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Housing Europe - European Federation for Public, Cooperative and Social Housing

CECODHAS

Housing Europe is a network of national and regional federations representing social housing providers.

Lobbying Activity

Housing Europe calls for tax exemptions for social housing

11 Sept 2024
Topic — Evaluation of EU rules targeting aggressive tax planning and corporate tax avoidance practices.
Message — The organization requests that social housing providers be allowed to fully deduct borrowing costs from their tax base. They propose amending the directive to exempt not-for-profit associations that serve social purposes.12
Why — This change would protect their economic model by significantly reducing financing and delivery costs.34
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

23 Feb 2024

Beyond creating socially inclusive and resilient housing systems, public, cooperative, and social housing providers have consistently underlined their commitment to tackling the sectors greenhouse gas emission in line with the European Commissions Green Deal. This is exemplified by the fact that Housing Europe Members have pledged to renovate 4 million homes by 2030. As such, the sector has adopted a frontrunner role in the green transition of the housing stock, and will continue to do so when it is time to implement the recasts of the Energy Performance of Buildings Directive, the Energy Efficiency Directive, and the Renewable Energy Directive. Nevertheless, public, cooperative, and social housing providers are also walking a tightrope to, on the one hand, facilitate the required renovations, while, on the other, also ensure that enough properties are being built or brought back into use, and that the homes provided remain affordable. In this sense, enhancing access to financing is crucial to facilitate socially just renovations. Nonetheless, we argue that private financing can only go so far and a focus on unlocking and increasing public financing is essential for our sector. Firstly, our sector is characterised by certain constrains which are not well suited to private financing stream. Due to the sectors adherence to affordability, it is often impossible and undesirable to increase rents following energy efficiency renovations. In that sense, a high return on investment is not possible and should also not be the core principle for financing streams. Secondly, and building on the first point, renovations past a certain point are no longer cost-optimal in our sector. In this sense, there is a diminishing return on investment past a specific label scale. This is illustrated by a study carried out by Copenhagen Economics and commissioned by Housing Europe (https://copenhageneconomics.com/wp-content/uploads/2021/12/impact-of-meps-in-revision-epbd_copenhagen-economics_20211004_final-report.pdf), that due to the prevalence of split incentive dilemma and regulated rents, public financing is fundamental in facilitating renovations. For example, Austrian Limited-Profit Housing associations have a revolving fund mechanism through which maintenance and renovation costs are inherently included in the (cost-based) rents, which is then supplemented with beneficial public subsidies, grants, or loans. You may find more information in financing schemes for renovation in Public, Cooperative, and Social Housing in the comparative study issued by Housing Europe, Groupe Caisse des Dépôts, and lUnion Sociale pour LHabitat: https://www.housingeurope.eu/resource-1124/the-financing-of-renovation-in-the-social-housing-sector All in all, while unlocking private financing is important in facilitating energy efficiency measures, our sector is and will remain dependent on public financing to ensure socially just renovations.
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Meeting with Nils Torvalds (Member of the European Parliament)

12 Jan 2024 · Soil Monitoring Law

Meeting with Kim Van Sparrentak (Member of the European Parliament)

9 Nov 2023 · housing

Housing Europe urges flexible circularity rules for affordable housing

3 May 2023
Topic — New technical screening criteria for circular economy activities under the EU Taxonomy.
Message — Housing Europe argues that uniform criteria fail to reflect the housing sector's complexity. They recommend using tools adapted to local situations rather than rigid standards.12
Why — Flexible criteria would ensure social housing projects remain eligible for essential green financing.3
Impact — Low-income residents may face fewer housing options if restrictive rules block project funding.4
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Meeting with Rosa D'Amato (Member of the European Parliament) and Amnesty International Limited

20 Feb 2023 · COVI Report

Housing Europe urges selective asbestos screening and removal strategies

26 Jan 2023
Topic — EU initiative on screening, registering, and monitoring asbestos to improve building transparency.
Message — Screening should occur only at trigger points like renovation, demolition, or sale. The federation opposes systematic removal to prevent excessive costs and worker risks.12
Why — Providers would avoid high renovation costs and safety risks associated with removal.3
Impact — Occupants lose health protections if asbestos screening is not conducted systematically.4
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Aluminium AISBL and

20 Oct 2022 · circular economy and construction sector

Meeting with Nicolas Schmit (Commissioner) and

19 Sept 2022 · Situation du logement et du logement social en Europe.

Meeting with Giulio Di Blasi (Cabinet of Commissioner Ylva Johansson) and Caritas Europa and Platform of European Social NGOs

2 Sept 2022 · Ukraine Safe Homes Initiative

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit), Christoph Nerlich (Cabinet of Commissioner Nicolas Schmit) and

22 Jun 2022 · Social Platform position on an EU Solidarity Strategy to respond to the Ukraine crisis

Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

Social, cooperative and public housing providers are strong supporters of the Renovation Wave and the decarbonization of social, cooperative and public housing is under way, as proven by the improved energy efficiency and reduction of C02 emitted by m2 . The proposed article 6 of the revised EED would include housing provided by public entities in the scope of the obligation to renovate 3% of the total floor area. Our sector needs an enabling framework that take into account the cost effectiveness of the measures in order to preserve the affordability of living for inhabitants. Setting unnecessary obligations and detailed prescriptions on how to reach decarbonization might turn counterproductive. Ultimately it could put the social housing sector at risk of failing to fulfill its historic mission of providing affordable and quality homes for those in need. Our main concerns in the proposed revised EED are a. the lack of financial support linked to obligation to renovate and b. The technical feasibility of achieving NZEBs for existing buildings. We advocate that NZEB renovations should only be done when this is technically, functionally and economically feasible , as stated by Article 9 of Directive 2010/31/EU. The Regulatory Scrutiny Board (RSB) pointed out that the EC did not properly investigate the effects of the NZEB as a standard for the required renovations, it is also not reflected in the impact assessment of the EC. With the ongoing housing crisis we find it to be risky that the effects of NZEB as norm for renovation has not been appropriately looked at. NZEB is a standard for the newly built environment. The costs involved in renovating to this standard exceeds the benefits, as evidence shows that energy renovations have sharply declining returns to the point where they are no longer earned back by future savings on the energy bill. These costs could come at the expense of affordable rent and the necessary construction of social housing. Housing Europe ambition to contribute to the renovation of 4 million homes by 2030 (https://www.housingeurope.eu/resource-1471/housing-europe-s-ambition-to-renovate-4-million-affordable-homes-by-2030) can only be achieved if contextualised and funded policies are put in place.
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Meeting with Katherine Power (Cabinet of Commissioner Mairead Mcguinness)

23 Apr 2021 · Taxonomy Delegated Act

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

22 Mar 2021

Housing Europe contribution to the consultation on the Policy Roadmap for the revision of the Energy Performance of Buildings Directive (EPBD) See attachment
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Meeting with Nicolas Schmit (Commissioner) and

10 Feb 2021 · Meeting on housing in the Action Plan on the European Pillar of Social Rights.

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit)

11 Dec 2020 · pillar of social rights in the field of housing and homelessness

Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Housing Europe's feedback can be found in attachment. "Conclusion The review of the Energy efficiency directive is the opportunity to rethink our policy approach. The best way to deliver the results we need is to support the people who are delivering them. Based on the evidence brought about by local stakeholders, Housing Europe favours non regulatory changes in the review of the EED in order to strengthen the building blocks of a fair energy transition. Incentivizing all the actors of the supply chain to work together in order to promote at the same time energy efficiency, clean (local) energy, circular economy and affordability should be main objective of the European Commission in reviewing all EU energy legislation. A European programme supporting such integrated projects can result in increasing the pace and depth of renovation of residential buildings."
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Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

23 Jul 2020 · National plans and European obstacles for renovation of social / affordable housing stocks

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

7 May 2020 · Renovation wave and recovery

Meeting with Kadri Simson (Commissioner) and

23 Apr 2020 · How building renovation can contribute to post covid-19 recovery, how to get renovation projects off the ground, how to remove regulatory obstacles and improve advice.

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

5 Mar 2020 · Presentation on greeen deal and renovation wave

Meeting with Ana Carla Pereira (Cabinet of Commissioner Nicolas Schmit)

17 Feb 2020 · Implementation of the action plan of the Social pilar, housing

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

4 Dec 2019 · Obstacles and opportunities for a renovations wave in the EU

Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen)

1 Apr 2019 · Social housing, investment support instruments

Meeting with Vasiliki Kokkori (Cabinet of Commissioner Marianne Thyssen)

26 Nov 2018 · implemention of the European Pillar of Social Rights and affordable/social housing.

Meeting with Florentine Hopmeier (Cabinet of Vice-President Jyrki Katainen) and European Association of Service providers for Persons with Disabilities and

22 Oct 2018 · Discussion on addressing social sector needs in the InvestEU Programme

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Eurocities and

29 Nov 2017 · Discussion on affordable housing in EU