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Irish Green Building Council

IGBC

Provide a source of leadership for sustainability and quality in the built environment Promote and assist in the provision of credible metrics for measuring progress towards the end goal of sustainability Provide a source of resources to companies transitioning their activities towards more sustainable practices Be central to alignment of the policies of organisations seeking to achieve sustainability in the built environment The Irish Green Building Council is looking to transform the Irish industry to sustainable practices through policy creation, education and provision of tools to measure and accelerate progress.

Lobbying Activity

Response to Union framework for the calculation of life-cycle Global Warming Potential for new buildings

31 Oct 2025

According to the Commission The mandatory calculation of GWP based on the calculation framework in the delegated regulation creates an incentive to use low-carbon construction materials including clean steel and cement, thereby fostering lead markets for such products, and biobased material such as wood which promotes the carbon storage in buildings. In order to incentivise this use of low carbon materials, all of the building, both internally and externally should be included in the scope, but the scope is currently ambiguous because of this term "External Works (Required only if covered by the EPC)" in the scope on p.17 of the draft Annex. We need a statement that clearly includes external works are covered by the EPC, otherwise roads, paths, paving and other surfaces suitable for traffic of people or vehicles which are within the building plot area (the red line), and all drainage and ancillary buildings that service a main building but dont require an EPC of their own, will be omitted, and therefore continue to be designed with little regard for environmental constraints. Worse it could potentially lead to even less efficient design to move elements from an EPC covered building to an ancillary building out of scope of the EPC. Research carried out by University College Dublin on behalf of the Housing Agency found an addition of around 5% for apartments, up to 20% for low rise semi detached and as for detached - too variable but certainly higher owing to the lower density of occupation and utility of the space. See section 5 of their report here: https://www.housingagency.ie/sites/default/files/2025-08/PC_housing_report_v5.pdf Previously an EPC only referred to a buildings energy performance in use, so covering only the internal definition was fine. Now that the EPC extends beyond the walls of one building, this needs to be reflected in the Article or the Annex, otherwise the calculation will fail in its aim as external works will continue to go unmeasured, meaning no need to consider the quantity of concrete in a carpark or the quantity of cement in the concrete. This is not good from a carbon perspective, but also from bio-diversity (Land use changes is one of the main drivers of biodiversity loss according to the IPBES) and flood risk perspectives as land continues to be permanently fragmented and sealed. Protecting land is also the most cost and resource effective way to reduce our emissions, while enhancing climate resilience. Our research shows that industry is ready to act but needs clarity on scopes, timelines, etc.(see: https://buildingazerocarbonireland.ie ) Knowing exactly what does an individual EPC cover is an important step. What about a housing estate or block of flats, where usually there is an EPC for each dwelling but not the overall project? As the basis for the updates to our national EPC systems we need clarification on what an EPC covers. A single house on an estate or a single flat has an EPC but neither exist in isolation. Should there be apportionment of external works that the user would normally need? The structure of the apartment block, lifts, communal heating etc., the private road into the estate to the house. Where would these emissions be covered? In short, we need a very clear and comprehensive definition of the system boundary in the calculation if we are to ensure nothing significant can be moved outside that boundary. The scope is clearly laid out in Level(s) indicator 1.2 but apportioning the externals does need clarifying. Clear guidance on how external works are treated within the EPC boundary will be essential to ensure consistent application across Member States. Linking to ICMS 3 coding would also remove ambiguity in naming conventions in different languages and make comparison and therefore benchmarks and limits for specific elements easier. As well as the above, we are fully in support of the submission made by the World Green Building Council (WGBC).
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Meeting with Lynn Boylan (Member of the European Parliament)

21 Feb 2025 · Sustainable Housing