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Position Paper on EC Consultation on Sustainable Buildings

Introducing our Network

Green Building Councils are not-for-profit, member-based organisations that are driving the transformation of

buildings, communities and users’ behaviour towards sustainability. The World Green Building Council is a

coalition of over 90 national Green Building Councils around the world, making it the largest international

organisation influencing the Green Building marketplace.

Our Europe Regional Network consists of over 30 national Green Building Councils and works in collaboration with

more than 3,500 member companies across Europe, which represent the full breadth of stakeholders in the

buildings industry. A crucial part of Green Building is bringing the whole value chain in our industry together to

provide better solutions, and this is exactly what we are doing through our members.

Executive Summary

This paper presents the views of the Europe Regional Network on the European Commission’s consultation on

sustainable buildings. We look forward to a dialogue with the Directorate Generals of the European Commission

and other stakeholders regarding the results of this consultation, and the direction that is consequently to be set

for the sector under the Commission’s upcoming Communication on Sustainable Buildings.

The contents of this paper broadly follow the structure of the Commission’s consultation questionnaire:

Part 1 (Introduction): This section contextualises the Commission’s present initiative, highlighting the

elements needed to achieve market transformation, the costs and benefits of sustainable buildings, and the

importance of the initiative to the European construction sector’s competitiveness.

Part 2 (Defining the Concept of Sustainable Buildings): This section addresses Section A of the

consultation, and comments on the scope and the focus of the concept of sustainable buildings as

presented in the Commission’s consultation questionnaire, which is restricted to resource efficiency.

Part 3 (Problems to Tackle): This section addresses Section B of the consultation, and comments upon

current and future demand for sustainable buildings, as well as the most appropriate levels of policy

intervention to drive sustainability regarding construction products and different building types.

Part 4 (Key Product Level Policy Recommendations): This section presents our key policy

recommendations for driving the sustainability of construction products, primarily through a staged phase-

in of Environmental Product Declarations across the single market.

Part 5 (Key Building Level Policy Recommendations): This section presents our key policy

recommendations for driving the sustainability of buildings. Foremost is the agreement of an EU framework

of lifecycle common indicators and calculation methodologies for sustainable buildings, followed by the

introduction of Green Public Procurement requirements based upon these. These measures would allow

for a period of data collection, benchmarking and incentivising before the potential introduction of other

policies, such as a basic sustainability labelling scheme for the residential sector.

Part 6 (Material Management): This concluding section comments briefly on the material management and

end of life sections of the consultation.

Annex: This contains our responses to the Commission’s multiple choice consultation questionnaire.

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1. Introduction

1.1. Achieving Market Transformation

The transformation of the buildings sector towards sustainability will require the coordination of a number of key

elements:

(i) Best Practice by Market Leaders: Organisations such as Green Building Councils and their market leading

members will need to constantly evolve and embed sustainability best practice through efforts such as

education, data collection and green building rating tools.

(ii) Required Practice by Policy Makers: Policy makers will need to translate sustainability practices which

prove feasible and scalable, to the whole sector, through a clear and long-term framework of policy and

regulatory obligations. This should create an enabling pathway towards best practice over time, including

the removal of market barriers to such practice and incentives to look beyond typical building practices.

(iii) Sustained Information Campaigns and Education by Central Actors: The associations and institutions

which represent those within Europe’s buildings sector will need to provide a sustained cycle of

information and education to help them make and profit from this transition. Public awareness-raising will

also be necessary to help people understand the benefits of and need for more sustainable buildings.

As an advocate of sustainable buildings, the Europe Regional Network warmly welcomes the European

Commission’s current initiative, which represents an important opportunity to ensure that the central building

blocks are in place for this market transformation.

We support the milestone aims for the buildings sector that are outlined in the Commission’s ‘Roadmap to a

Resource Efficient Europe’, which informs the aims of this consultation. Namely that: ‘By 2020 the renovation and

construction of buildings and infrastructure will be made to high resource efficiency levels. The Life-cycle approach

will be widely applied; all new buildings will be nearly zero-energy and highly material efficient, and policies for

renovating the existing building stock will be in place so that it is cost-efficiently refurbished at a rate of 2% per

year. 70% of non-hazardous construction and demolition waste will be recycled.’1

1 COM(2011) 571

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Indeed, many of our members are actively proving that even greater ambition is possible, though the challenges

for the whole sector to reach and then surpass these milestones are significant.

One of the crucial challenges for the Commission and for our sector will be to look beyond the resource efficiency

focus of this initiative, as this scope will serve to hold back efforts to drive demand for more sustainable buildings.

Only a built environment which is high performance in social, economic and environmental terms can be

considered sustainable. From decades of experience within the Green Building Council movement, we know that

initiatives narrowly focused on a single one of these elements will fail to transform the market.

1.2. The Costs and Benefits of Sustainable Buildings

The World Green Building Council’s report ‘The Business Case for Green Building’ examined international peer

reviewed research on the costs and benefits associated with sustainable buildings2. Amongst its findings, the

report highlighted that there are currently significant misconceptions about the costs associated with

sustainable buildings. The diagram below shows the gap between the actual cost of delivering sustainable

buildings and the significantly greater costs that the wider industry perceives are involved.

Global trends show these costs being driven down over time, as the construction value chain gets more

accustomed to delivering sustainable solutions. Moreover, there are manifold operational cost benefits to green

buildings, aside from energy costs, that offset construction premiums during the lifecycle of the building,

alongside a multitude of other business benefits to developers, owners and tenants/users (see diagrams

overleaf).

2 Those that are certified by rating tools or another national green standard above regulatory minimum standard.

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1.3 The Green Building Market is Global: Inaction will Impact the EU’s Competitiveness

Despite ‘The Business Case for Green Buildings’ proving that many construction businesses are realising the

bottom line benefits of building more sustainably, many in the European buildings sector have yet to make this

transition. European companies risk being left behind in the global green building market.

This year’s ‘Global Green Building Trends’ report shows levels of green building project activity3 on the rise

worldwide (see ‘Levels of Green Building Activity by Firms Around the World’ below). Some of the world’s leading

sustainable building markets are in the EU, but other countries are seeing the number of firms focused on

sustainable project work grow steadily (see ‘Percentage of Firms With more Than 60% of Work Green’ below).

The European Commission’s current initiative therefore represents an important challenge for our region, and it is

one that is crucial to the European construction sector’s competitiveness in the global economy: how do we

achieve market transformation?

Lack of political support/incentives is one of the key challenges to increasing green building activity4. Incentives,

and long-term certainty and clear timescales in the form of policy and regulation, will be needed to overcome

current market barriers and inertia, and move towards more sustainable and competitive practices in Europe.

Industry needs to be at the forefront of shaping this collaboratively with policy makers, to ensure it is the right fit

for a globally competitive green building market that is good for business as well as people and the environment.

In the following sections, we have outlined the shape we believe that future policy for the sector needs to take, in

response to the various sections of the Commission’s consultation questionnaire. These proposals are put

forward as a basis for further debate, and we welcome comments by other stakeholders on them.

Our full responses to the Commission’s multiple choice questionnaire are contained in the Annex to this paper,

and referenced throughout the body of this response where relevant.

3 Projects built to a rigorous green building rating system or those that are energy efficient, water efficient and address other aspects of sustainability. 4 Page 12, Global Green Building Trends, McGraw-Hill Construction in association with UTC, World GBC and USGBC.

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2. Defining the Concept of Sustainable Buildings

As noted in our response to Question 1 (see Annex), we have ranked all listed aspects of environmental

performance as important or somewhat important, based on their relative lifecycle impacts. In addition to these

responses, we would like to raise the following points regarding the scope and focus of the concept of sustainable

buildings in the context of EU policy.

2.1 Scope

We understand that the scope of the sustainable buildings concept is limited to resource efficiency under this

Commission initiative, primarily led by DG Environment. However, from our experience with green building rating

tools, the market is already demanding information and improvements regarding additional elements of building

performance. Importantly, we know that some performance aspects which sit outside pure environmental

performance are actually key elements for driving demand for more sustainable buildings. Therefore, any

initiative which focuses solely on resource efficiency risks failure in terms of driving demand in the market.

Policy in this arena will therefore need to represent a joined-up effort across the Commission.

Other considerations that impact resource efficiency include:

Transport and Amenities: If a new building is designed without due regard to transport considerations and

proximity to other relevant amenities, it may require that its users use resources and create emissions in

providing their own personal transport. Distance also creates inconvenience, and thus impacts demand.

However, as user behaviour is a significant factor, this may be difficult to account for in any regulation.

Other considerations concerning environmental performance include:

Land Use: Encouraging use of land previously subject to development (contaminated or remediated) before

undeveloped land.

Biodiversity: Whilst dealt with under EU law, discouraging the reduction of biodiversity and encouraging its

promotion is absent and is an important design consideration.

GHG intensity of energy use: Given the environmental impact concern associated with energy use is

climate change, GHG intensity is an important measure of how sustainable any energy used is.

Toxicity/Hazardous Materials and Health Impacts: The toxicity and potential health impacts of building

materials are important areas where greater data and transparency is being demanded by the market.

Other considerations that help drive demand amongst end users for more sustainable buildings include:

Indoor Air Quality: This is crucial to creating a healthy and productive indoor environment.

Daylight: This can improve environmental performance of a building through resource efficiency, and views

and daylight are proven to improve user experience and productivity.

Acoustic Quality: Particularly in buildings where user concentration is important (schools, offices etc.), an

environment that helps decrease noise/distractions is important.

Use of Space: Ensuring space is well utilised to suit user needs and ensure reduction of wasted resource.

The above categories should be part of any dialogue around sustainable buildings. It is crucial that economic and

social performance issues are considered in order to help drive demand for better buildings. The business case

for resource efficiency is significant, but the real business case for sustainable buildings lies beyond this.

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2.2. Focus

It is good to see the aspects of environmental performance listed in Question 1 broadly mirror the building

lifecycle. However, there are a few important points to note regarding the focus of any EU sustainable buildings

policy:

Assessment must be focused at the building scale: The focus in Question 1 appears wrongly placed on

product/process scale. Building level lifecycle analysis (LCA) provides the only accurate view on whether the

solutions provided for a building (in terms of product/process) are the most sustainable over its whole

lifecycle given its context and function (see below). Indeed, building assessment often needs to look

beyond the building scale to a development’s surroundings in order to properly assess the most

sustainable solutions.

Building performance should not be assessed without reference to context: A building in Southern Spain

may require a high level of water efficiency during its lifecycle to be considered a sustainable building. In

Sweden, where water scarcity is not an issue, water efficiency is far less relevant. Context is key when

considering what is important, and whilst our overall response to the questionnaire reflects the general

sense across the region, it should be noted that answers from different countries across our Network vary.

Building performance should not be assessed without reference to function: A highly resource efficient

building that does not perform its designated function well constitutes resource waste. It is for this reason

that green building rating tools have evolved to cater for different building typologies (e.g. offices, schools,

logistics centres etc.). An assessment of a hospital and a logistics centre would not be expected to take the

same approach to category weightings – their users are fundamentally different in terms of their needs.

The in-use phase should be a significant area of focus: Due to numerous market barriers (such as split

incentives) impeding progress in this area, this should be a significant area of policy focus.

3. Problems to Tackle

3.1 Current and Future Demand for Sustainable Buildings

Please see our answers to Questions 2A and 2B (see Annex).

In some of the EU’s leading green building markets, the use of green building rating tools is growing rapidly,

which is currently the best measure of demand. This growth is mostly in the non-residential sector, though

markets like France and Sweden are seeing rapidly growing demand for residential rating tools (HQE in France and

Miljöbyggnad in Sweden).

Recent IVG Research found that the number of non-residential projects certified to BREEAM, DGNB, HQE or LEED

in Europe had tripled between 2011 and 2013.5 Current figures for the number of green certified non-residential

and residential projects in Europe are as follows:

5 IVG Resarch LAB 3/2013, ‘Completed Certifications in Europe’, p6

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Rating System Non-residential Certified Projects Residential Certified Projects Total

BREEAM 7,163 16,232 (to Ecohomes/Code for

Sustainable Homes)

23,395

DGNB 371 32 403

HQE 1,539 33,000 (housing units rather

than projects)

1,539 (plus

residential

projects)

LEED 481 22 503

VERDE 8 7 15

Demand for voluntary green building rating tools is typically strongest in the offices sector, with industry and

retail following. Figures below are taken from the Netherlands, where offices pursuing the local green building

rating tool BREEAM-NL now represent approximately 75% of the total new build market (by square meters).

Rapid growth in the number of buildings that are registered or certified as sustainable under existing assessment

schemes is also occurring in other markets. The graph below shows the rapid growth in demand for the Swedish

assessment scheme Miljöbyggnad in Sweden, alongside LEED and BREEAM, which has been concentrated over

the last two years. Similar growth patterns in a number of European countries show green building rating tools

starting to be widely used in certain parts of the market.

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Whilst demand is increasing in certain sectors such as offices, it is not generally well documented in others where

the market for sustainable buildings is still in its infancy, such as the residential sector in the majority of EU

countries. The graphic below shows expected levels of activity across various project types in Europe and other

regions, noting the percentage of respondent firms with planned green projects in each area. Demand in the

residential sector is far considerably lower overall than demand in the non-residential sector.

3.2 Appropriate Levels/Forms of Intervention

Please see our answers to Question 2C (see Annex). There is no single level of policy/regulatory intervention

that will be entirely appropriate by itself to drive demand, and appropriateness entirely depends on the form

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of intervention. We have indicated the primary level of intervention that we feel is appropriate in our answers to

the Commission’s questionnaire, though also indicated secondary levels at which some coordination/intervention

may also be needed or help to drive demand. This situation also differs from country to country.

In general, we would advise the following as the most appropriate levels of intervention:

At product level: As products travel across borders, an EU approach to policy/regulation is the most

appropriate, and an international one would be the ideal solution, so should be pursued. However, given

the time international agreements take, this may not be the most appropriate level of intervention if the

goal is to drive the market in the near-term.

At building level: The most appropriate level of intervention is national, so that context and functional

specifics can be accounted for, and further regional/local tailoring may be necessary. Nevertheless, some

forms of EU intervention in the near-term are appropriate in our view. Over the longer-term EU policy-

makers may need to intervene further if too little action is taken at national level to ensure the EU’s

resource efficiency and competitiveness goals are met. A ‘carrots first, sticks later’ approach is preferable.

The following diagram indicates what we believe should form the Commission’s priority list in terms of EU policy

interventions based upon likely future demand (in a business as usual scenario) and other factors such as the

prevalence of market barriers.

We have previously stated a concern that the EU Ecolabel for Office Buildings project is not adding value as an EU

initiative in terms of driving demand and tackling market barriers where this is most needed, and still hold this

view. However, EU policy will be needed, and in the following Sections of our response we have outlined our

recommendations for EU policy interventions firstly at product level, and secondly at building level. These

include recommendations to deal with issues that the Ecolabel work was aiming to deal with, namely the

convergence and comparability of existing initiatives.

4. Key Product Level Policy Recommendations

Please see our answers to Questions 3C, 3D, 4F, 9A, 9B, 10A, 10B, 12A and 12B insofar as these are relevant to

product level considerations (see Annex).

4.1. Phase-in of Environmental Product Declarations

Central Recommendation: Environmental Product Declarations based on EN15804 should eventually be

mandated across the EU through a ‘phase-in’ approach.

Highest priority for EU intervention (on

basis of demand and other factors)

Lowest priority for EU intervention (on

basis of demand and other factors)

1. Construction Products

2. Public Buildings

3. Residential Buildings

4. Non-residential Buildings

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Environmental Product Declarations (EPDs) are necessary to provide LCA data for building level LCA. They are also

necessary to create a virtuous circle for the supply chain. The key industry need is to have open, transparent

environmental data readily available throughout the supply chain, so the supply of EPDs must eventually be a

supply chain obligation for anyone placing construction products on the single market, though manufacturers will

have the primary obligation to draft them.

We must firstly consult widely to have a harmonised EU LCA standard that is fit for purpose and widely endorsed.

A lack of certainty over the standard for EPDs has held companies back from commissioning them. Large

European companies are now ready for the transition to EPDs, and a harmonised standard and a timeline for

consequent regulation will provide certainty for the investments required. For European SMEs, a phase-in will be

needed, which allows time for EPD business services to scale and reduce in cost, and which provides the needed

support and incentives for SMEs to make this transition.

The following provides an indicative timeline of our recommended EU interventions to ensure a move towards

lifecycle analysis by 2020. Clear timelines and horizons will be needed to help the market scale-up and help

businesses prepare adequately, so the transition to EPDs does not impact their competitiveness.

4.2. Phase-in Stages

Phase 1

A harmonised LCA standard for construction products needs to be agreed. EN15804, the product level standard

developed under the CEN/TC 350 framework, should be the basis of this. This standard will need to be consulted

on more widely to ensure it is sufficiently robust and accepted by all stakeholders, so any consultation will need

to be preceded by appropriate information dissemination to engage stakeholders both inside and outside the

expert LCA industry. EN15804’s scope will need extending to include equipment and service providers, and end of

life and other current issues will also need to be resolved (also see Section 6.4 below). The results of this process

would of course also be important for informing the new Construction Products Regulation Basis Work

Requirement 7 regarding the sustainable use of natural resources.

We understand that the Commission’s new Product Environmental Footprint seeks to deal with outstanding

issues with EN15804. These are issues that need resolving, however, we do not understand the approach of

creating a new initiative to resolve them, as this has so far served to confuse the market. These issues should be

resolved through stakeholder consultation and through the CEN process.

Phase 1 Phase 2 Phase 3 Phase 4 Phase 5 Information dissemination followed by public consultation on EN15804 to agree robust harmonised LCA standard for construction products

Support work to EPD Platform to be completed so infrastructure for cross-border EPD recognition in place (based on EN15804). Commission set clear framework for generic EPDs

EU Green Public Procurement requirements to be introduced at building level, including requirement for EPDs (based on EN15804) from public sector supply chain

EU and national EPD support schemes in operation, including support for SMEs. Incentives for EPDs put in place (e.g. tax)

Mandatory EU EPD requirement to be introduced for companies placing construction products on the market

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Phase 2

A Core-EU EPD must be agreed, based on a revised EN15804. A platform will be needed to serve as the

transparent and open data portal and quality control mechanism for the EU Core-EPD, and to develop common

quality management and verification procedures to enable mutual recognition across the region. This should

ideally be a platform that represents a public-private collaboration, in which industry is in the driving seat as the

expert, and the EU is involved to ensure that commercial and proprietary concerns do not lead to a lack of

transparency over data.

Good work has already been done by the ‘ECO Platform’ towards achieving much of this, and this platform should

be trialled further to see if it is an appropriate platform for the Commission’s support and collaboration rather

than instigating a new EU platform. The creation of multiple platforms should be avoided.

Further support will be needed at EU level to help reduce the costs associated with EPDs for all those required to

commission them. Setting a clear framework for generic EPDs, alongside providing appropriate software support,

are ways in which the European Commission could help reduce associated costs for all companies.

Phase 3

EPDs should be introduced initially through demand-side EU Green Public Procurement (GPP) measures, to

prepare the market for regulation. Ensuring that the public sector leads in order to scale-up the market is a

principle that has proved successful under EU energy efficiency regulation for buildings. We have commented

further on the need for EU GPP measures in Section 5 (‘Building Level Policy Recommendations’).

Phase 4

Before mandatory EU EPD legislation can be introduced, EU and national level support schemes will need to be in

place to encourage and assist companies with the transition to EPDs. As well as information and education

services for smaller companies, these could also include forms of financial and fiscal incentives, such as tax breaks

for products which have EPDs compliant with the existing schemes.

Phase 5

The final phase will be to mandate EPDs for the whole market.

5. Key Building Level Policy Recommendations

Please see our answers to Questions 2A, 2B, 2C, 3C, 3D, 4M, 7A, 7B, 8A, 8B, 8D, 8E, 8G, 8H, 13A, 13B insofar as

these are relevant to building level considerations (see Annex). In overview, we believe that EU building level

policy will need to include the following elements, which are explained in detail in the following sections:

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5.1 An EU Framework of Common Indicators and Calculation Methodologies (Phases 1 & 2)

Central Recommendation: Agree an EU framework of common indicators and calculation methodologies for the

lifecycle performance of sustainable buildings based on the work of CEN/TC 350 and other relevant initiatives.

Assessment tools only work effectively to guide the design of better, more sustainable buildings if they are

context and function specific (see Section 2.2 above), so creating an EU definition or set of weightings through an

EU assessment tool (such as an Ecolabel) would be a step in the wrong direction.

However, an EU ‘framework’ consisting of common indicators (e.g. GHG, water, waste etc.) and associated

calculation methodologies for LCA performance under each indicator would be a step in the right direction – for

both new and existing buildings. National initiatives (market driven or regulatory) required to converge with such

a framework would therefore be comparable with regard to these key indicators, and the concept of a sustainable

building would be more readily accessible from a policy perspective.

This work is already underway, and was in fact directed by the Commission under a mandate in 2004. CEN/TC 350

“Sustainability of Construction Works” has started the process of creating a common EU framework of indicators

and calculation methodologies for both product and building level. It has the advantage of covering

environmental, social and economic aspects, which is crucial for any EU initiative on sustainable buildings. Any

common indicators should not be restricted to resource efficiency if they are to be successful in driving demand

for better buildings (see Section 2 above).

It is our belief that the work of CEN/TC 350 should be built upon as a foundation, though not uncritically,

particularly given the fact the mandate was set nearly a decade ago. The CEN process has also been largely

restricted to industry LCA specialists, and there is a need to consult more widely on the conclusions it has reached

Phase 1 Phase 2 Phase 3 Phase 4 Phase 5 Phase 6 Information dissemination followed by public consultation on CEN/TC 350 and other relevant initiatives, to create robust EU framework of LCA common indicators and calculation methodologies

Publish EU framework of LCA common indicators and calculation methodologies to enable existing initiatives (e.g. green building rating tools) to align with this. Launch information campaign on benefits of performance improvements under indicators

EU Green Public Procurement criteria to be introduced at building level, based on EU framework of LCA common indicators and calculation methodologies. Provision of public sector lifecycle costing training to be a Member State requirement. EU funding made conditional on applying GPP criteria

Collection of data across national GPP programmes. Data used to inform benchmarking on a national basis, supported by Commission. Feasibility of basic EU labelling scheme (based on certain key indicators) for residential sector to be assessed

Member States introduce financial/fiscal incentive schemes for sustainable buildings based on country benchmarks (informed by Commission guidance). Existing initiatives (e.g. rating tools) used to demonstrate eligibility

Basic residential labelling scheme (based on common indicators) introduced if feasibility studies prove viable. Used to demonstrate eligibility for national financial/fiscal incentive schemes

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and modify the standards as necessary to ensure that they are robust, as well as widely understood and endorsed

by all relevant stakeholders (businesses, NGOs, the public sector etc.).

Alongside the CEN work, much valuable work has been done around the theme of common key indicators and

calculation methodologies by projects such as SBAlliance, Open House and SuPerBuildings. In terms of creating a

EU framework that appropriately enables dialogue and functions from a policy (and not just a purely technical)

perspective, this work should also be widely disseminated and examined under stakeholder consultation.

Good quality indicators are already available for the lifecycle performance of buildings, we are simply missing

convergence around key indicators for the region. So, the Commission’s aim going forward should be to

disseminate, strengthened and converge the existing work, and help stakeholders come to a collective view on

the most appropriate common indicators and calculation methodologies for sustainable buildings. The result

should:

Provide a common language for all stakeholders;

Reinforce trust by ensuring transparency; and

Be relatively easy to communicate.

A concerted regional information campaign, aimed both at industry and the public will be necessary to

accompany these new indicators, evidencing and educating on the benefits (social, economic, environmental) of

performance improvements in these areas. This should help drive public demand, both in people’s personal and

professional lives. This information campaign should identify national routes for data collection, which can be

brought together across the region and disseminated. Data collection will be able to progress far more rapidly

once initiatives converge around an EU framework.

5.2 Green Public Procurement (Phase 3)

Central Recommendation: The public sector should lead the market. Introduce mandatory EU Green Public

Procurement criteria based on the agreed EU Framework of Common Indicators and Calculation

Methodologies.

The key aims of any EU sustainable buildings initiative should be to create transparency and comparability,

improve performance, collect data and enable benchmarking. In the move towards country level data collection

and benchmarking, this is an area where the public sector can and should have a leading role. We can learn much

from experience with the Energy Performance of Buildings Directive here. New practices for the market are

more appropriately phased in through demand side Green Public Procurement (GPP) measures rather than

regulating the wider market as a first step.

As existing overview studies have demonstrated6, there is already good GPP work being undertaken in various EU

countries, but common performance criteria do not exist across the region. Monitoring of data and results at EU

level, and effective sharing of best practice has therefore proved extremely difficult. Mandating the

implementation of national GPP requirements based on an EU framework of lifecycle common indicators and

calculation methodologies (see Section 5.1 above) would therefore greatly assist in improving the sector’s

sustainable competitiveness as a Lead Market.

6 ‘Best practice on green or sustainable public procurement and new guidelines’ published in February 2012 under the Open House FP7 project is a useful summary.

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Additionally, this would further encourage the alignment of national voluntary green building rating tools with the

EU framework, as these are often used as a means of complying with sustainable procurement standards, and

would only be eligible as a GPP compliance tool if aligned with the EU framework. Such existing tools may have an

important role in GPP, as third party/independent audit requirements are usually a feature, and this is so far

lacking in most national GPP schemes. An independent auditor requirement, as under the EPBD, will need to be

introduced alongside any GPP scheme to ensure that it is robust and that good quality data is being produced.

There are public sector concerns about the increased cost of procuring sustainable buildings. Training in lifecycle

costing would enable the public sector to determine what represents the most economically advantageous

tender on a lifecycle basis. As stated in Section 1.2 above (‘The Costs and Benefit of Sustainable Buildings’) and in

‘The Business Case for Green Buildings’, lifecycle cost benefits offset construction stage premiums for sustainable

buildings, and their user health and productivity benefits are significant. The value lost to taxpayers and public

sector workers through a ‘lowest price’ default criteria is significant.

There are also other concerns which governments resistant of GPP should be aware of. In the current climate,

many public services are downsizing. Numerous studies have demonstrated that the growth of the green building

market we are seeing across Europe is generally associated with an increasing ‘brown discount’ on sales of non-

green properties, as they become increasingly less desirable assets.7 In a climate where the public sector may

need to dispose of property assets, management of their portfolio’s sustainability will be important to decrease

the risk of incurring significant financial losses on these assets.

Many public construction projects are beneficiaries of EU funding. The need for the public sector to lead is a

principle of much Community legislation on the basis it is often a country’s largest construction client. As

indirectly through EU funding, the EU is the region’s largest construction client, this same principle must apply.

Any EU funding for public projects must therefore become conditional upon applying GPP criteria.

5.3 Data Collection, Benchmarking and Incentivising (Phases 4 & 5)

Data collection and reporting should be a requirement under national GPP programmes, so that this can be

systematically collated to enable countries and the Commission to start the process of accurately benchmarking

performance for different building typologies.

Based upon this exercise, the Commission should be able to formulate guidance to Member States about the

level of lifecycle building environmental ‘footprint’ that should be incentivised by national financial/fiscal

incentive schemes (i.e. the highest performers).

The requirement for such schemes will probably need to be voluntary in nature initially, but the Commission’s

data collection under GPP schemes should also aim to explore and demonstrate the economic case for

performance improvements. Where there is proven to be a robust economic case, a requirement to introduce

national incentive schemes could be made mandatory.

Existing or new schemes that have third party auditor requirements could be a means of robustly demonstrating

eligibility under such incentive schemes.

7 ‘The Business Case for Green Building’, World Green Building Council, 2013

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5.4 Basic EU Labelling Scheme for Residential (Phases 4 & 6)

Similarly based upon the lessons learned during the benchmarking exercise for the public sector, the Commission

should assess the feasibility of introducing a basic EU labelling scheme for residential that examines performance

across certain key indicators from the EU framework. In administrative terms, this would need to build on the

existing infrastructure in place for Energy Performance Certificates rather than creating a separate layer of

administration.

Given current sensitivities in terms of pricing pressures and provision of housing in many Member States, very

robust analysis and consultation on the options will be needed before any such scheme is progressed. However,

we are firmly of the belief that finance rather than environmental requirements is by far the bigger issue in terms

of Europe’s housing sector. Given the increasing evidence that sustainability performance positively impacts the

risk profile of property as an investment (for both institutional investors and home buyers), we believe that the

administrative burdens of any such scheme could be considerably offset in terms of de-risking investment in this

sector.

6. Material Management

Please see our answers to Questions 5A, 5B, 12A and 12B (see Annex).

6.1 Issues are material/product specific so it is hard to generalise

It is difficult to generalise about many of the options in the Commission’s questionnaire given the situation varies

based upon the specific material or product that is in question. Certain material (e.g. copper) is of higher value, so

there are greater economic incentives to reuse/recycle it, and conversely there are lesser incentives for materials

of lower value.

However, across all areas in the Commission’s questionnaire, some degree of improvement is needed. The most

appropriate levels of intervention are considered to be at national and/or industry level, though there are

appropriate areas for EU intervention which are noted below.

6.2 Landfill Tax will help level the playing field for secondary materials

In terms of levelling the playing field at the lower value end, periodic increases in landfill tax have had significant

positive impact on the market for secondary materials, and the tax regime may be a useful and simple instrument

for Member States to provide economic incentives where these are absent. Under the Commission’s current

review of waste management and recycling targets, targets under the Landfill Directive ought to be assessed and

made more ambitious if this is determined not to cause significantly material negative economic impacts. Other

tax incentives could also be explored, such as a decreased VAT rate for the use of secondary materials.

As an overall target, we fully support the target in the Roadmap to a Resource Efficient Europe of reducing landfill

of non-hazardous construction and demolition waste by 70% by 2020. Some of our members are looking to

achieve zero waste-to-landfill significantly before this date, and so there may in fact be room to raise the level of

ambition here dependent on how the market progresses.

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6.3 Lifecycle Analysis should Determine the Best Solutions

Taking the example of recycled content in products, it is easy to simply request more on the basis that recycling

sits high-up the EU’s waste hierarchy. However, LCA must be used to determine suitability of proposals. There is

often a trade-off between higher rates of recycled materials and embodied energy/carbon that we must be aware

of, and lifecycle costing should be used to help cost optimisation and to build the business case for more

sustainable solutions.

6.4 The EU Should Develop End-of-Life Criteria

The development of end-of-life criteria in relation to construction products will be another key area where the EU

has an important role to play, already identified under the Roadmap to a Resource Efficient Europe. This will be

particularly important for materials which are hard or impossible to recycle.

Again, CEN TC/350 has developed end-of-life criteria within EN15804, which will need to be thoroughly reviewed

over time. Designing for deconstruction is currently thinking which is poorly embedded across the sector, and

could also potentially be designed into any end-of-life considerations revisions of EN15804.

6.5 Closed Loop Thinking should be Encouraged

In terms of ‘Other’ categories, closed loop thinking and processes are significant omissions from this part of the

consultation. Any EU work around end-of-life criteria should as a minimum encourage a closed loop approach in

order to move towards a circular economy.

World Green Building Council – Not at limited company (Business No. 842737454) – 5 Shoreham Drive, Downsview Ontario, M3N 1S4, Canada –

www.worldgbc.org – For further information about this response please contact europe@worldgbc.org

EU Transparency Register ID Number: 482897410370-35

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Annex – Europe Regional Network’s responses to the Commission’s multiple choice questions

We have completed the Commission’s multiple choice questionnaire as indicated throughout this Annex. As our Network contains Green Building Councils (GBCs)

from many countries across the region, we have used individual answers from national GBCs and further discussions within our Network of GBCs to arrive at answers

that we feel are the most appropriate for the EU as a whole. It should therefore be noted that there is country-to-country variance on a number of the issues.

The symbol represents the answer we have provided in the Commission’s online form as the most appropriate, as only one answer is allowed.

However, it is our belief that many questions do not have one simple answer, and in some cases the structure of the questionnaire led us to give potentially

misleading or unclear answers. For this reason, the symbol represents other answers that may also be appropriate.

The main body of this paper provides further details on our position on each area by reference to the question numbers, as well as providing clarifications where we

felt the structure of the questionnaire did not allow us to provide the most appropriate response.

Given the structure of the questionnaire, we feel that some caution must be applied when interpreting stakeholder responses.

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NOTE: The boundaries between the first and second aspects are unclear. We have counted material use for products such as concrete/steel etc. as that used for

producing them, even though they are also materials used on the construction site.

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Note: European Green Building Councils work with a number of green building assessment schemes, including BREEAM, DGNB, HQE, LEED, Miljöbyggnad and VERDE,

amongst others.

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