strategic goal of the environmental objective, i.e. for climate change mitigation the aim is to reduce the greenhouse gas emissions, consequently the reduction of greenhouse gas real performance of buildings should be evaluated, instead of utilizing EPCs, which are based on calculations and the primary energy demand of buildings. Furthermore, the regulation should give clear instructions on the proposed partial alignment concept, to avoid green washing claims. The implementation of Do No Significant Harm (DNSH) criteria has revealed methodological difficulties, especially the inflexibility of the methodologies. Simplification would be welcomed to reduce the complexity and reporting burden. The EU Commission can however consider alternative policy instruments to achieve the environmental objectives, i.e. reducing hazardous materials production and circulation, rather than mandating reporting on the topic by parties. In particular to the DNSH Pollution Criteria and the Appendix C, two options were proposed. We strongly recommend the implementation of option 2, replacing the paragraph with the amendment given in the Annex of this Document. In conclusion, Europe must chart a strategic path forward as a global leader in climate action. This requires a collaborative approach that goes beyond traditional regulatory frameworks. EU policy should actively work with diverse stakeholders across the real economy, financial sector, and civil society to comprehensively frame and assess the materiality of environmental objectives. Critically, small and medium-sized enterprises (SMEs) must be explicitly included in this development process, ensuring they are properly addressed and equipped to participate effectively. The goal is to develop a harmonized approach that reduces individual company reporting efforts while ensuring data points are strategically defined. These metrics must be capable of effectively steering transformation, aligned with overarching EU goals, and grounded in real performance measurements. By creating supportive mechanisms that simplify compliance for SMEs without diminishing their accountability, the EU can ensure these smaller businesses are not left behind in the sustainability transition. The ultimate objective is to create a robust regulatory environment that encourages meaningful sustainability efforts, rewards proactive approaches, and provides clear, implementable frameworks for businesses of all sizes in their journey towards a sustainable future. By maintaining this nuanced, inclusive, and collaborative approach, Europe can continue to drive meaningful progress in addressing the critical challenges of climate change and environmental sustainability.
Read full responseResponse to Initiative on EU taxonomy - environmental objective
3 May 2023
Increasing global resource use and associated environmental impact are necessitating a radical shift towards whole lifecycle approaches and implementing circular economy practices. Given high levels of resource intensity and waste generation, construction and real estate activities have a crucial role in the transformation towards a sustainable and resource-efficient EU economy. Against this background we welcome the Commissions work regarding the EU Taxonomy Circular Economy criteria as we see the EU Taxonomy as a valuable trigger to speed up the much-needed sectoral transition and are fully supportive of the overall concept and thinking behind the revised criteria for a transition to a Circular Economy. However, we are concerned regarding their level of ambition which may turn out to be challenging in terms of large-scale market application. To avoid creating uncertainty in the market, we deem it necessary to provide unambiguous definitions of scope and methodologies or, alternatively, to align the proposed criteria with existing and tested methodologies and tools. Especially with regard to setting specific quotas for use of reused and recycled materials it is crucial to ensure that the overall market and national/local legislative context helps facilitate implementation. This could for example entail requirements for construction materials and building components to clearly depict their recycled content, the existence of potentially hazardous substances and future circular pathways. Equally important would be the improvement of the existing infrastructure for reusable materials across the EU, e.g. through setting up digital warehouses. Regulation could then refer to a common set of indicators incorporated in product data sheets of materials and components sold in the EU. Rather than setting rigid, ambitious targets, the requirements should be more flexible and allow the project responsible to decide which respective quota contributes most impactful to the overarching circularity target within the project. To be able to asses an economic activity in terms of Taxonomy alignment, or whether an individual project is Taxonomy aligned, data and documentation regarding the construction or renovation process is essential. We therefore welcome the Commission explicitly requiring the use of electronic tools to describe the characteristics of the building as built, including the materials and components used for the purpose of future maintenance, recovery, and reuse. We feel that a clear reference to the introduction and use of digital building logbooks and/or material passports should be added as they would contain all the relevant information regarding material and technical characteristics and quantities of products and materials used and also valuable information for future maintenance, recovery and reuse pathways thus acting as supporting sectoral tools not only for the successful implementation of the Circular Economy criteria but for achieving all six environmental objectives of the EU Taxonomy.
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