The EACB welcomes the possibility to answer the TEG consultation on taxonomy, our answers focus on the sector constructions/buildings. Indeed co-operative banks, as members owned, locally-oriented are best placed to facilitate the greening of buildings, which are responsible of 40% of the total CO2 emissions of the EU. This is why we believe it is important to create a workable framework.
Some key messages of our answer can be summarised as follows:
- One important recommendation is to insert a section “purschase of existing energy efficient buildings”. This is missing in the current TEG taxonomy proposal. However in order to create proper incentives and capital allocation to energy efficient buildings, the focus should not only be limited to “renovations” or “construction of new buildings”, (new buildings account only for about 1% of the existing stock).
- The EACB encourages the use of EPCs as a "useful" basis for setting the thresholds in new buildings and as the necessary basis for measuring performance in existing buildings. EPCs are currently the only EU wide existing buildings energy efficiency classification/ metric. The real energy use is not accessible everywhere and poses a number of concerns especially for consumers.
- In renovations, absolute target values are preferred to relatives, to create the right incentives and achieve concrete results. A higher improvement derives from a 20% in a G house than from a 40% in a B one.
- The EACB calls for a dynamic and gradual approach ("shades of green") and a proporiotnate approach (differentiate residential and not).
- In order to avoid stranded assets it is important that thresholds are realistic. Especially for existing buildings we recommend the use of EPCs. However EPC database shall be made easly availbale to to financial services providers (on a data protection compliant basis). Databases, however, should be kept updated either as legal obligation or via incentive systems. Without those outcomes the current stock of building may result in “stranded assets”. Moreover adaptation of measures should be announced with sufficient time to avoid sudden changes in real estate prices"