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40 | THE PERFECT FIT REGULATORY ASSISTANCE PROJECT What should the EU do to make the policy proposals better? The requirement for Member States to introduce policies to phase out the use of fossil fuels in heating by 2040 should be strengthened. Currently this requirement exists only as a mandatory element of the National Building Renovation Plan (Annex 2). The phaseout of fossil fuels should be promoted to inclusion in the main Directive text. The Directive should make better use of the opportunity to use MEPS to drive deeper renovations and heat decarbonisation in the 2020s and 2030s. The Directive should require that the F and G class buildings targeted in the existing proposal be improved to a higher standard of performance than the current proposal of EPC E. Buildings should be renovated to a minimum standard designed to ensure that they can be heated efficiently through low system flow temperatures and to enable heating to be scheduled flexibly to help heating loads to be electrified efficiently.50 The Directive should also out a longer-term trajectory of minimum standards to address more than just the worst-performing stock. The Directive should also give more explicit attention to support to enable new electrified loads to be made flexible, in particular by including demand-side electricity and heat storage and smart building automation measures in the building assessment and information tools mentioned above. What should Member States do now? Member States can set their own, more ambitious minimum energy performance standards to drive renovation and decabonised zero-emissions heat that are fully aligned with their 2030, 2040 and 2050 targets. These standards can be used to either define the complete pathway for buildings to decabonise or to improve energy-efficiency levels in advance of a fossil-fuel boiler phaseout so that building owners are afforded the opportunity to improve thermal conditions before switching heat source at boiler replacement. Further still, Member States should set out fossil fuel heating phaseout dates. Such regulations should include not just an end date for the installation of replacement fossil-fuel heating systems but could also include backstop dates beyond which the use of fossil fuels in heating is disallowed. 4.3.2 Proposed revision of the EPBD for new buildings Newly constructed buildings in the EU will not represent the majority of the building stock in 2050. However, unless they are constructed to performance standards that align with the EU’s updated 2030 climate targets and climate-neutrality goal, they will lock in energy demand and associated emissions that will make it harder to achieve these goals. New buildings in Europe should not have to undergo a deep renovation between now and 2050 in order to bring the process of decarbonising the building stock back on track.51 50 Yule-Bennett, S. & Sunderland, L. (2022). The Joy of flex: Embracing household demand-side flexibility as a system resource for Europe. Regulatory Assistance Project. Forthcoming. 51 BPIE (Buildings Performance Institute Europe). (2021). The make-or-break decade: Making the EPBD fit for 2030. https://www.bpie.eu/publication/the-make- or-break-decade-making-the-epbd-fit-for-2030/PDF Image | RAP Perfect Fit Heat Pump
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