AIOTI Response to Energy Efficiency Directive (EED) recast


The EED builds on the European Green Deal, in which the Commission set out “a new growth strategy that aims to transform the EU into a fair and prosperous society, with a modern, resource-efficient and competitive economy where there are no net emissions of greenhouse gases in 2050 and where economic growth is decoupled from resource use. It also aims to protect, conserve and enhance the EU’s natural capital, and protect the health and well-being of citizens from environment-related risks and impacts.

  • AIOTI strongly supports this strategy
  • AIOTI strongly supports the reduction of GHG emissions of at least 55% by 2030 compared to 1990 as a concrete element of this strategy
  • AIOITI believes that an earlier date then 2050 needs to be set for the European Union to achieve carbon neutrality, given the current climate facts (e.g. IPPC report August 2021) and lack of clear 1,5C measures agreement in the recent COP26 (nov 2021).
  • AIOTI strongly supports prioritisation of the principle to increase energy efficiency, meaning a realizing of a certain output with minimum energy consumption.
  • To this matter AIOTI perceives the proposed EED recast as an attempt to try to impact detailed energy consumption equipment, while not seeing the bigger integral impact. AIOTI fears that the current EED approach will only create a gradual and laborious increase of energy efficiency.
  • AIOTI misses the clear implication of the Green Deal ambition in the EED, as is now proposed in (50) ‘Not promote activities that are not environmentally sustainable such as use of solid fossil fuels’. In our view it would be logical to state the ban of solid, liquid or gaseous fossil fuels for energy generation in favour of no-emission, renewable solutions. We believe that sufficient alternatives are available, it will strengthen the position of the EU, by strongly reducing dependency from fuel imports to EU, as well as generating the co-benefits of introducing renewable energy sources to health, air quality, GHG emission reduction and more. Technical solutions from the wide IoT field are already available to ensure optimal use at scale, like for example solar panels (as panel or integrated in building facades), solar boilers, wind turbines (high turbines as well as on buildings), hydro-power, kinetic power, passive and nature-based design and so on.

AIOTI would like to emphasize the need for integral approaches to the Green Deal ambition, meaning designing back from the future ambition. Rather than trying to enforce an optimization from our current implemented solutions. Based on for example the IPCC report of August 2021, it is clear we need giant leaps in transforming our society and economy, instead of small optimization steps.

In particular, IoT and Edge Computing are two elements in a larger family of technologies to deliver effective and sustainable systems. Currently many enabling technologies, like IoT, edge computing, smart connectivity, AR/VR, AI/ML and distributed ledger technologies are being deployed and used in many facets of the economy and vertical industry domains. The use of those enabling technologies can support sustainable solutions that will be able to achieve the objectives of the European Green Deal and Energy Efficiency. Those technologies, such as IoT, edge computing and smart connectivity can function as enablers of such solutions and at the same time their use will enable energy networks and consumers to become more energy efficient in general, thereby reducing energy consumption at a time when the future of our environment depends on it. These enabling technologies are supported by an evolved ICT infrastructure addressing the connectivity and computing horizontal features.

The full document can be found here.


Buildings: AIOTI response to revision of Energy Performance of Buildings Directive

The Inception Impact Assessment for the revision of the EPBD proposes 3 different pathways.

  • AIOTI strongly supports Option 3 ‘Amend the EPBD’ as we are convinced this to be crucial to achieving the Renovation Wave objectives. We support the clear focus on 1) introduction of minimum energy performance standards in combination with deep renovation definition focusing on minimum individual and collective living quality, 2) updating the EPC framework and 3) developing a new vision for buildings.
  • AIOTI strongly believes that Option 2 ‘Non-regulatory measures’, especially transition and financial support mechanisms and supply chain capacity, are key enablers.
  • Recent publications, assessing Long-term Renovation Strategies and their non-compliance with the EPBD objectives of climate-neutrality by 2050[1], assessments of the social and cultural influences on energy consumption[2], and the current unacceptable low deep renovation rates, clearly show that Option 1 ‘No policy change’ is far from being a responsible option.

AIOTI would like to emphasize the need for the most effective synchronization of both regulatory and non-regulatory measures for the upcoming revision of the EPBD.

[1] On the way to a climate-neutral Europe – Contributions from the building sector to a strengthened 2030 climate target BPIE – Buildings Performance Institute Europe

[2] Energy Demand Challenges in Europe – Implications for policy, planning and practice

In conclusion AIOTI suggests that the measures proposed in Option 3 and the non-regulatory measures in Option 2, should be implemented in a concerted way, in the context of the upcoming EPBD revision as to accelerate the renewal of the built environment in Europe including the development of thriving of equitable communities.

The full document can be found here.


Buildings: AIOTI Contribution to Recovery and Renovation Wave in Europe

As the global COVID-19 pandemic continues to unfold, plans for recovery and the future are now set in place. These plans need to turn the challenges of today into the opportunities of tomorrow. Recovery must be focused on building a more competitive, sustainable and resilient economy that is able to create jobs and enable the transition in the built environment that is human-centric, green and digital.

The NextGenerationEU package offers a once-in-a-generation chance to shape our European economies and societies for the better, to renovate the existing stock of buildings and to make them better places to live and work, whilst being more energy and resource efficient. AIOTI Buildings Group supports the focus on digital and green technologies in the overall EU Recovery Fund package, particularly the Recovery and Resilience Facility, which will bring jobs and economic growth. In order for the recovery funds to make a real, long term impact for the European built environment, there is a need to fulfil the ambition of a carbon-free continent by 2050, backed by the full power of digital technologies.

Decarbonising the EU’s building stock through human-centric renovations will support job creation and sustainable growth, driving the economic recovery from the ongoing economic and health crisis. The building sector is the largest energy consumer in Europe, absorbing 40% of the final energy and producing about 36% of all greenhouse emissions[1]. Across Europe, 75% of buildings are considered energy inefficient, and, depending on the Member State, only 0.4-1.2% of the building stock is renovated each year. If Europe is to fulfil its 2050 climate and energy goals, this rate will need to be doubled to reach 3% per year.

[1] European Commission, Communication from the Commission on the European Green Deal

AIOTI Buildings Group believes that the foundation for an effective and ambitious Renovation Wave must be based on the following three principles:

  • Digitally integrated building renovations: Boosting digitally integrated renovations for energy efficient, renewable-based and flexible buildings, to attain climate neutrality in the most cost-effective and timely manner. This approach is based on the integration of technologies related to various segments that combined, evolve into smart buildings, enabling the advantages of collaboration and joint platforms benefiting from generated data. Only the integration offers the opportunity for future smart city planning, digital and sustainable building development, smart working & living and the evolution into a ‘technological building ecosystem’.
  • Energy Efficiency and Renewables: in line with the Energy System Integration Strategy and the upcoming Climate Law, energy efficiency and renewable energy sources renewables must be central to all aspects of building renovations. This can be combined with policies that go beyond energy efficiency and promote Indoor Environment Quality (IEQ) to ensure comfort, wellbeing, and productivity benefits to their users. An example of a tool that could achieve both energy savings and higher comfort and wellbeing is the Energy Performance of Buildings Directive’s (EPBD) Smart Readiness Indicator, which is currently being applied throughout the EU on a voluntary basis[1].
  • Dedicated financial flows: it is crucial that each Member State dedicate financing within their National Plans for the EU Recovery and Resilience Facility, and other available funding sources, to increase the rate and quality of renovations of buildings and to support integrated building renovations that will deliver decarbonisation before 2050.

[1] Smart Readiness Indicators

AIOTI Recommendations:

  1. Infrastructure – digital infrastructures are key to the development of the smart buildings of the future. 5G will improve the connection speed and allow the development of applications that require low latency, high reliability or the connection of millions of low-energy sensors. Fibre networks must be extended as quickly as possible in all areas currently served by mixed copper infrastructure. Part of the resources of the Recovery Fund should be invested in the research and development of future-proof networks and infrastructures in the context of smart buildings.
  2. Digitally-enabled solutions – in the context of the Renovation Wave, funding conditionality for financing should not neglect to improve a building’s smartness from both an energy efficiency and indoor environmental quality perspective. Technologies including IoT, smart connectivity, AI, edge computing can be enablers to achieve the objectives of the Renovation Wave. The potential of connectivity and digital tools to enable energy savings will prevent long-term lock-in-effects and prepare for flexible use scenarios of buildings in the future. Investment into collaboration hubs around buildings will enable technology providers, manufacturers and service providers to develop joint solutions and platforms that all ecosystem stakeholders will be able to benefit from associated data generation.
  3. Building Information Modelling (BIM) – promote BIM in public tenders by basing public procurement on the MEAT[1] Digital solutions based on ecosystems of Digital Twins will prove key to reaching the green goals efficiently. Public sector should lead by example. All public EU tenders (e.g., from cities), for both new buildings and renovations, should be made digital and have BIM included with a coordinated overall design.
  4. Digital know-how and skills – in parallel with the construction of the networks and services implementation, there is a need to train building professionals (such as designers and installers) for the secure digital environment in order for it to be an engine of inclusive growth. Digital skills development needs investment to retrain building professionals for the design, deployment and maintenance of the technologies needed to achieve more energy-efficient and smart buildings.
  5. Human-centric – all renovations should be targeted to support health and wellbeing for the occupants. Indoor environmental quality if mandatory to provide people a decent place to work and stay.

[1] Most Economically Advantageous Tender

Full document can be found here.



Position paper: A balanced approach for implementing the Smart Readiness Indicator

AIOTI WG Digital Buildings has prepared a position paper on “A balanced approach for implementing the Smart Readiness Indicators”.

The voluntary Smart Readiness Indicator (SRI) under the Energy Performance of Buildings Directive is a welcome development. If implemented in a balanced and holistic manner, the SRI has the ability to raise awareness about the benefits of smart technologies and the uptake of new technology in the building sector. To ensure a balanced and holistic approach to the SRI framework, this paper outlines AIOTI Smart Building and Architecture Working Group’s position on the main questions guiding the 2nd phase of the SRI study. Among other recommendations, AIOTI urges the SRI Study Group to consider:

  • The inclusion of network readiness as a key impact criterion to address the importance of connectivity for smart systems to function smoothly.
  • Ensure the SRI Is compatible with the LEVEL(S) scheme, Energy Performance Certificates, and the Broadband Cost Reduction Directive.
  • Ensure the SRI framework is adaptable and accounts for the differences in building contexts, typologies and geographic locations through distinct frameworks for building types.
  • For the widest use and adoption of the SRI, the framework must be flexible in assessment by ensuring the format and presentation of information is conveyed in a meaningful manner so it is easily understood.

We use this paper to open a dialog between AIOTI and the SRI Study Group on the topics highlighted in this paper.

The full paper can be downloaded here.