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European Property Federation

EPF

Article 3 of the Statutes: The purposes of the Federation are: a) within the context of real estate, to help attain the European goals set forth in the Treaty of Rome and subsequent treaties; b)to facilitate discussion and exchange of views on matters of common interest and to make representations on behalf of its members on European matters; and c) to co-operate with other organisations having an interest in real estate

Lobbying Activity

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

On 20 January 2021, European Historic Houses (EHH), European Landowners' Organization (ELO), European Property Federation (EPF) and The European Group of Valuers' Associations (TEGOVA) sent a joint letter to Commissioner Simson. It addresses many of the key issues raised by the Inception Impact Assessment. Synopsis of the most important points: 1. The target of at least 55% GHG emissions reduction by 2030 will never be met without at least doubling the rate of renovation. 2. The rate of renovation will never double without EU regulation. 3. Regulation means: (1) PHASING OUT OF FOSSIL FUELS: We believe that EU regulation should lay down an obligation and a timeline for the phasing out of fossil fuels in heating systems whilst leaving the details to the member states so that they can mesh this with the necessary concomitant network building and urban planning. (2) AN EU FRAMEWORK FOR THE RENOVATION OF THE WORST-PERFORMING BUILDING STOCK (see also annex below) Such a framework won’t work without: (a) CUT-OFF DATES FOR SALE OR RENTAL OF UNRENOVATED BUILDINGS: We accept that the only way to get this done at scale is by imposing cut-off dates at which buildings that have not been renovated can no longer be sold or rented out, as is already planned in some of the LTRSs. But such an extraordinary shock to property markets requires that member states retain control over the exact type of building stock covered and the degree of renovation required. (the Finnish Real Estate Federation dissents on cut-off dates) (b) HIGHER RENOVATION RATES FOR ALL PUBLIC BUILDINGS and not just for those owned and occupied by central government as is the case now DEEP RENOVATION: We warn against Commission overemphasis on this, supposedly so as to avoid carbon ‘lock-in’, until the next renovation. We find this reasoning simplistic, static and Malthusian, and stress that new technical solutions are appearing at great speed and the prices of old ones are dropping quickly. The absolute priority should be to reduce carbon emissions substantially by 2030 so as to head off climate impacts that will be caused by our current behavior no matter how much emissions are reduced after 2030. In the building sector, that means renovation at scale, even if it is not all ‘deep’ or ‘near-zero’. Furthermore, renovation at scale will have the side-effect of increasing the rate of ‘deep’ renovation anyway. HISTORIC HOUSES: Heritage authority constraints mean the exemption in Article 4(2)(a) EPBD must be retained. ANNEX Renovation of the worst performing segment of the building stock We believe that there could be an EU framework for energy efficiency renovation of the worst performing segment of the building stock by 2030, but without the directive specifying the degree of deepness of the renovation. This approach corresponds to that taken in the EED for renovation of buildings owned and occupied by central government – there is no specification of degree of deepness. Prioritising the worst performing building stock is socially very attractive, as housing is 75% of the building stock and the worst performing dwellings tend to be occupied by people experiencing energy poverty. But that means that particular advance attention will need to be paid to financing for both owners and the many landlords who are themselves financially fragile and rely on their rental housing to complement their pensions. This is not suitable for regulation at EU level, but the European Commission and the EIB can act by means of EU funding conditionalities. Funding requires control, especially in a field where, in some member states, energy renovation fraud is already rife. For EU-funded projects, controls of post-renovation energy performance should be undertaken and follow-up implemented, to avoid fraud from some renovation companies. If performance is not reached, fines/penalties should apply. This would make owners/landlords more confident in undertaking renovations.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

The main focus should be at energy system and CO2 emission level. For instance, in Finland the share of CO2-neutral energy production (electricity, district heating and district cooling) is rather high and therefore in buildings, as elsewhere, CO2-neutral energy is already commonly used. Given such existing objective situations, specific EU sub-targets for buildings should not steer and promote on-site real estate energy production only. The Finnish case serves as a reminder that the specific building stock and energy supply features of each Member State should be carefully taken into account when conducting the impact assessment. A tax shift more favourable to renewables and less so for fuel is an option as part of the mix. It makes sense to think of gradually increasing taxes on fossil fuels as a measure to force owners to start with sustainable renovation programmes. Nonetheless, for best results the main emphasis should be on expanding and tightening the EU emission trading system. Building-specific heating should be included in the EU ETS. Indeed, if the EU ETS were expanded and tightened, it would render building-specific sub-targets irrelevant. We would emphasise that for the renewables component as for energy efficiency, the key is long-term plans such as are organised by the Energy Governance Regulation’s National Energy and Climate Plans and the EPBD’s Long-term Renovation Strategies. These have the major double advantage of: • providing each Member State with the freedom to plan in accordance with its existing building stock and energy mix; and • providing all stakeholders and in particular building owners big and small with visible ‘fixed’ long term goals that are key to planning at every level, in accordance with the parties’ financial situation. It needs to be accompanied by a combination of significant financial support measures, such as low interest loans and/or grants and by deadlines or sanctions where this is demonstrably necessary to stay on target.
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Response to Evaluation of State aid rules for health and social services of general economic interest and SGEI De Minimis

27 Jun 2019

SGEI and Social Housing Housing policy is a national competence but investment in housing is one of the Internal Market Freedoms (free movement of capital), to the great benefit of EU citizens. Social housing is a national prerogative and governments can subsidise it as much as they want. Nor do they need to notify such activity to the Commission as long as it is restricted to “the provision of social housing for disadvantaged citizens or socially less advantaged groups, who due to solvency constraints are unable to obtain housing at market conditions” (Recital 11, SGEI Decision). That restriction is crucial, underpinning all the work that the Commission has done to ensure that social housing companies must not use the state aid they receive for housing provision to disadvantaged citizens when competing with private investors and landlords for middle-income tenants. This is no blind application of some autistic EU bias in favour of free movement of ‘capital’ over true social needs; it is an action that fosters competition in the development of quality housing provision and which, by increasing and improving the rental stock, actually takes the pressure off of social housing, making it easier for that sector to provide for those in need. In fact, governments are increasingly turning to innovative, cost-effective private housing providers to provide the social housing for disadvantaged citizens that is in such short supply (these private providers are submitted to exactly the same public service requirements as standard social housing). It is no coincidence that much of the EU state aid intervention in this area has concerned Sweden and the Netherlands. The Commission’s actions were founded on solid legal reasons: European real estate investors (one of the largest pan-European capital flows) were facing unfair competition on private housing markets in two of the most inefficient housing markets in the EU. Two rich countries with otherwise superb macroeconomic fundamentals that have major housing shortages or mismatches biased against the young and the new arrivals and in favour of those who own a house or have inherited a place in social housing. Year after year, the European Semester highlights this phenomenon in both countries in great detail, putting housing market reform at the top of the Council Recommendations. National prerogatives over housing policy notwithstanding, it is the right and the duty of the Union to ensure that all providers are on a level playing field on the free housing market, especially as private investment is delivering: Housing – including student and health care housing – is now a major activity for highly skilled commercial property companies and real estate funds that traditionally concentrated on office, retail, hotel and logistics. The main reasons that housing is still under stress are two extraneous phenomena: the EU’s internal migration flows to cities and international migration flows into Europe. PS: “ ... recent developments in the jurisprudence of the European Court may have led to legal uncertainty on how Member States can fund services of general economic interest in these sectors that are of key importance for citizens and society as a whole, while preserving the key aspects of State aid control.” (Roadmap, top p. 2) Certainly not in the case of social housing competing on the open market. On the contrary, the Woonpunt and Woonlinie cases of 15 November 2018 upheld in full the Commission's 2009 Decision on Dutch social housing corporations.
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