49
MARKET NEEDS AND GAPS IN ENERGY EFFICIENT MORTGAGES’ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting, processing and disclosure of Energy Efficient Assets

EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

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Page 1: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

MARKET NEEDS AND GAPS IN ENERGY

EFFICIENT MORTGAGESrsquo REPORTING

PROTOCOL AND DATA PORTAL

IMPLEMENTATION

Setting on the necessary requirements for a harmonised reporting processing and disclosure of Energy Efficient Assets

D32 Technical Report on Market Needs and Gaps

249

Executive Summary

The first EeDaPP report - including a mapping exercise ndash which provided a detailed analysis of existing

green reporting criteria in the energy efficiency and buildings sectors allowed us to narrow down the

variables and define the list of criteria to underpin the data protocol The present report identifies

market gaps and needs in the Energy Efficient Mortgages (hereafter EEM) market with regard to

information and data gathering processing and disclosure

Gathering Market players generally and lending institutions in particular need to gather and

consolidate information coming from different sources of different natures and with several levels of

aggregation Moreover the implementation of the data gathering and reporting protocol must be

elaborated with the objective of optimisation and cost mutualisation for the EEM product and its

integration with IT systems already in place (ie integrate with existing reporting requirements and

practices minimise additional criteria)

Processing The EeDaPP initiative aims to provide relevant robust and reliable information to assess

EEM performance and risk evaluation The common database is an unprecedented collection of

reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

Disclosure The green bond market is growing rapidly and is key to the mobilisation of sustainable

investments As such it needs clear yet rigorous criteria for eligible assets for each key sector (new

and existing buildings in our case) and a harmonised and transparent reporting process aligned with

existing international standards regulatory developments and market best practices

To reach these objectives the EeDaPP initiative has to overcome the following gaps in the market

- Data availability issues at European and national levels regarding financial property valuation

and energy performance data

- Data consolidation harmonisation and comparability issues when processing information

coming from several data sources of different formats natures and calculation methods

- Data quality and representativeness issues for risk impact assessments

- Data monitoring issues especially regarding dynamic and evolving sustainability targets

criteria stringency and energy consumption reporting and monitoring

The ultimate objective of this work together with the previous publication (D31 ndash available here ) and

a final report (to be published in the future) is to elaborate a detailed and comprehensive list of energy

efficiency and performance criteria The full list of relevant data fields is to be collated in a reporting

protocol and common data portal which will allow the gathering processing and disclosur of relevant

information on Energy Efficient Mortgages across European markets

Source Activity WP3PU Editor L Bertalot (EMF-ECBC) Authors D Leboullenger J Johnson L Bertalot D Westig Status Final Date 30112018 Contractual Delivery Date M6

D32 Technical Report on Market Needs and Gaps

349

Table of Contents

1 INTRODUCTION 5

2 IDENTIFYING MARKET NEEDS 6

21 Gathering 6

211 Market needs Energy Efficient Mortgages framework and stakeholders 6

212 Existing reporting frameworks 8

22 Processing 14

221 Market needs Establish a direct link between loan level credit and mortgage risks

property valuation and energy performance 14

222 Existing studies on the link between the energy performance of buildings and mortgage

defaulthelliphelliphelliphelliphelliphellip 14

223 Reporting on the financial performance and related risk of Energy Efficiency

investments and energy upgrades 16

23 Disclosure 16

231 Market needs Provide the missing link from origination to funding 17

232 Impact reporting 18

233 Alignment with existing taxonomy international pledges and regulatory

developmentshelliphelliphelliphelliphelliphellip 20

3 ASSESS MARKET GAPS 25

31 Data Availability 25

311 Overall assessment 25

312 Energy performance data availability 25

313 Link between energy performance property valuation and mortgage data 29

32 Data Consolidation Comparability and Harmonisation Issues 30

321 Data consolidation and common key identifier 30

322 Harmonisation of the different methodologies and definitions 30

323 Calculation methods and comparability issues 32

33 Data Minimum Quality and Representativeness 35

331 Sampling problem coverage and data history 35

332 Lack of default data for the relevant period 36

34 Data Processing Monitoring and Usage 36

341 Privacy and contractual considerations 36

D32 Technical Report on Market Needs and Gaps

449

342 Practical issues Dynamic monitoring 38

343 Evolving sustainability targets 39

4 Conclusions and next steps 42

5 Annexes 43

51 List of figures and tables 43

52 EPC coverage 44

53 Data avaialbility Overall assessment 45

D32 Technical Report on Market Needs and Gaps

549

1 INTRODUCTION

The EeDaPP project seeks to provide a protocol and a technical solution for the design and use of a

Standardised Reporting Template and Common Data Portal for energy efficient mortgages and

assets This can be segmented into three key sections as illustrated in the figure below First EeDaPP

as an IT system solution proposes a reporting protocol to collect data and gather information on

energy efficient assets Second using the data collected provide a reliable database for the analysis

of the risk profile and performance of this new financial product and assess the statistical evidence

of the impact on energy performance on key mortgage indicators Loan to Value (LTV) Probability of

Default (PD) and Loss Given Default (LGD) Thirdly and finally the reporting protocol can be used to

disclose key features of Energy Efficient Assets to serve a potential certification or labelling process

to be used as an impact report for funding purposes and as empirical evidence for policy and

prudential purposes

Gathering

bullIT System solution to gather EEM data information and characteristics

bullReporting Criteria and Management Standardisation

Processing

bullEEM Performance and Risk Analysis ndash analyse and quantify the impact of energy efficiency on major risk indicators such as the impact on property value (LTV and LGD) and on the probability of default (PD)

Disclosure

bullOutput reporting for EEM certificationlabelling

bullImpact reporting for funding tools

bullStatistical evidence for empirical policy recommendations and prudential treatment of EEM

D32 Technical Report on Market Needs and Gaps

649

2 IDENTIFYING MARKET NEEDS

21 Gathering

Market needs to design a harmonised common data portal which market players generally and

lending institutions in particular need to gather and consolidate information coming from different

sources of different natures and with several levels of aggregation Moreover the implementation of

the data gathering and reporting protocol must be elaborated with the objective of optimisation and

cost mutualisation for the EEM product and its integration with IT systems already in place (ie

integrate with existing reporting requirements and practices minimise additional criteria)

211 Market needs Energy Efficient Mortgages framework and stakeholders

The EeDaPP initiative aims to develop reporting standards and design a common data portal for EEM

This implies gathering relevant information from several stakeholders The Energy Efficient Mortgage

market is complex as it involves numerous and diverse actors from both the public and the private

spheres on the retail and capital markets sides (see Figure 1)

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side

Source EeDaPP Consortium

The Energy Efficient Mortgage data reporting protocol is an integrated tool that gathers key data

and indicators from three different ldquolayersrdquo according to the sourcing and the use of the data

provided

EEM

Borrowers

Banks

Valuers

Public Authorities

SMEs

Technical Experts

EEM Portfolio

Investors

Capital Markets

Authorities

Certification Bodies

Rating Agengies

Internation-al pledges

on Paris Agreement

Green Bond

Issuers

D32 Technical Report on Market Needs and Gaps

749

Loan level (banks and borrowers) On the origination side borrowers are at the very beginning of the

value chain as they trigger the energy efficiency investment (either by buying a dwelling that is already

energy efficient or by undertaking energy upgrades on their property) These initial investors can be

real-estate companies (private or social housing funders) or households (that can be either private

landlords landlords in co-ownership or tenants) that become borrowers once they decide to finance

their project with bank lending and apply for financing via a loan or a mortgage from lending

institutions These lending institutions can be of several types private banks specialised banks or

public entities that operate with financial intermediaries Note that in some cases specific groups of

households can rely on specialised agencies1 such as credit assessors as a first point of contact Most

secured lending requires the gathering of information on both the status of the borrower herhis

creditworthiness determined by the lender and the quality of the underlying collateral The former is

derived directly from the borrower the latter is advised by a valuer or via an AVM (automated

valuation model) instructed by the lending institution The role of the valuer who is typically a

qualified professional operating in line with requirements laid down by their professional body is

normally to supply an estimate of the appraisal value of the asset as at the appraisal date of valuation

(Market Value - MV or Mortgage Lending Value - MLV) This value will determine the (current) Loan

to Value ratio which is determinant for the bank to assess the amount of the requested loan relative

to the value of the property

Asset level (energy performance of the building and energy efficiency upgrades) The value of the

property and selected features are assessed by valuers or valuation models The energy performance

of the property is assessed by technical experts who perform energy audits and deliver Energy

Performance Certificates (EPC) The energy performance assessment of the building can also be

inferred by hedonistic modelling (ie Automated Valuation Models) to obtain ldquotheoreticalrdquo EPC (see

the Dutch and Belgian cases cited later in this report) In most cases the energy efficient mortgage will

be granted for the purchase and subsequent energy efficient renovation of existing properties The

energy performance resulting from specific renovation works will be assessed andor certified through

building renovation roadmaps and involve the expertise of constructionbuilding actors

Portfolio level (EEM certification and labelling for funding purposes) Energy efficient mortgages

pooled in a portfolio can constitute a new kind of asset class that classifies EEM portfolios as a ldquo2deg

alignedrdquo (aligned with the COP21 Paris Agreement pledges to limit climate heat change to less than 2

degrees Celsius) or ldquogreenrdquo bond eligible To align with current market practices and upcoming

regulations and requirements covered bond and securitisation issuers will need to disclose specific

information relative to the alignment of the portfolio to sustainable goals and the ldquogreenrdquo taxonomy

in place (see more on this in Section 2 of the report) They are subject to second party opinions and

external ratings from specialised agencies and certification bodies Therefore there is a need for in-

depth and robust data on energy performance in order to ensure that European low carbon energy

1 In France or in Ireland for example specialised agencies (ANAH and SEAI) are providing funds and grants to fuel-poor households to refurbish their homes

D32 Technical Report on Market Needs and Gaps

849

transition targets set at national and international levels relative to energy consumption and the

carbon footprint of the residential sector are met

Table 1 Reporting ldquoLayersrdquo and information sources

Reporting ldquoLayerrdquo Datainformation source Aggregation Level

Financial reporting Mortgage Lending InstitutionData repositories

Loan level

Valuation reporting ValuerReal estate data providersLender PropertyIndividualloan level

Energy performance reporting

Energy AuditorsArchitectsBuilding performance logbookGreen building label certifiers

PropertyIndividual level

Impact reporting Funding instrument issuerSecond party opinionldquoGreen bondrdquo certification agencies

Portfolio aggregated and macro level

Source EeDaPP Consortium

212 Existing reporting frameworks

For time cost and resource optimisation purposes the EeDaPP initiative must build on all existing

reporting templates and framework to gather the relevant data on Energy Efficient Mortgages

To date there are several reporting methods andor databases in place regarding the information that

the EeDaPP data portal needs to collate such as on the financial performance of loans property

valuation data the energy performance of the building stock energy efficiency upgrades and relevant

public policies regarding energy efficiency and performance in European countries

Financial performance reporting

Regarding financial reporting there are already several mandatory and regulatory reporting

frameworks that mortgage lending institutions must comply with and use to deliver data to their

regulator for transparency and prudential risk monitoring exercises These frameworks are either

public or confidential and comprise mandatory or optional reporting variables They constitute the

foundation of the EeDaPP reporting protocol and requirements regarding mortgage related and loan

level financial data

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 2: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

249

Executive Summary

The first EeDaPP report - including a mapping exercise ndash which provided a detailed analysis of existing

green reporting criteria in the energy efficiency and buildings sectors allowed us to narrow down the

variables and define the list of criteria to underpin the data protocol The present report identifies

market gaps and needs in the Energy Efficient Mortgages (hereafter EEM) market with regard to

information and data gathering processing and disclosure

Gathering Market players generally and lending institutions in particular need to gather and

consolidate information coming from different sources of different natures and with several levels of

aggregation Moreover the implementation of the data gathering and reporting protocol must be

elaborated with the objective of optimisation and cost mutualisation for the EEM product and its

integration with IT systems already in place (ie integrate with existing reporting requirements and

practices minimise additional criteria)

Processing The EeDaPP initiative aims to provide relevant robust and reliable information to assess

EEM performance and risk evaluation The common database is an unprecedented collection of

reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

Disclosure The green bond market is growing rapidly and is key to the mobilisation of sustainable

investments As such it needs clear yet rigorous criteria for eligible assets for each key sector (new

and existing buildings in our case) and a harmonised and transparent reporting process aligned with

existing international standards regulatory developments and market best practices

To reach these objectives the EeDaPP initiative has to overcome the following gaps in the market

- Data availability issues at European and national levels regarding financial property valuation

and energy performance data

- Data consolidation harmonisation and comparability issues when processing information

coming from several data sources of different formats natures and calculation methods

- Data quality and representativeness issues for risk impact assessments

- Data monitoring issues especially regarding dynamic and evolving sustainability targets

criteria stringency and energy consumption reporting and monitoring

The ultimate objective of this work together with the previous publication (D31 ndash available here ) and

a final report (to be published in the future) is to elaborate a detailed and comprehensive list of energy

efficiency and performance criteria The full list of relevant data fields is to be collated in a reporting

protocol and common data portal which will allow the gathering processing and disclosur of relevant

information on Energy Efficient Mortgages across European markets

Source Activity WP3PU Editor L Bertalot (EMF-ECBC) Authors D Leboullenger J Johnson L Bertalot D Westig Status Final Date 30112018 Contractual Delivery Date M6

D32 Technical Report on Market Needs and Gaps

349

Table of Contents

1 INTRODUCTION 5

2 IDENTIFYING MARKET NEEDS 6

21 Gathering 6

211 Market needs Energy Efficient Mortgages framework and stakeholders 6

212 Existing reporting frameworks 8

22 Processing 14

221 Market needs Establish a direct link between loan level credit and mortgage risks

property valuation and energy performance 14

222 Existing studies on the link between the energy performance of buildings and mortgage

defaulthelliphelliphelliphelliphelliphellip 14

223 Reporting on the financial performance and related risk of Energy Efficiency

investments and energy upgrades 16

23 Disclosure 16

231 Market needs Provide the missing link from origination to funding 17

232 Impact reporting 18

233 Alignment with existing taxonomy international pledges and regulatory

developmentshelliphelliphelliphelliphelliphellip 20

3 ASSESS MARKET GAPS 25

31 Data Availability 25

311 Overall assessment 25

312 Energy performance data availability 25

313 Link between energy performance property valuation and mortgage data 29

32 Data Consolidation Comparability and Harmonisation Issues 30

321 Data consolidation and common key identifier 30

322 Harmonisation of the different methodologies and definitions 30

323 Calculation methods and comparability issues 32

33 Data Minimum Quality and Representativeness 35

331 Sampling problem coverage and data history 35

332 Lack of default data for the relevant period 36

34 Data Processing Monitoring and Usage 36

341 Privacy and contractual considerations 36

D32 Technical Report on Market Needs and Gaps

449

342 Practical issues Dynamic monitoring 38

343 Evolving sustainability targets 39

4 Conclusions and next steps 42

5 Annexes 43

51 List of figures and tables 43

52 EPC coverage 44

53 Data avaialbility Overall assessment 45

D32 Technical Report on Market Needs and Gaps

549

1 INTRODUCTION

The EeDaPP project seeks to provide a protocol and a technical solution for the design and use of a

Standardised Reporting Template and Common Data Portal for energy efficient mortgages and

assets This can be segmented into three key sections as illustrated in the figure below First EeDaPP

as an IT system solution proposes a reporting protocol to collect data and gather information on

energy efficient assets Second using the data collected provide a reliable database for the analysis

of the risk profile and performance of this new financial product and assess the statistical evidence

of the impact on energy performance on key mortgage indicators Loan to Value (LTV) Probability of

Default (PD) and Loss Given Default (LGD) Thirdly and finally the reporting protocol can be used to

disclose key features of Energy Efficient Assets to serve a potential certification or labelling process

to be used as an impact report for funding purposes and as empirical evidence for policy and

prudential purposes

Gathering

bullIT System solution to gather EEM data information and characteristics

bullReporting Criteria and Management Standardisation

Processing

bullEEM Performance and Risk Analysis ndash analyse and quantify the impact of energy efficiency on major risk indicators such as the impact on property value (LTV and LGD) and on the probability of default (PD)

Disclosure

bullOutput reporting for EEM certificationlabelling

bullImpact reporting for funding tools

bullStatistical evidence for empirical policy recommendations and prudential treatment of EEM

D32 Technical Report on Market Needs and Gaps

649

2 IDENTIFYING MARKET NEEDS

21 Gathering

Market needs to design a harmonised common data portal which market players generally and

lending institutions in particular need to gather and consolidate information coming from different

sources of different natures and with several levels of aggregation Moreover the implementation of

the data gathering and reporting protocol must be elaborated with the objective of optimisation and

cost mutualisation for the EEM product and its integration with IT systems already in place (ie

integrate with existing reporting requirements and practices minimise additional criteria)

211 Market needs Energy Efficient Mortgages framework and stakeholders

The EeDaPP initiative aims to develop reporting standards and design a common data portal for EEM

This implies gathering relevant information from several stakeholders The Energy Efficient Mortgage

market is complex as it involves numerous and diverse actors from both the public and the private

spheres on the retail and capital markets sides (see Figure 1)

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side

Source EeDaPP Consortium

The Energy Efficient Mortgage data reporting protocol is an integrated tool that gathers key data

and indicators from three different ldquolayersrdquo according to the sourcing and the use of the data

provided

EEM

Borrowers

Banks

Valuers

Public Authorities

SMEs

Technical Experts

EEM Portfolio

Investors

Capital Markets

Authorities

Certification Bodies

Rating Agengies

Internation-al pledges

on Paris Agreement

Green Bond

Issuers

D32 Technical Report on Market Needs and Gaps

749

Loan level (banks and borrowers) On the origination side borrowers are at the very beginning of the

value chain as they trigger the energy efficiency investment (either by buying a dwelling that is already

energy efficient or by undertaking energy upgrades on their property) These initial investors can be

real-estate companies (private or social housing funders) or households (that can be either private

landlords landlords in co-ownership or tenants) that become borrowers once they decide to finance

their project with bank lending and apply for financing via a loan or a mortgage from lending

institutions These lending institutions can be of several types private banks specialised banks or

public entities that operate with financial intermediaries Note that in some cases specific groups of

households can rely on specialised agencies1 such as credit assessors as a first point of contact Most

secured lending requires the gathering of information on both the status of the borrower herhis

creditworthiness determined by the lender and the quality of the underlying collateral The former is

derived directly from the borrower the latter is advised by a valuer or via an AVM (automated

valuation model) instructed by the lending institution The role of the valuer who is typically a

qualified professional operating in line with requirements laid down by their professional body is

normally to supply an estimate of the appraisal value of the asset as at the appraisal date of valuation

(Market Value - MV or Mortgage Lending Value - MLV) This value will determine the (current) Loan

to Value ratio which is determinant for the bank to assess the amount of the requested loan relative

to the value of the property

Asset level (energy performance of the building and energy efficiency upgrades) The value of the

property and selected features are assessed by valuers or valuation models The energy performance

of the property is assessed by technical experts who perform energy audits and deliver Energy

Performance Certificates (EPC) The energy performance assessment of the building can also be

inferred by hedonistic modelling (ie Automated Valuation Models) to obtain ldquotheoreticalrdquo EPC (see

the Dutch and Belgian cases cited later in this report) In most cases the energy efficient mortgage will

be granted for the purchase and subsequent energy efficient renovation of existing properties The

energy performance resulting from specific renovation works will be assessed andor certified through

building renovation roadmaps and involve the expertise of constructionbuilding actors

Portfolio level (EEM certification and labelling for funding purposes) Energy efficient mortgages

pooled in a portfolio can constitute a new kind of asset class that classifies EEM portfolios as a ldquo2deg

alignedrdquo (aligned with the COP21 Paris Agreement pledges to limit climate heat change to less than 2

degrees Celsius) or ldquogreenrdquo bond eligible To align with current market practices and upcoming

regulations and requirements covered bond and securitisation issuers will need to disclose specific

information relative to the alignment of the portfolio to sustainable goals and the ldquogreenrdquo taxonomy

in place (see more on this in Section 2 of the report) They are subject to second party opinions and

external ratings from specialised agencies and certification bodies Therefore there is a need for in-

depth and robust data on energy performance in order to ensure that European low carbon energy

1 In France or in Ireland for example specialised agencies (ANAH and SEAI) are providing funds and grants to fuel-poor households to refurbish their homes

D32 Technical Report on Market Needs and Gaps

849

transition targets set at national and international levels relative to energy consumption and the

carbon footprint of the residential sector are met

Table 1 Reporting ldquoLayersrdquo and information sources

Reporting ldquoLayerrdquo Datainformation source Aggregation Level

Financial reporting Mortgage Lending InstitutionData repositories

Loan level

Valuation reporting ValuerReal estate data providersLender PropertyIndividualloan level

Energy performance reporting

Energy AuditorsArchitectsBuilding performance logbookGreen building label certifiers

PropertyIndividual level

Impact reporting Funding instrument issuerSecond party opinionldquoGreen bondrdquo certification agencies

Portfolio aggregated and macro level

Source EeDaPP Consortium

212 Existing reporting frameworks

For time cost and resource optimisation purposes the EeDaPP initiative must build on all existing

reporting templates and framework to gather the relevant data on Energy Efficient Mortgages

To date there are several reporting methods andor databases in place regarding the information that

the EeDaPP data portal needs to collate such as on the financial performance of loans property

valuation data the energy performance of the building stock energy efficiency upgrades and relevant

public policies regarding energy efficiency and performance in European countries

Financial performance reporting

Regarding financial reporting there are already several mandatory and regulatory reporting

frameworks that mortgage lending institutions must comply with and use to deliver data to their

regulator for transparency and prudential risk monitoring exercises These frameworks are either

public or confidential and comprise mandatory or optional reporting variables They constitute the

foundation of the EeDaPP reporting protocol and requirements regarding mortgage related and loan

level financial data

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 3: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

349

Table of Contents

1 INTRODUCTION 5

2 IDENTIFYING MARKET NEEDS 6

21 Gathering 6

211 Market needs Energy Efficient Mortgages framework and stakeholders 6

212 Existing reporting frameworks 8

22 Processing 14

221 Market needs Establish a direct link between loan level credit and mortgage risks

property valuation and energy performance 14

222 Existing studies on the link between the energy performance of buildings and mortgage

defaulthelliphelliphelliphelliphelliphellip 14

223 Reporting on the financial performance and related risk of Energy Efficiency

investments and energy upgrades 16

23 Disclosure 16

231 Market needs Provide the missing link from origination to funding 17

232 Impact reporting 18

233 Alignment with existing taxonomy international pledges and regulatory

developmentshelliphelliphelliphelliphelliphellip 20

3 ASSESS MARKET GAPS 25

31 Data Availability 25

311 Overall assessment 25

312 Energy performance data availability 25

313 Link between energy performance property valuation and mortgage data 29

32 Data Consolidation Comparability and Harmonisation Issues 30

321 Data consolidation and common key identifier 30

322 Harmonisation of the different methodologies and definitions 30

323 Calculation methods and comparability issues 32

33 Data Minimum Quality and Representativeness 35

331 Sampling problem coverage and data history 35

332 Lack of default data for the relevant period 36

34 Data Processing Monitoring and Usage 36

341 Privacy and contractual considerations 36

D32 Technical Report on Market Needs and Gaps

449

342 Practical issues Dynamic monitoring 38

343 Evolving sustainability targets 39

4 Conclusions and next steps 42

5 Annexes 43

51 List of figures and tables 43

52 EPC coverage 44

53 Data avaialbility Overall assessment 45

D32 Technical Report on Market Needs and Gaps

549

1 INTRODUCTION

The EeDaPP project seeks to provide a protocol and a technical solution for the design and use of a

Standardised Reporting Template and Common Data Portal for energy efficient mortgages and

assets This can be segmented into three key sections as illustrated in the figure below First EeDaPP

as an IT system solution proposes a reporting protocol to collect data and gather information on

energy efficient assets Second using the data collected provide a reliable database for the analysis

of the risk profile and performance of this new financial product and assess the statistical evidence

of the impact on energy performance on key mortgage indicators Loan to Value (LTV) Probability of

Default (PD) and Loss Given Default (LGD) Thirdly and finally the reporting protocol can be used to

disclose key features of Energy Efficient Assets to serve a potential certification or labelling process

to be used as an impact report for funding purposes and as empirical evidence for policy and

prudential purposes

Gathering

bullIT System solution to gather EEM data information and characteristics

bullReporting Criteria and Management Standardisation

Processing

bullEEM Performance and Risk Analysis ndash analyse and quantify the impact of energy efficiency on major risk indicators such as the impact on property value (LTV and LGD) and on the probability of default (PD)

Disclosure

bullOutput reporting for EEM certificationlabelling

bullImpact reporting for funding tools

bullStatistical evidence for empirical policy recommendations and prudential treatment of EEM

D32 Technical Report on Market Needs and Gaps

649

2 IDENTIFYING MARKET NEEDS

21 Gathering

Market needs to design a harmonised common data portal which market players generally and

lending institutions in particular need to gather and consolidate information coming from different

sources of different natures and with several levels of aggregation Moreover the implementation of

the data gathering and reporting protocol must be elaborated with the objective of optimisation and

cost mutualisation for the EEM product and its integration with IT systems already in place (ie

integrate with existing reporting requirements and practices minimise additional criteria)

211 Market needs Energy Efficient Mortgages framework and stakeholders

The EeDaPP initiative aims to develop reporting standards and design a common data portal for EEM

This implies gathering relevant information from several stakeholders The Energy Efficient Mortgage

market is complex as it involves numerous and diverse actors from both the public and the private

spheres on the retail and capital markets sides (see Figure 1)

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side

Source EeDaPP Consortium

The Energy Efficient Mortgage data reporting protocol is an integrated tool that gathers key data

and indicators from three different ldquolayersrdquo according to the sourcing and the use of the data

provided

EEM

Borrowers

Banks

Valuers

Public Authorities

SMEs

Technical Experts

EEM Portfolio

Investors

Capital Markets

Authorities

Certification Bodies

Rating Agengies

Internation-al pledges

on Paris Agreement

Green Bond

Issuers

D32 Technical Report on Market Needs and Gaps

749

Loan level (banks and borrowers) On the origination side borrowers are at the very beginning of the

value chain as they trigger the energy efficiency investment (either by buying a dwelling that is already

energy efficient or by undertaking energy upgrades on their property) These initial investors can be

real-estate companies (private or social housing funders) or households (that can be either private

landlords landlords in co-ownership or tenants) that become borrowers once they decide to finance

their project with bank lending and apply for financing via a loan or a mortgage from lending

institutions These lending institutions can be of several types private banks specialised banks or

public entities that operate with financial intermediaries Note that in some cases specific groups of

households can rely on specialised agencies1 such as credit assessors as a first point of contact Most

secured lending requires the gathering of information on both the status of the borrower herhis

creditworthiness determined by the lender and the quality of the underlying collateral The former is

derived directly from the borrower the latter is advised by a valuer or via an AVM (automated

valuation model) instructed by the lending institution The role of the valuer who is typically a

qualified professional operating in line with requirements laid down by their professional body is

normally to supply an estimate of the appraisal value of the asset as at the appraisal date of valuation

(Market Value - MV or Mortgage Lending Value - MLV) This value will determine the (current) Loan

to Value ratio which is determinant for the bank to assess the amount of the requested loan relative

to the value of the property

Asset level (energy performance of the building and energy efficiency upgrades) The value of the

property and selected features are assessed by valuers or valuation models The energy performance

of the property is assessed by technical experts who perform energy audits and deliver Energy

Performance Certificates (EPC) The energy performance assessment of the building can also be

inferred by hedonistic modelling (ie Automated Valuation Models) to obtain ldquotheoreticalrdquo EPC (see

the Dutch and Belgian cases cited later in this report) In most cases the energy efficient mortgage will

be granted for the purchase and subsequent energy efficient renovation of existing properties The

energy performance resulting from specific renovation works will be assessed andor certified through

building renovation roadmaps and involve the expertise of constructionbuilding actors

Portfolio level (EEM certification and labelling for funding purposes) Energy efficient mortgages

pooled in a portfolio can constitute a new kind of asset class that classifies EEM portfolios as a ldquo2deg

alignedrdquo (aligned with the COP21 Paris Agreement pledges to limit climate heat change to less than 2

degrees Celsius) or ldquogreenrdquo bond eligible To align with current market practices and upcoming

regulations and requirements covered bond and securitisation issuers will need to disclose specific

information relative to the alignment of the portfolio to sustainable goals and the ldquogreenrdquo taxonomy

in place (see more on this in Section 2 of the report) They are subject to second party opinions and

external ratings from specialised agencies and certification bodies Therefore there is a need for in-

depth and robust data on energy performance in order to ensure that European low carbon energy

1 In France or in Ireland for example specialised agencies (ANAH and SEAI) are providing funds and grants to fuel-poor households to refurbish their homes

D32 Technical Report on Market Needs and Gaps

849

transition targets set at national and international levels relative to energy consumption and the

carbon footprint of the residential sector are met

Table 1 Reporting ldquoLayersrdquo and information sources

Reporting ldquoLayerrdquo Datainformation source Aggregation Level

Financial reporting Mortgage Lending InstitutionData repositories

Loan level

Valuation reporting ValuerReal estate data providersLender PropertyIndividualloan level

Energy performance reporting

Energy AuditorsArchitectsBuilding performance logbookGreen building label certifiers

PropertyIndividual level

Impact reporting Funding instrument issuerSecond party opinionldquoGreen bondrdquo certification agencies

Portfolio aggregated and macro level

Source EeDaPP Consortium

212 Existing reporting frameworks

For time cost and resource optimisation purposes the EeDaPP initiative must build on all existing

reporting templates and framework to gather the relevant data on Energy Efficient Mortgages

To date there are several reporting methods andor databases in place regarding the information that

the EeDaPP data portal needs to collate such as on the financial performance of loans property

valuation data the energy performance of the building stock energy efficiency upgrades and relevant

public policies regarding energy efficiency and performance in European countries

Financial performance reporting

Regarding financial reporting there are already several mandatory and regulatory reporting

frameworks that mortgage lending institutions must comply with and use to deliver data to their

regulator for transparency and prudential risk monitoring exercises These frameworks are either

public or confidential and comprise mandatory or optional reporting variables They constitute the

foundation of the EeDaPP reporting protocol and requirements regarding mortgage related and loan

level financial data

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 4: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

449

342 Practical issues Dynamic monitoring 38

343 Evolving sustainability targets 39

4 Conclusions and next steps 42

5 Annexes 43

51 List of figures and tables 43

52 EPC coverage 44

53 Data avaialbility Overall assessment 45

D32 Technical Report on Market Needs and Gaps

549

1 INTRODUCTION

The EeDaPP project seeks to provide a protocol and a technical solution for the design and use of a

Standardised Reporting Template and Common Data Portal for energy efficient mortgages and

assets This can be segmented into three key sections as illustrated in the figure below First EeDaPP

as an IT system solution proposes a reporting protocol to collect data and gather information on

energy efficient assets Second using the data collected provide a reliable database for the analysis

of the risk profile and performance of this new financial product and assess the statistical evidence

of the impact on energy performance on key mortgage indicators Loan to Value (LTV) Probability of

Default (PD) and Loss Given Default (LGD) Thirdly and finally the reporting protocol can be used to

disclose key features of Energy Efficient Assets to serve a potential certification or labelling process

to be used as an impact report for funding purposes and as empirical evidence for policy and

prudential purposes

Gathering

bullIT System solution to gather EEM data information and characteristics

bullReporting Criteria and Management Standardisation

Processing

bullEEM Performance and Risk Analysis ndash analyse and quantify the impact of energy efficiency on major risk indicators such as the impact on property value (LTV and LGD) and on the probability of default (PD)

Disclosure

bullOutput reporting for EEM certificationlabelling

bullImpact reporting for funding tools

bullStatistical evidence for empirical policy recommendations and prudential treatment of EEM

D32 Technical Report on Market Needs and Gaps

649

2 IDENTIFYING MARKET NEEDS

21 Gathering

Market needs to design a harmonised common data portal which market players generally and

lending institutions in particular need to gather and consolidate information coming from different

sources of different natures and with several levels of aggregation Moreover the implementation of

the data gathering and reporting protocol must be elaborated with the objective of optimisation and

cost mutualisation for the EEM product and its integration with IT systems already in place (ie

integrate with existing reporting requirements and practices minimise additional criteria)

211 Market needs Energy Efficient Mortgages framework and stakeholders

The EeDaPP initiative aims to develop reporting standards and design a common data portal for EEM

This implies gathering relevant information from several stakeholders The Energy Efficient Mortgage

market is complex as it involves numerous and diverse actors from both the public and the private

spheres on the retail and capital markets sides (see Figure 1)

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side

Source EeDaPP Consortium

The Energy Efficient Mortgage data reporting protocol is an integrated tool that gathers key data

and indicators from three different ldquolayersrdquo according to the sourcing and the use of the data

provided

EEM

Borrowers

Banks

Valuers

Public Authorities

SMEs

Technical Experts

EEM Portfolio

Investors

Capital Markets

Authorities

Certification Bodies

Rating Agengies

Internation-al pledges

on Paris Agreement

Green Bond

Issuers

D32 Technical Report on Market Needs and Gaps

749

Loan level (banks and borrowers) On the origination side borrowers are at the very beginning of the

value chain as they trigger the energy efficiency investment (either by buying a dwelling that is already

energy efficient or by undertaking energy upgrades on their property) These initial investors can be

real-estate companies (private or social housing funders) or households (that can be either private

landlords landlords in co-ownership or tenants) that become borrowers once they decide to finance

their project with bank lending and apply for financing via a loan or a mortgage from lending

institutions These lending institutions can be of several types private banks specialised banks or

public entities that operate with financial intermediaries Note that in some cases specific groups of

households can rely on specialised agencies1 such as credit assessors as a first point of contact Most

secured lending requires the gathering of information on both the status of the borrower herhis

creditworthiness determined by the lender and the quality of the underlying collateral The former is

derived directly from the borrower the latter is advised by a valuer or via an AVM (automated

valuation model) instructed by the lending institution The role of the valuer who is typically a

qualified professional operating in line with requirements laid down by their professional body is

normally to supply an estimate of the appraisal value of the asset as at the appraisal date of valuation

(Market Value - MV or Mortgage Lending Value - MLV) This value will determine the (current) Loan

to Value ratio which is determinant for the bank to assess the amount of the requested loan relative

to the value of the property

Asset level (energy performance of the building and energy efficiency upgrades) The value of the

property and selected features are assessed by valuers or valuation models The energy performance

of the property is assessed by technical experts who perform energy audits and deliver Energy

Performance Certificates (EPC) The energy performance assessment of the building can also be

inferred by hedonistic modelling (ie Automated Valuation Models) to obtain ldquotheoreticalrdquo EPC (see

the Dutch and Belgian cases cited later in this report) In most cases the energy efficient mortgage will

be granted for the purchase and subsequent energy efficient renovation of existing properties The

energy performance resulting from specific renovation works will be assessed andor certified through

building renovation roadmaps and involve the expertise of constructionbuilding actors

Portfolio level (EEM certification and labelling for funding purposes) Energy efficient mortgages

pooled in a portfolio can constitute a new kind of asset class that classifies EEM portfolios as a ldquo2deg

alignedrdquo (aligned with the COP21 Paris Agreement pledges to limit climate heat change to less than 2

degrees Celsius) or ldquogreenrdquo bond eligible To align with current market practices and upcoming

regulations and requirements covered bond and securitisation issuers will need to disclose specific

information relative to the alignment of the portfolio to sustainable goals and the ldquogreenrdquo taxonomy

in place (see more on this in Section 2 of the report) They are subject to second party opinions and

external ratings from specialised agencies and certification bodies Therefore there is a need for in-

depth and robust data on energy performance in order to ensure that European low carbon energy

1 In France or in Ireland for example specialised agencies (ANAH and SEAI) are providing funds and grants to fuel-poor households to refurbish their homes

D32 Technical Report on Market Needs and Gaps

849

transition targets set at national and international levels relative to energy consumption and the

carbon footprint of the residential sector are met

Table 1 Reporting ldquoLayersrdquo and information sources

Reporting ldquoLayerrdquo Datainformation source Aggregation Level

Financial reporting Mortgage Lending InstitutionData repositories

Loan level

Valuation reporting ValuerReal estate data providersLender PropertyIndividualloan level

Energy performance reporting

Energy AuditorsArchitectsBuilding performance logbookGreen building label certifiers

PropertyIndividual level

Impact reporting Funding instrument issuerSecond party opinionldquoGreen bondrdquo certification agencies

Portfolio aggregated and macro level

Source EeDaPP Consortium

212 Existing reporting frameworks

For time cost and resource optimisation purposes the EeDaPP initiative must build on all existing

reporting templates and framework to gather the relevant data on Energy Efficient Mortgages

To date there are several reporting methods andor databases in place regarding the information that

the EeDaPP data portal needs to collate such as on the financial performance of loans property

valuation data the energy performance of the building stock energy efficiency upgrades and relevant

public policies regarding energy efficiency and performance in European countries

Financial performance reporting

Regarding financial reporting there are already several mandatory and regulatory reporting

frameworks that mortgage lending institutions must comply with and use to deliver data to their

regulator for transparency and prudential risk monitoring exercises These frameworks are either

public or confidential and comprise mandatory or optional reporting variables They constitute the

foundation of the EeDaPP reporting protocol and requirements regarding mortgage related and loan

level financial data

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 5: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

549

1 INTRODUCTION

The EeDaPP project seeks to provide a protocol and a technical solution for the design and use of a

Standardised Reporting Template and Common Data Portal for energy efficient mortgages and

assets This can be segmented into three key sections as illustrated in the figure below First EeDaPP

as an IT system solution proposes a reporting protocol to collect data and gather information on

energy efficient assets Second using the data collected provide a reliable database for the analysis

of the risk profile and performance of this new financial product and assess the statistical evidence

of the impact on energy performance on key mortgage indicators Loan to Value (LTV) Probability of

Default (PD) and Loss Given Default (LGD) Thirdly and finally the reporting protocol can be used to

disclose key features of Energy Efficient Assets to serve a potential certification or labelling process

to be used as an impact report for funding purposes and as empirical evidence for policy and

prudential purposes

Gathering

bullIT System solution to gather EEM data information and characteristics

bullReporting Criteria and Management Standardisation

Processing

bullEEM Performance and Risk Analysis ndash analyse and quantify the impact of energy efficiency on major risk indicators such as the impact on property value (LTV and LGD) and on the probability of default (PD)

Disclosure

bullOutput reporting for EEM certificationlabelling

bullImpact reporting for funding tools

bullStatistical evidence for empirical policy recommendations and prudential treatment of EEM

D32 Technical Report on Market Needs and Gaps

649

2 IDENTIFYING MARKET NEEDS

21 Gathering

Market needs to design a harmonised common data portal which market players generally and

lending institutions in particular need to gather and consolidate information coming from different

sources of different natures and with several levels of aggregation Moreover the implementation of

the data gathering and reporting protocol must be elaborated with the objective of optimisation and

cost mutualisation for the EEM product and its integration with IT systems already in place (ie

integrate with existing reporting requirements and practices minimise additional criteria)

211 Market needs Energy Efficient Mortgages framework and stakeholders

The EeDaPP initiative aims to develop reporting standards and design a common data portal for EEM

This implies gathering relevant information from several stakeholders The Energy Efficient Mortgage

market is complex as it involves numerous and diverse actors from both the public and the private

spheres on the retail and capital markets sides (see Figure 1)

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side

Source EeDaPP Consortium

The Energy Efficient Mortgage data reporting protocol is an integrated tool that gathers key data

and indicators from three different ldquolayersrdquo according to the sourcing and the use of the data

provided

EEM

Borrowers

Banks

Valuers

Public Authorities

SMEs

Technical Experts

EEM Portfolio

Investors

Capital Markets

Authorities

Certification Bodies

Rating Agengies

Internation-al pledges

on Paris Agreement

Green Bond

Issuers

D32 Technical Report on Market Needs and Gaps

749

Loan level (banks and borrowers) On the origination side borrowers are at the very beginning of the

value chain as they trigger the energy efficiency investment (either by buying a dwelling that is already

energy efficient or by undertaking energy upgrades on their property) These initial investors can be

real-estate companies (private or social housing funders) or households (that can be either private

landlords landlords in co-ownership or tenants) that become borrowers once they decide to finance

their project with bank lending and apply for financing via a loan or a mortgage from lending

institutions These lending institutions can be of several types private banks specialised banks or

public entities that operate with financial intermediaries Note that in some cases specific groups of

households can rely on specialised agencies1 such as credit assessors as a first point of contact Most

secured lending requires the gathering of information on both the status of the borrower herhis

creditworthiness determined by the lender and the quality of the underlying collateral The former is

derived directly from the borrower the latter is advised by a valuer or via an AVM (automated

valuation model) instructed by the lending institution The role of the valuer who is typically a

qualified professional operating in line with requirements laid down by their professional body is

normally to supply an estimate of the appraisal value of the asset as at the appraisal date of valuation

(Market Value - MV or Mortgage Lending Value - MLV) This value will determine the (current) Loan

to Value ratio which is determinant for the bank to assess the amount of the requested loan relative

to the value of the property

Asset level (energy performance of the building and energy efficiency upgrades) The value of the

property and selected features are assessed by valuers or valuation models The energy performance

of the property is assessed by technical experts who perform energy audits and deliver Energy

Performance Certificates (EPC) The energy performance assessment of the building can also be

inferred by hedonistic modelling (ie Automated Valuation Models) to obtain ldquotheoreticalrdquo EPC (see

the Dutch and Belgian cases cited later in this report) In most cases the energy efficient mortgage will

be granted for the purchase and subsequent energy efficient renovation of existing properties The

energy performance resulting from specific renovation works will be assessed andor certified through

building renovation roadmaps and involve the expertise of constructionbuilding actors

Portfolio level (EEM certification and labelling for funding purposes) Energy efficient mortgages

pooled in a portfolio can constitute a new kind of asset class that classifies EEM portfolios as a ldquo2deg

alignedrdquo (aligned with the COP21 Paris Agreement pledges to limit climate heat change to less than 2

degrees Celsius) or ldquogreenrdquo bond eligible To align with current market practices and upcoming

regulations and requirements covered bond and securitisation issuers will need to disclose specific

information relative to the alignment of the portfolio to sustainable goals and the ldquogreenrdquo taxonomy

in place (see more on this in Section 2 of the report) They are subject to second party opinions and

external ratings from specialised agencies and certification bodies Therefore there is a need for in-

depth and robust data on energy performance in order to ensure that European low carbon energy

1 In France or in Ireland for example specialised agencies (ANAH and SEAI) are providing funds and grants to fuel-poor households to refurbish their homes

D32 Technical Report on Market Needs and Gaps

849

transition targets set at national and international levels relative to energy consumption and the

carbon footprint of the residential sector are met

Table 1 Reporting ldquoLayersrdquo and information sources

Reporting ldquoLayerrdquo Datainformation source Aggregation Level

Financial reporting Mortgage Lending InstitutionData repositories

Loan level

Valuation reporting ValuerReal estate data providersLender PropertyIndividualloan level

Energy performance reporting

Energy AuditorsArchitectsBuilding performance logbookGreen building label certifiers

PropertyIndividual level

Impact reporting Funding instrument issuerSecond party opinionldquoGreen bondrdquo certification agencies

Portfolio aggregated and macro level

Source EeDaPP Consortium

212 Existing reporting frameworks

For time cost and resource optimisation purposes the EeDaPP initiative must build on all existing

reporting templates and framework to gather the relevant data on Energy Efficient Mortgages

To date there are several reporting methods andor databases in place regarding the information that

the EeDaPP data portal needs to collate such as on the financial performance of loans property

valuation data the energy performance of the building stock energy efficiency upgrades and relevant

public policies regarding energy efficiency and performance in European countries

Financial performance reporting

Regarding financial reporting there are already several mandatory and regulatory reporting

frameworks that mortgage lending institutions must comply with and use to deliver data to their

regulator for transparency and prudential risk monitoring exercises These frameworks are either

public or confidential and comprise mandatory or optional reporting variables They constitute the

foundation of the EeDaPP reporting protocol and requirements regarding mortgage related and loan

level financial data

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 6: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

649

2 IDENTIFYING MARKET NEEDS

21 Gathering

Market needs to design a harmonised common data portal which market players generally and

lending institutions in particular need to gather and consolidate information coming from different

sources of different natures and with several levels of aggregation Moreover the implementation of

the data gathering and reporting protocol must be elaborated with the objective of optimisation and

cost mutualisation for the EEM product and its integration with IT systems already in place (ie

integrate with existing reporting requirements and practices minimise additional criteria)

211 Market needs Energy Efficient Mortgages framework and stakeholders

The EeDaPP initiative aims to develop reporting standards and design a common data portal for EEM

This implies gathering relevant information from several stakeholders The Energy Efficient Mortgage

market is complex as it involves numerous and diverse actors from both the public and the private

spheres on the retail and capital markets sides (see Figure 1)

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side

Source EeDaPP Consortium

The Energy Efficient Mortgage data reporting protocol is an integrated tool that gathers key data

and indicators from three different ldquolayersrdquo according to the sourcing and the use of the data

provided

EEM

Borrowers

Banks

Valuers

Public Authorities

SMEs

Technical Experts

EEM Portfolio

Investors

Capital Markets

Authorities

Certification Bodies

Rating Agengies

Internation-al pledges

on Paris Agreement

Green Bond

Issuers

D32 Technical Report on Market Needs and Gaps

749

Loan level (banks and borrowers) On the origination side borrowers are at the very beginning of the

value chain as they trigger the energy efficiency investment (either by buying a dwelling that is already

energy efficient or by undertaking energy upgrades on their property) These initial investors can be

real-estate companies (private or social housing funders) or households (that can be either private

landlords landlords in co-ownership or tenants) that become borrowers once they decide to finance

their project with bank lending and apply for financing via a loan or a mortgage from lending

institutions These lending institutions can be of several types private banks specialised banks or

public entities that operate with financial intermediaries Note that in some cases specific groups of

households can rely on specialised agencies1 such as credit assessors as a first point of contact Most

secured lending requires the gathering of information on both the status of the borrower herhis

creditworthiness determined by the lender and the quality of the underlying collateral The former is

derived directly from the borrower the latter is advised by a valuer or via an AVM (automated

valuation model) instructed by the lending institution The role of the valuer who is typically a

qualified professional operating in line with requirements laid down by their professional body is

normally to supply an estimate of the appraisal value of the asset as at the appraisal date of valuation

(Market Value - MV or Mortgage Lending Value - MLV) This value will determine the (current) Loan

to Value ratio which is determinant for the bank to assess the amount of the requested loan relative

to the value of the property

Asset level (energy performance of the building and energy efficiency upgrades) The value of the

property and selected features are assessed by valuers or valuation models The energy performance

of the property is assessed by technical experts who perform energy audits and deliver Energy

Performance Certificates (EPC) The energy performance assessment of the building can also be

inferred by hedonistic modelling (ie Automated Valuation Models) to obtain ldquotheoreticalrdquo EPC (see

the Dutch and Belgian cases cited later in this report) In most cases the energy efficient mortgage will

be granted for the purchase and subsequent energy efficient renovation of existing properties The

energy performance resulting from specific renovation works will be assessed andor certified through

building renovation roadmaps and involve the expertise of constructionbuilding actors

Portfolio level (EEM certification and labelling for funding purposes) Energy efficient mortgages

pooled in a portfolio can constitute a new kind of asset class that classifies EEM portfolios as a ldquo2deg

alignedrdquo (aligned with the COP21 Paris Agreement pledges to limit climate heat change to less than 2

degrees Celsius) or ldquogreenrdquo bond eligible To align with current market practices and upcoming

regulations and requirements covered bond and securitisation issuers will need to disclose specific

information relative to the alignment of the portfolio to sustainable goals and the ldquogreenrdquo taxonomy

in place (see more on this in Section 2 of the report) They are subject to second party opinions and

external ratings from specialised agencies and certification bodies Therefore there is a need for in-

depth and robust data on energy performance in order to ensure that European low carbon energy

1 In France or in Ireland for example specialised agencies (ANAH and SEAI) are providing funds and grants to fuel-poor households to refurbish their homes

D32 Technical Report on Market Needs and Gaps

849

transition targets set at national and international levels relative to energy consumption and the

carbon footprint of the residential sector are met

Table 1 Reporting ldquoLayersrdquo and information sources

Reporting ldquoLayerrdquo Datainformation source Aggregation Level

Financial reporting Mortgage Lending InstitutionData repositories

Loan level

Valuation reporting ValuerReal estate data providersLender PropertyIndividualloan level

Energy performance reporting

Energy AuditorsArchitectsBuilding performance logbookGreen building label certifiers

PropertyIndividual level

Impact reporting Funding instrument issuerSecond party opinionldquoGreen bondrdquo certification agencies

Portfolio aggregated and macro level

Source EeDaPP Consortium

212 Existing reporting frameworks

For time cost and resource optimisation purposes the EeDaPP initiative must build on all existing

reporting templates and framework to gather the relevant data on Energy Efficient Mortgages

To date there are several reporting methods andor databases in place regarding the information that

the EeDaPP data portal needs to collate such as on the financial performance of loans property

valuation data the energy performance of the building stock energy efficiency upgrades and relevant

public policies regarding energy efficiency and performance in European countries

Financial performance reporting

Regarding financial reporting there are already several mandatory and regulatory reporting

frameworks that mortgage lending institutions must comply with and use to deliver data to their

regulator for transparency and prudential risk monitoring exercises These frameworks are either

public or confidential and comprise mandatory or optional reporting variables They constitute the

foundation of the EeDaPP reporting protocol and requirements regarding mortgage related and loan

level financial data

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 7: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

749

Loan level (banks and borrowers) On the origination side borrowers are at the very beginning of the

value chain as they trigger the energy efficiency investment (either by buying a dwelling that is already

energy efficient or by undertaking energy upgrades on their property) These initial investors can be

real-estate companies (private or social housing funders) or households (that can be either private

landlords landlords in co-ownership or tenants) that become borrowers once they decide to finance

their project with bank lending and apply for financing via a loan or a mortgage from lending

institutions These lending institutions can be of several types private banks specialised banks or

public entities that operate with financial intermediaries Note that in some cases specific groups of

households can rely on specialised agencies1 such as credit assessors as a first point of contact Most

secured lending requires the gathering of information on both the status of the borrower herhis

creditworthiness determined by the lender and the quality of the underlying collateral The former is

derived directly from the borrower the latter is advised by a valuer or via an AVM (automated

valuation model) instructed by the lending institution The role of the valuer who is typically a

qualified professional operating in line with requirements laid down by their professional body is

normally to supply an estimate of the appraisal value of the asset as at the appraisal date of valuation

(Market Value - MV or Mortgage Lending Value - MLV) This value will determine the (current) Loan

to Value ratio which is determinant for the bank to assess the amount of the requested loan relative

to the value of the property

Asset level (energy performance of the building and energy efficiency upgrades) The value of the

property and selected features are assessed by valuers or valuation models The energy performance

of the property is assessed by technical experts who perform energy audits and deliver Energy

Performance Certificates (EPC) The energy performance assessment of the building can also be

inferred by hedonistic modelling (ie Automated Valuation Models) to obtain ldquotheoreticalrdquo EPC (see

the Dutch and Belgian cases cited later in this report) In most cases the energy efficient mortgage will

be granted for the purchase and subsequent energy efficient renovation of existing properties The

energy performance resulting from specific renovation works will be assessed andor certified through

building renovation roadmaps and involve the expertise of constructionbuilding actors

Portfolio level (EEM certification and labelling for funding purposes) Energy efficient mortgages

pooled in a portfolio can constitute a new kind of asset class that classifies EEM portfolios as a ldquo2deg

alignedrdquo (aligned with the COP21 Paris Agreement pledges to limit climate heat change to less than 2

degrees Celsius) or ldquogreenrdquo bond eligible To align with current market practices and upcoming

regulations and requirements covered bond and securitisation issuers will need to disclose specific

information relative to the alignment of the portfolio to sustainable goals and the ldquogreenrdquo taxonomy

in place (see more on this in Section 2 of the report) They are subject to second party opinions and

external ratings from specialised agencies and certification bodies Therefore there is a need for in-

depth and robust data on energy performance in order to ensure that European low carbon energy

1 In France or in Ireland for example specialised agencies (ANAH and SEAI) are providing funds and grants to fuel-poor households to refurbish their homes

D32 Technical Report on Market Needs and Gaps

849

transition targets set at national and international levels relative to energy consumption and the

carbon footprint of the residential sector are met

Table 1 Reporting ldquoLayersrdquo and information sources

Reporting ldquoLayerrdquo Datainformation source Aggregation Level

Financial reporting Mortgage Lending InstitutionData repositories

Loan level

Valuation reporting ValuerReal estate data providersLender PropertyIndividualloan level

Energy performance reporting

Energy AuditorsArchitectsBuilding performance logbookGreen building label certifiers

PropertyIndividual level

Impact reporting Funding instrument issuerSecond party opinionldquoGreen bondrdquo certification agencies

Portfolio aggregated and macro level

Source EeDaPP Consortium

212 Existing reporting frameworks

For time cost and resource optimisation purposes the EeDaPP initiative must build on all existing

reporting templates and framework to gather the relevant data on Energy Efficient Mortgages

To date there are several reporting methods andor databases in place regarding the information that

the EeDaPP data portal needs to collate such as on the financial performance of loans property

valuation data the energy performance of the building stock energy efficiency upgrades and relevant

public policies regarding energy efficiency and performance in European countries

Financial performance reporting

Regarding financial reporting there are already several mandatory and regulatory reporting

frameworks that mortgage lending institutions must comply with and use to deliver data to their

regulator for transparency and prudential risk monitoring exercises These frameworks are either

public or confidential and comprise mandatory or optional reporting variables They constitute the

foundation of the EeDaPP reporting protocol and requirements regarding mortgage related and loan

level financial data

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 8: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

849

transition targets set at national and international levels relative to energy consumption and the

carbon footprint of the residential sector are met

Table 1 Reporting ldquoLayersrdquo and information sources

Reporting ldquoLayerrdquo Datainformation source Aggregation Level

Financial reporting Mortgage Lending InstitutionData repositories

Loan level

Valuation reporting ValuerReal estate data providersLender PropertyIndividualloan level

Energy performance reporting

Energy AuditorsArchitectsBuilding performance logbookGreen building label certifiers

PropertyIndividual level

Impact reporting Funding instrument issuerSecond party opinionldquoGreen bondrdquo certification agencies

Portfolio aggregated and macro level

Source EeDaPP Consortium

212 Existing reporting frameworks

For time cost and resource optimisation purposes the EeDaPP initiative must build on all existing

reporting templates and framework to gather the relevant data on Energy Efficient Mortgages

To date there are several reporting methods andor databases in place regarding the information that

the EeDaPP data portal needs to collate such as on the financial performance of loans property

valuation data the energy performance of the building stock energy efficiency upgrades and relevant

public policies regarding energy efficiency and performance in European countries

Financial performance reporting

Regarding financial reporting there are already several mandatory and regulatory reporting

frameworks that mortgage lending institutions must comply with and use to deliver data to their

regulator for transparency and prudential risk monitoring exercises These frameworks are either

public or confidential and comprise mandatory or optional reporting variables They constitute the

foundation of the EeDaPP reporting protocol and requirements regarding mortgage related and loan

level financial data

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 9: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

949

Table 2 Existing Data Templates

By fulfilling their reporting duties for their financial review either at loan level or at portfolio level

lending institutions can rely on data providers and repositories

Data repositories are directly involved in the development of a standardised data platform for Energy

Efficient Mortgages because of their extensive experience in defining reporting criteria and formats

and due to their implicit existing and often long-standing relationships with data owners (or data

providers which provide the data on behalf of the owner) in other words banks This means they are

uniquely positioned to explain the benefits to their data owners of the provision of this data and to

actively encourage data owners to provide this data Data repositories are furthermore crucial in

promoting the availability of additional robust and reliable energy efficiency data related to

residential and commercial mortgage loans and related debt instruments to their extensive network

of users eg lenders issuers investors rating agencies and central banks etc2

Credit reference agencies or Credit bureaux in some countries are companies which store

consumersrsquo utilities payment data with the purpose of credit scoring and other services (for example

fraud prevention) According to an ACCIS survey conducted in 2018 countries where energy utilities

supply payment data are Austria the Czech Republic Denmark Germany Iceland Poland Romania

Spain Switzerland and the United Kingdom Many banks are already in a business relationship with

2 Members of the EeDaPP Consortium European DataWarehouse Hypoport TXS CRIF

Current existing data-templates

Description Link

STS Residential Draft Template

Regulation shall apply to securitisations entered into on or after 1 January 2019

httpswwwesmaeuropaeupolicy-activitiessecuritisation

European Central Bank (EDW) Templates

The loan-level reporting requirements started on 3 January 2013 for RMBS and on 1 March 2013 for CMBS

httpswwwecbeuropaeupaymcollloanleveltransmissionhtmlindexenhtml

Rating Agency Templates

Quite similar and recently in most cases very similar to ECB loan level template (see above)

Not public

HTT NTT Harmonised investor report (HTT) and national investor report (for Dutch issuers available on issuer-website)

httpswwwcoveredbondlabelcomissuersharmonised-transparency-template

DSA Dutch national standard for investor reports used for securitised transactions

httpswwwdutchsecuritisationnlinvestor-reporting

AnaCredit Regulation

Dataset containing detailed information on individual bank loans in the euro area

httpswwwecbeuropaeustatsmoney_credit_bankinganacredithtmlindexenhtml

Source EeDaPP Consortium

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 10: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1049

credit reference agencies and therefore they could represent an option to access the payment data

and subsequently use payments as a proxy to calculate savings

Reporting of the property prices and valuations

Databases at property level on real estate prices and characteristics exist at national level but are

gathered and stored by different actors in different EU countries Access is made publicly available for

research and commercial purposes in some countries but not all (free access in the UK and

Netherlands for a fee in France etc)

Examples of (semi-) public registers

- Notary transaction databases (France Belgium)

- Real-estate data providers (the Netherlands)

- Public institutions (eg the Royal Mail in the United Kingdom)

Real-estate data providers are independent technology companies specialising in the statistical

analysis and valuation of real estate Such companies can perform Automated Valuation Models

(AVM) for valuation of individual homes Their services can be used by rating agencies mortgage

lenders investors intermediaries validation institutes housing corporations consumer

organisations real estate companies brokers government agencies and regulators The European

AVM Alliance (EAA) was launched as a pan-European initiative at the end of 2012 with its mission

being to promote and standardise the usage of AVMs resulting in a consistent approach to automated

valuations in Europe EAA members include Calcasa (the Netherlands) Hometrack (the United

Kingdom) Eiendomsverdi (Norway) Vaumlrderingsdata (Sweden) CRIF (Italy) Tinsa (Spain) On-Geo

(Germany and Austria)

Reporting and data tools on the energy performance of the building stock

EU Building Stock Observatory The European Commission and the Building Performance Institute

Europe (BPIE) launched its Building Stock Observatory3 in November 2016 This constitutes an existing

platform to monitor and assess the energy performance of the existing building stock across Europe

To do so it assesses improvements in the energy efficiency of buildings and the impact of these on the

actual energy consumption of the building sector overall The Observatory contains a database a data

mapper and provides factsheets tracking

- Energy efficiency levels in buildings in individual EU countries and across the EU as a whole

- Different certification schemes (EPCs and nearly Zero Energy Efficient Buildings - nZEBs4) and

how they are implemented in terms of the financing available for renovating buildings

3 httpseceuropaeuenergyeneubuildings 4 Nearly zero-energy buildings (nZEBs) have very high energy performance The low amount of energy that these buildings require comes mostly from renewable sources

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 11: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1149

Energy poverty5 levels across the EU

Over recent years the BPIE contributed to the development of several tools within the framework of

EU-funded projects and more Among these the European project ZEBRA2020 was developed to

monitor the market uptake of nZEBs across Europe and covers seventeen European countries and

almost 90 of the European building stock (EU amp EEA) These countries have different climatic

conditions polices and economic capabilities The ZEBRA2020 data tool offers a user-friendly

presentation of indicators related to the overall building stock and to nZEB activities The first part of

the tool presents an overview of the current building stock including renovation and construction

and monitors Energy Performance Certificate (EPC) activities by country (focusing on the projectrsquos

target countries) The tool endeavours to overcome data gaps and provide comprehensive datasets

which support stakeholders in their efforts to consolidate the transition to an nZEB market The

second part of the tool determines relevant indicators of nZEB buildings constructed after 2010 in

selected European countries Furthermore it aims to provide information on best cases in Europe

thereby showing most recurring technologies materials and strategies towards the nZEB target The

tool distinguishes between residential and non-residential nZEB buildings and determines some of

the most significant indicators regarding energy performance passive and active solutions and

production of renewable energy

Reporting on energy efficiency upgrades

The De-risking Energy Efficiency Platform (DEEP)6 is an open source database for the monitoring and

benchmarking of energy efficiency investments that provides detailed analysis and evidence on the

performance of energy efficiency investments in both commercial and residential sectors to support

the assessment of the related benefits and financial risks The DEEP platform offers the following

services

- Key Figures Provides a quick overview of the buildings and industry projects in the DEEP

- Data Overview Provides a more comprehensive (but still aggregated) overview of the

energy efficiency projects in the DEEP

- Chart Views Allows the user to view and filter a number of predefined charts for buildings

and industry energy efficiency projects

- Add and Manage Projects Data providers can upload and manage data on their energy

efficiency projects

- Analysis Toolbox Allows users to create charts in a dynamic and highly customisable

manner

5 Energy poverty is a multi-dimensional concept based on several prices income housing and living condition indicators More information can be found here 6 httpsdeepeefigeu

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 12: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1249

- Benchmark Projects Allows users to benchmark their own projects and portfolios of

projects against a selected group of reference projects from the DEEP database

The EEFIG DEEP platform reports key financial and energy indicators from over 5000 energy efficiency

projects in buildings including almost 2000 residential multi-family buildings financed and developed

between 2012 and 2016 The data on energy efficiency projects included in the DEEP has been

provided by public and private investment funds and financial institutions national and regional

authorities as well as energy efficiency solution providers Data is stored and managed at the

European Commission level within DG Energy

Building Typology and Energy Consumption data portal TABULA7 as part of the EU-funded research

projects (2009-2012) TABULA residential building typologies have been developed for 13 European

countries Each national typology consists of a classification scheme grouping buildings according to

their size age and further parameters and a set of exemplary buildings representing the building

types These have been published by the project partners in national Building Typology Brochures

written in their respective languages As a common element all brochures contain double page

ldquoBuilding Display Sheetsrdquo for all example buildings on which energy related features and the effects

of refurbishment measures are illustrated graphically With a view to exchanging information at

European level the TABULA WebTool provides an online calculation of the exemplary buildings from

all countries displaying their energy related features and the possible energy savings that could be

realised by implementing refurbishment measures The basis of the TABULA WebTool is a simple and

transparent reference procedure for calculating the energy need the energy use by energyware and

the energyware assessment (primary energy carbon dioxide costs) The tool also provides an

estimate of the energy savings per msup2 per year if the selected dwelling undergoes energy upgrades

(classified in three categories existing state usual refurbishment and advanced refurbishment)

Individual Building Renovation Roadmap (iBROAD) Building data passport (Logbook)8 The iBRoad

project works on developing an Individual Building Renovation Roadmap for single-family houses This

tool provides a customised renovation plan over a long-term period (10-20 years) The renovation

roadmap is combined with a building logbook a repository where all the buildingrsquos related information

can be stored and continuously updated The type of information stored in the logbook and its

functions can evolve over time and could range from energy production and consumption to

equipment maintenance as well as insurance property plans and obligations energy bills smart

meter data and links to available financing options for renovation projects (eg green loans

incentives tax credits) The logbook will collect and structure information in five modules (General

and administrative information Building construction information Building Energy Performance

Building Operation and Use and SMART information collected through information and

communication technologies (ICT) such as IoT - Internet of Things appliances)

7 httpwebtoolbuilding-typologyeupdfur 8 httpsibroad-projecteunewsthe-logbook-data-quest

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 13: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1349

Within that project several regional initiatives were developed and should enter into operation soon

such as PORTAL CASA + in Portugal and the Woning Pass in the Flanders region (Belgium)9

Netherlands EPC open database On the website httpwwwenergielabelatlasnl all the EPCrsquos in

the Netherlands are publicly available This openly accessible register displays full coverage in energy

performance labels at building unit level based on either a theoretical EPC or effectively delivered

certificate The database also displays a breakdown of the labelled energy performance for each

designated area (at district levels) as well as the average EPC rank

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot

Source Energielabelatlas

Reporting on energy efficiency policies

IEA Building Energy Efficiency Database (BEEP) - discontinued The International Energy Agency

provides a database of all registered public policies regarding energy efficiency

httpswwwieaorgbeep It provides an overview analysis of each country and a detailed list of

existing building codes labels and incentives in place The last update of this database was is 2010

Odysee-MURE Policy database MURE (Mesures dUtilisation Rationnelle de lEnergie) provides

information on energy efficiency policies and measures that have been carried out in the Member

States of the European Union The information is accessible by query in the database10

9 Prototype Online Tool available here here and here 10 httpwwwmeasures-odyssee-mureeutopics-energy-efficiency-policyasp

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 14: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1449

22 Processing

Market needs The EeDaPP initiative aims to provide relevant robust and reliable information to

assess EEM performance and risk evaluation The common database is an unprecedented collection

of reliable and harmonised energy efficiency and financial criteria which can be used to provide robust

empirical evidence of the correlation between energy performance and mortgage risk default

221 Market needs Establish a direct link between loan level credit and mortgage

risks property valuation and energy performance

The underlying business case of a future EEM product is that there is an impact of the energy

performance of a residential or a commercial building on the level of risk associated with the mortgage

financing the property and its energy efficiency Energy Efficient Mortgages are less risky to finance

and therefore less costly in capital at balance sheet level for the bank because both the property value

and the borrower risk profile are better compared to another loan all other things equal One of the

objectives of the EeDaPP initiative is to provide statistical evidence supporting this business case and

establishing a direct link between loan level credit and mortgage risks property valuation and energy

performance

The EeDaPP consortium partners are currently researching the correlation between energy efficiency

in buildings and the probability of default (PD) associated with the mortgage The research team is

currently investigating the Dutch residential market using European Data Warehouse loan data and

Dutch Energy Agency (RVO) data on energy performance using EPCs and their findings are to be

published in a later stage

222 Existing studies on the link between energy performance of buildings and

mortgage default

To date there exist very few research studies that investigate the relationship between energy

efficiency and default rates and those which do mainly focus on the United Statesrsquo (US) market The

main reason for this is that there is a significant lack of data available in Europe on both financial and

energy efficiency at loan level with a direct matching link (ie datasets that contain both energy and

financial loan level data)

Focussing on the European market a preliminary study11 published by Bank of England uses loan

performance data for residential mortgages in the entire UK (year-end 2017) matched with the energy

performance certificates (EPCs12) of the underlying properties and with information on the income of

the borrower at the time of mortgage origination EPCs in the UK rate properties from A (most

11 Available here 12 Data obtained here httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 15: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1549

efficient) to G (least efficient) and provide information on the annual energy costs of a property

Properties are categorised into three buckets lsquoHigh energy efficiencyrsquo (EPC ratings of A B or C)

lsquoMedium energy efficiencyrsquo (EPC rating of D) and lsquoLow energy efficiencyrsquo (EPC ratings of E F or G) For

example the annual energy bill of a highly energy-efficient four-bedroomed house is on average GBP

1080 lower than for a four-bedroomed house with low energy efficiency

Table 3 Annual energy costs (in GBP) by type and energy efficiency of the property

Type of property High energy efficiency

Medium energy

efficiency

Low energy

efficiency

(EPC rating A-C) (EPC rating D) (EPC rating E-G)

2-bedroomed flat pound417 pound676 pound1023

3-bedroomed house pound578 pound891 pound1340

4-bedroomed house pound695 pound1130 pound1775

Source Bank Underground

By using univariate comparisons the study shows that about 093 of residential mortgages against

energy-efficient properties are in payment arrears This share is 021 percentage points lower than

the share of mortgages against energy-inefficient properties which is 114 This difference is

statistically significant at the one percent level In Figure 3 the black dot illustrates this difference

The black bar shows the 99 confidence interval

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency)

Source Bank Underground

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 16: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1649

223 Reporting on the financial performance and related risk of energy efficiency

investment and energy upgrades

Additional information is needed to provide a sound and robust assessment of the effect of energy

efficiency on the risk profile of the borrower and the underlying asset value This information relates

to energy performance upgrades to the type of renovation that needs to be undertaken the related

cost and rate of return as well as the additional sources of finance available that would reduce the

initial investment coming from the borrower The DEEP platform introduced earlier assesses the

profitability and the risk analysis of energy efficiency investments in housing in a static yet quantitative

format

23 Disclosure

Market Needs The green bond market is growing rapidly and is key to mobilise sustainable

investments It needs clear yet rigorous criteria for eligible assets the natural counterpart of the

liabilities (bonds) for each key sector (new and existing buildings in our case) and a harmonised and

transparent reporting process aligned with existing international standards regulatory

developments and market best practices

According to the IEA World Energy Investment 2018 report close to 60 of all investment in energy

efficiency was attributed to the building sector Yet the sector accounts only for 6 in the climate-

aligned bond universe (CBI Report September 201813) The green bond market although still in its

infancy is experiencing exponential growth The Climate Bond Initiative reports USD 155 bn worth of

green bonds outstanding as of year-end 2017 (+99 year on year on the first quarter 2018)

There is room and market potential to develop standards and a reporting protocol that will facilitate

the issuance of such bonds for financial institutions willing to use a dedicated funding tool to finance

their Energy Efficient Mortgage portfolios

The benefits of an energy efficient mortgage market can also be seen on the funding side attracting

new types of investors with the issuance of a new asset class that can be classified as a green bond

Indeed the vast majority of climate-aligned bonds outstanding (USD 72 bn in Q1 2018) is allocated to

fund certified buildings (57) and energy efficiency upgrades (40) the rest (3) being allocated to

certified building materials and LED manufactures The largest issuer is the USrsquo Fannie Mae which

dominates the sector with USD 377 bn green MBS outstanding allocated to loans for energy and water

efficiency and energy efficient mortgages The next largest issuers are BerlinHyp (DE) Obvion (NL) and

the Development Bank of Japan14

The EeDaPP initiative aims to provide its stakeholders with the tools necessary to establish impact

reporting disclosure standards and guidelines for funding certifications and labels for the dedicated

ldquogreen bondrdquo issuance In this context it is worth noting that the green bond market is almost entirely

13 httpswwwclimatebondsnetfilesreportscbi_sotm_2018_final_01g-webpdf 14 More details can be found in the previous EeDaPP publication

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 17: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1749

documentation based - ie use of proceeds and that the tracking of the actual energy performance of

the underlying collateral is an additional challenge for the EeDaPP initiative to take on

231 Market needs Provide the missing link from origination to funding

Increasingly bond investors are assessing the alignment of their bond portfolio with climate goals

Over the next couple of years and driven by governmental schemes supervisors and investor

coalitions this approach is likely to become common practice and create more appetite for ESG

(Environmental Social and Governance) integration and impact reporting Having started considering

ESG factors earlier than elsewhere in Europe French Dutch and Nordic investors are comparatively

more advanced In France the integration process has been spurred by investor reporting obligations

under Article 173 of Francersquos law on energy transition for green growth In Sweden and in the

Netherlands normative-based approaches have been the precursor of more mainstream ESG

investing and engagement practices are more established In parallel a large coalition of investors

Climate Action 100+ is planning to engage with a list of 150 investee companies to request climate

target setting They primarily plan to leverage their voting rights as shareholders but most of these

investors are also investing in the bonds issued by the same companies15 This dynamic involves the

development of potentially convergent practices that might create opportunities for synergies

between target setting requests for bond issuers and impact reporting This implies two challenges

The first challenge is to provide the necessary information for a standardised ldquorobustness checkrdquo and

facilitate certification from third-party specialised institutions and investors To do that one can use

a ldquobest in classrdquo indicator using a performance distribution method (an example being from the

Climate Bond Initiative using a 15 ldquobest in classrdquo indicator) This requires specific information about

the relevant market to provide a comparative baseline (overall performance of the building stock at a

relevant perimeter)

The second challenge is to create a bridge between energy consumption data at the origination level

and the metrics used by ldquogreen bondrdquo certification bodies ie COsup2 emission reduction targets in

adequacy with macro level sustainable targets such as the Green Bond Principles National Sustainable

Strategies within the COP21 pledges etc The methodology to convert energy consumption into carbon

dioxide emissions is detailed in the IPCC Assessment Reportrsquos methodological annex16 This will require

15 https2degrees-investingorgwp-contentuploads201805Green-bonds-contribution-2Dii-May2018pdf 16 ldquoCarbon dioxide emission factors for electricity and heat have been derived as the ratio of CO2 emissions from fuel inputs of power plants relative to the electricity and heat delivered The method is equivalent to the one described above for primary factors The fuel inputs have in addition been multiplied by their CO2 emission factors of each fuel type as defined in IPCC (2006) The calculation of electricity and heat related CO2 emission factors are conducted at the country level Indirect carbon emissions related to electricity and heat consumption are then derived by simply multiplying the amount of electricity and heat consumed with the derived electricity and heat CO2 emission factors at the sectoral levelrdquo Assessment Report 5 annex ii page 1296 httpswwwipccchpdfassessment-reportar5wg3ipcc_wg3_ar5_annex-iipdf

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 18: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1849

additional information on more macroeconomic variables such as type of heating energy mix and

conversion metrics

232 Impact reporting

Market practices

There have been many market initiatives both from within and beyond the EU for ldquogreen bondrdquo

issuance backed by energy efficiency and performance financing in the building sector Most of the

current green bond market is unsecured and therefore regarded as on-balance sheet transactions

where reporting requirements are substantially lower compared to public covered

bondsecuritisation Several banks in Europe have issued ldquogreenrdquo covered bonds such as Deutsche

Hypo Berlin Hyp Muumlnchener Hyp Casa Rural de Navarra and SpareBank1 Boligkreditt The latter two

have issued covered bonds backed by residential ldquogreenrdquo properties17 All issuing banks developed

impact reporting templates post-issuance certification and assurance reports that contains specific

information on the energy performance and efficiency of their portfolio on a aggregated level (see

Table 4)

Table 4 Impact reporting template ndash example from ABN AMRO (the Netherlands)

Residential

1 Percentage of buildings with primary energy consumption below 70 kWhmsup2

2 Percentage of buildings that comply to Dutch Building Code 2012 (Bouwbesluit and NEN 7120)

3 Energy Performance Coefficient levels

4 Average Energy consumption of the buildings financed through the loans average energy consumption in the Netherlands

5 Average CO2 emissions of residential buildings (in gmsup2) financed through the loans compared to the average CO2 emissions of residential buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

Commercial

1 Percentage of residential buildings that comply with the Dutch Building Decree 2012 (Bouwbesluit 2012 Chapter 5 and NEN 7120)

2 Distribution of Energy Performance Coefficient levels and Energy Performance Certifications (ldquoEnergy labelsrdquo) among the buildings

3 Percentage of offices that are located within a maximum of 1 km from two or more modalities of public transport (newly constructed buildings)

4 Average annual energy consumption of residential buildings offices retail stores andor logistics centres compared to average energy consumption per residential building office space or retail store in the Netherlands (in kWhmsup2)

5 Average CO2 emissions of residential buildings offices retail stores andor logistics centres (in gmsup2) financed through the loans compared to the average CO2 emissions of equivalent buildings in the Netherlands (based on the carbon intensity of the Dutch energy mix)

17 Read more in the previous EeDaPP publication on market mapping

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 19: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

1949

6 Percentage of building projects with gross floor areas bigger than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo completion certificate (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

7 Percentage of building projects with gross floor areas smaller than 5000 msup2 which have at least a BREEAM ldquoVery Goodrdquo or LEED ldquoGoldrdquo indicative label (newly constructed buildings) or GPR Building score of ldquo75rdquo or RVO Green funds sustainable buildings funding scheme 2010

Residential and

commercial real estate upgrades

1 Percentage of expected and if available realised CO2 emission reduction related to the upgraderenovation of commercial andor residential real estate

2

Distribution of Energy Performance Certificate issued by RVO (Netherlands Enterprise Agency Rijksdienst voor Ondernemend Nederland) before and after the energy efficiency upgrade except in case of transformation projects For the latter only the final Energy Performance Certificate will be reported

Second Party Opinions and External reviewers Over 98 of green bond issuance in Europe benefits

from at least one external review and 93 of these reviews include a second-party opinion (SPO)

Vigeo-Eiris has the highest market share with 38 by issuance volume (followed by Cicero with 29

Sustainalytics ISS-Oekom DNV GL18) The credit rating agencies Moodyrsquos and SampP Global Ratings have

provided green bond assessmentsevaluations on deals totalling over EUR 5 bn Some deals benefit

from both ratings and reviews Although some of these organisationsrsquo broader activities are regulated

third-party verifiers of green bonds do not have to abide by any particular rules in the environmental

finance market

Energy performance indicators from kWh to CO2 emissions savings

Sustainability scores based on ldquoCO2 emission avoidancesrdquo must integrate an Emissions Intensity

Factor this is the factor used to convert emissions performance into a level of emissions intensity

This is more relevant for non-residential buildings than for residential buildings For non-residential

buildings the factor to calculate emissions intensity is either floor area (in square metres) or number

of rooms whichever is relevant for the particular building type (eg offices hotels) For residential

buildings the lower variation within one building type (eg three-bedroomed dwellings) means that

emissions performance can be expressed for the whole building removing the need to calculate

emissions intensity19 Furthermore the data used to establish the emissions performance of the

energy-efficient buildings must satisfy quality and coverage requirements such as minimum sample

size relevant scope for carbon emission calculation operational performance preferred to modelled

performance and be expressed on an annual basis in kgCO2 terms

18 Find a list of approved Verifiers under the Climate Bond Standards here httpswwwclimatebondsnetstandardsassuranceapproved-verifiers 19 CBI provides a CO2 target calculator for low carbon buildings comprised in the pool of assets for residential and commercial buildings and property upgrades httpswwwclimatebondsnetstandardbuildingsresidentialcalculatorillustration

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 20: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2049

233 Alignment with existing taxonomy international pledges and regulatory

developments

Existing ldquoGreen Taxonomyrdquo

Climate Bond Initiative (CBI) ndash Taxonomy for Buildings and ldquobest in classrdquo indicator to align the

building sector with a low carbon objective the CBI developed its Low Carbon Building Criteria (LCB)

establishing the green credentials of low carbon features of bonds loans and mortgages in the sector

and alignment with emissions standards and objectives The CBI states that for ldquogreen bondsrdquo backed

by energy efficient non-residential buildings the energy efficiency performance requirement is an

emissions targets derived from an ldquoemissions performance trajectoryrdquo that starts with the emissions

performance of the top 15 most energy-efficient buildings (of its type eg offices) in its geographic

location and declines to zero carbon emissions in 2050 For residential buildings the energy efficiency

performance requirement is a CBI-approved proxy derived either through benchmarking against the

local market emissions performance (ie emissions performance trajectory) or through analysis of a

particular ratinglabel as a proportion of total ratingslabels awarded under a scheme

Table 5 CBI Location Specific Criteria for Residential Buildings on European Markets

Country State StateSub Category

Proxy Brochure

Belgium Country

wide single amp

multifamily

Energy Performance Certificate (EPC) rating of A OR

Flemish building code after 2014

England Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

Germany Country

wide single amp

multifamily Energieausweis (EPC) rating of A OR B PDF

Netherlands Country

wide single amp

multifamily

Post 2012 Dutch Building Decree 2012

PDF

amp

Netherland Normalisation Institute (NEN) 7120 Standard

----------

Pre-2012 Energy Performance Certificate (EPC) Rating A

Norway Country

wide single amp

multifamily House or Apartment Energimerking (EPC) rating

of A B OR C

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 21: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2149

House TEK (Building Code) 2007

Apartment TEK (Building Code) 2010

-----------

8 improvement from Energy Star Certified Homes Version 31 Revision 08

OR

9 improvement from Energy Star Certified Homes Version 31 Revision 09

Wales Country

wide single amp

multifamily Environmental Impact (EI) rating of A OR B as part of the Energy Performance Certificate programme

PDF

International International

LEED Gold OR Platinum

WITH

ASHREA 901

International International EDGE certified

International International Net Zero and Near Zero Energy Buildings (NZEB)

International International Living Building Challenge Certified

International International PassiveHaus Standard

European Commission Action Plan on Sustainable Finance (Taxonomy Benchmark Disclosures)

The European Commissionrsquos (EC) Action Plan on Sustainable Finance The European Commissionrsquos

Action Plan on Sustainable Finance is part of the Capital Markets Union (CMU) initiativersquos efforts to

connect finance with the specific needs of the European economy to the benefit of the planet and

society As such it is also one of the key steps towards implementing the COP21 Paris

Agreement 20 and the European Unions agenda for sustainable development 21 Based on the

recommendations set out by the High-Level Expert Group on Sustainable Finance (HLEG)22 in March

2018 the European Commission published a roadmap to boost the role of finance in achieving a well-

performing economy that also delivers on environmental and social goals

In May 2018 the EC presented a package of measures as a follow-up to its Action Plan23 The package

includes three proposals aimed at

20 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en 21httpseceuropaeueuropeaidpolicieseuropean-development-policy2030-agenda-sustainable-development_en 22 httpseceuropaeuinfopublications180131-sustainable-finance-report_en 23 httpseceuropaeuinfopublications180524-proposal-sustainable-finance_en

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 22: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2249

bull Establishing a unified EU classification system of sustainable economic activities (taxonomy)

bull Improving disclosure requirements on how institutional investors integrate environmental

social and governance (ESG) factors in their risk processes

bull Creating a new category of benchmarks which will help investors compare the carbon

footprint of their investments

Taxonomy The Regulation sets out six environmental objectives

1 Climate change mitigation

2 Climate change adaptation

3 Sustainable use and protection of water and marine resources

4 Transition to a circular economy waste prevention and recycling

5 Pollution prevention and control

6 Protection of healthy ecosystems

For an activity to be environmentally-sustainable it must contribute substantially to one or more of

these objectives not significantly harm any of them and comply with minimum safeguards and

technical screening criteria which will be set out in a Delegated Act

Carbon Benchmarks The EC proposes to amend Benchmarks Regulation to include references to

ldquoLow-carbon benchmarksrdquo (ie one which has less carbon emissions compared to a standard capital-

weighted benchmark) and ldquopositive carbon impact benchmarksrdquo (those for which the underlying

assets are selected on the basis that their carbon emissions savings exceed the assetsrsquo carbon

footprints) Again this Regulation will be underpinned by Delegated Acts

Disclosures on sustainability risks and on sustainable investments The Taxonomy Regulation is

accompanied by four further Regulations one of which covers disclosures by the financial market

participants The articles largely refer to financial products which may be difficult to implement in the

context of portfolio management (a service) The disclosures cover the integration of sustainability

risks including how the firmrsquos remuneration policy aligns with the sustainable investment target of

products and cover both pre-contractual and periodic disclosures

Sustainable investments include those with an environmental (as defined by the taxonomy mentioned

above) social or good governance objective The three-line definition of social objective is not the

same as and does not refer to the definition used in the EuSEF Regulation This Disclosure Regulation

is to be underpinned by various Delegated Acts and Regulatory Technical Standards The legislative

proposal includes a definition of sustainable investments and sustainability risks to ensure a coherent

application of this Regulation which is clearly and consistently applied by financial market participants

it is necessary to lay down a harmonised definition of ldquosustainable investmentsrdquo and sustainability

risks

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 23: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2349

Other relevant bodies

Principles for Responsible Investments24 The Principles were launched in April 2006 at the New York

Stock Exchange developed after a call from the United Nations UN- PRI is a 20-person investor group

drawn from institutions in 12 countries was supported by a 70-person group of experts from the

investment industry intergovernmental organisations and civil society Since then the number of

signatories has grown from 100 to over 1800 The six Principles for Responsible Investment are a

voluntary and aspirational set of investment principles that offer a menu of possible actions for

incorporating ESG issues into investment practice The Principles were developed by investors for

investors In implementing them signatories contribute to developing a more sustainable global

financial system

United Nations Conferences of Parties (COP) The international agreements reached during the UN

various COPs are clearly defined nationally and regionally in the Sustainable Development Goals

(SDGs) 25 All the countries of the world have agreed on a sustainability agenda covering three broad

areas ndash economic social and environmental development ndash and comprising 17 global goals further

developed into 169 specific targets to be reached by 2030

G20 and FSB Task Force on Climate-Related Disclosures in 2015 G20 Finance Ministers and Central

Bank Governors asked the Financial Stability Board (FSB) to review how the financial sector can take

account of climate-related issues The FSB established the Task Force on Climate-Related Financial

Disclosures (TCFD)26 to develop recommendations for more effective climate-related disclosures that

could promote more informed investment credit and insurance underwriting decisions and in turn

would enable stakeholders to understand better the concentrations of carbon-related assets in the

financial sector and the financial systems exposures to climate-related risks

ICMA Green Bond Principles 27 Green Bonds enable capital-raising and investment for new and

existing projects with environmental benefits The Green Bond Principles (GBP) updated as of June

2018 are voluntary process guidelines that recommend transparency and disclosure and promote

integrity in the development of the Green Bond market by clarifying the approach for issuance of a

Green Bond The GBP are intended for broad use by the market they provide issuers with guidance

on the key components involved in launching a credible Green Bond they aid investors by ensuring

availability of information necessary to evaluate the environmental impact of their Green Bond

investments and they assist underwriters by moving the market towards standard disclosures which

will facilitate transactions

24 httpswwwunpriorg 25 httpswwwunpriorgsdgsthe-sdg-investment-case303article 26 Comprised 31 international members including providers of capital insurers large non-financial companies accounting and consulting firms and credit rating agencies 27 httpswwwicmagrouporggreen-social-and-sustainability-bondsgreen-bond-principles-gbp

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 24: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2449

The Green Loan Principles launched on 21 March 2018 by the Europe-based Loan Market Association

(LMA) and Asia Pacific Loan Market Association (APLMA) the initiative aims to facilitate a more

targeted green financing approach across sectors This in turn could support further green bond

issuance from banks

The Central Banks and Supervisors Network for Greening the Financial System (NGFS)28 Launched

in December 2017 at the Paris Climate week NGFS is a group of Central Banks and Supervisors willing

on a voluntary basis to exchange experiences share best practices contribute to the development of

environment and climate risk management in the financial sector and to mobilize mainstream finance

to support the transition toward a sustainable economy Its purpose is to define and promote best

practices to be implemented within and outside of the Membership of the NGFS and to conduct or

commission analytical work on green finance The NGFSrsquos research agenda will deal with supervisory

issues at micro and macro level and an investigation on the role of central banks to scale up green

finance More particularly the first work stream is considering the extent to which a financial risk

differential exists between lsquogreenrsquo and lsquobrownrsquo assets taking stock of research projects from

university and experts to assess whether greenbrown loansbonds have lowerhigher default

probabilities than non-greenbrown loans bonds as a basis for exploring motives underpinning a risk

differential between such investment that are consistent with financial mandate This work is

expected to feed into the first NGFS progress report to be issued by April 2019

28ttpswwwbanque-francefrenfinancial-stabilityinternational-rolenetwork-greening-financial-systemabout-us

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 25: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2549

3 ASSESS MARKET GAPS

This section of the report seeks to list identified market gaps bottlenecks and in some cases potential

solutions for the practical implementation of an EEM reporting protocol and common data portal

These gaps relate first and foremost to data availability quality harmonisation at EU level and

technical issues such as privacy non-bank nature and dynamic data monitoring

31 Data Availability

311 Overall assessment

In the table of Annex 53 there is an assessment made by the EeDaPP data services and repositories

of data availability source quality and format for all the possible variables that can feed the data

portal

312 Energy performance data availability

Following the Energy Efficiency and the Energy Performance of Buildings Directives the deliverance

of EPCs is mandatory for every property that is either rented or sold in all EU Member States that

implemented the measure into national legislation between 2009 and 2013

Despite being recognised as the most reliable tool for European assessment of the energy

performance of the building stock there remain major gaps with regards to the availability of the

information on EPC on several levels coverage scope and accessibility as shown in Figure 4 Of the

total building stock only a small share of energy efficient buildings has EPC labels (because for

example EPC was not available in a digital format or not used as certification for all energy upgrades

which is often the case for small renovations financed by own funds or short-term consumer loans)

From that share of the building stock that have EPC data available the access to the EPC database is

not publicly accessible in every EU Member State

Figure 4 Venn diagram of the building energy performance data availability

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 26: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2649

EPC database register and access

In several EU Member States and EEA members like Norway access to EPC registers is public and free

of charge provided privacy protection measures are met In some countries EPC registers are

accessible via an online platform In other countries to date EPC registers do not exist or access to

them is restricted to some organisations such as in Germany (no public access) France or Spain

Total Building Stock

Energy Performant

Building stock

EPC labelled Building stock

EPC labelled

and accessible building

stock

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 27: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2749

Figure 5 Mapping of the access to EPC databases

Some EPC registers are accessible via an online platform but EPC digital registration is not in place in

every country Countries in Scandinavia (Norway Denmark Sweden) the Netherlands the United

Kingdom France Portugal Greece and Estonia have automatic registration of EPC data Table 7

presents a list of the different EPC registers in EU (source Building Energy Performance EU

Observatory)

Table 6 National EPC Registers

Country Responsible organisation

Link

Denmark Energy performance certificates scheme database

httpsboligejerdk

France ADEME - Observatoire DPE

httpwwwobservatoire-dpefrindexphp

Italy Regional EPC registers

CTI-Comitato termotecnico italiano httpswwwcti2000it

Lithuania SPSC database httpswwwspscltcmsindexphpoption=com_contentampview=articleampid=57ampItemid=331amplang=en

Netherlands AgentschapNL

Norway EnergiMerking httpwwwenergimerkingnonoEnergimerking-Bygg

Portugal Portuguese Energy Agency (ADENE) SCE -

httpswwwsceptpesquisa-certificados

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 28: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2849

energy certification system

Romania EPC Database

Slovakia INFOREG

United Kingdom

DCLC httpswwwgovukbuy-sell-your-homeenergy-performance-certificates

Hungary EPITES httpswwwe-epiteshuentan Ireland SEAI httpsndberseaiie Spain Regional EPC

register

Source BPIE

EPC data coverage

Given the short history of mandatory implementation of EPCs in the residential market the overall

coverage of EPCs with respect to the national housing stock is still limited This is reinforced by the

fact that EPC deliverance obligations do not apply to the stock that has not been rented or sold during

the last decade To date the Netherlands the United Kingdom and the Scandinavian countries display

the highest EPC coverage with respectively 32 (UK and Netherlands in 2013) 17 (Norway) 13

(Denmark) 11 (Sweden)

Table 7 Total stock of residential buildings registered in EPC database

Unit Source 2010 2011 2012 2013 2014

Netherlands calculation 236 289 307 321 na

UK calculation 64 119 172 246 325

Norway calculation 22 58 99 138 173

Denmark calculation 67 89 106 127 130

Sweden calculation 59 73 84 97 108

Italy calculation 16 34 55 76 95

Portugal calculation 28 47 61 73 na

France calculation na na na 44 44

Spain calculation na na na 33 40

Slovakia calculation 04 08 13 18 24

Lithuania calculation 01 02 04 13 22

Romania calculation 00 02 04 04 na

Germany calculation na na na na 077

Source Enerdata- 29

29 httpwwwzebra-monitoringenerdataeuoverall-building-activitiesshare-of-new-dwellings-in-residential-stockhtml-of-total-residential-stock-with-epchtml

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 29: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

2949

313 Link between energy performance property valuation and mortgage data

Property valuation is a pillar of the EEM framework and key indicators for its assessment must figure

in the common data portal to correctly measure the effect of energy efficient homes on property value

and derived indicators such as the Loan to Value Valuation reports or assessments must take into

account all factors considered salient to the value of the relevant property analyse other market

transactions from within the locality and arrive at a judgement of market value or mortgage lending

value which is then used by the lending institution at mortgage origination and for prudential

compliance purposes (ie in determining the Loan to Value ratio and the Loss Given Default amount)

At present there is no specific mandatory professional reporting requirement in relation to energy

efficiency except if it is deemed to be a ldquomaterial riskrdquo to the likely maintenance of the income In

other words due to the conservative role of property valuers there is a negative bias on the energy

performance factors taken into account in the property valuation report

In terms of professional body requirements placed on the valuer there are two leading professional

bodies in Europe the first is RICS (Royal Institution of Chartered Surveyors) the second is TEGoVA

the European Group of Valuers Associations30 RICSrsquo best practice advice to valuers the so-called ldquoRed

Bookrdquo sets out the main items that should be inspected and the due diligence process that valuers

should follow Under this valuers are ldquostrongly advisedrdquo to

ldquohellipcollect and record appropriate and sufficient sustainability data as and when it becomes

available for future comparability even if it does not currently impact on value This could be

particularly beneficial where the valuer is retained to provide regular reports to a clientrdquo

The intention behind this advice is that as more data becomes available and is stored within

databases of comparable evidence data on matters affecting sustainability and notably energy

efficiency will be routinely collected by valuers during their due diligence process Therefore this data

become available for use within the analysis phase of the valuation

30 httpswwwtegovaorgdatabina5738793c0c61b_EVS_2016pdf

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 30: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3049

32 Data Consolidation Comparability and Harmonisation Issues

321 Data consolidation and common key identifier

As shown in Figure 6 the challenge of a common data portal for Energy Efficient Mortgages is to

reunite data fields and loan level information on several key yet different areas such as loan

performance valuation assessment energy performance and efficiency features and impact

reporting requirements Each database can be elaborated and operated by a different actor using

different key identifiers referring either to the borrower (individual and loan ID) the property

(cadastral of geographical data) or the issuerportfolio or cover pool level on the funding side for

impact reporting A common key identifier to connect all data source is needed

322 Harmonisation of the different methodologies and definitions

The EeDaPP protocol and final data portal must ensure that every variable reported is controlled for its potentially different nature format scope and calculation method Harmonisation needs to be undertaken for each type of criteria relative to energy performance valuation and financial performance

Definitions

In defining what is an energy performant building and setting the eligibility criteria for complying to

the EEM perimeter the choice was made to rely on European level tools and indicators enforced by

European legislation Energy Performance Certificates (EPCs) for existing rented or sold properties and

Loan Database

Valuation Database

Energy Performance Database

Impact Reporting Template

Energy Efficient Mortgages Common

Data Portal

Figure 6 Schematic view of the different sources within the EEM Database

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 31: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3149

nZEB certifications for new builds Both concepts have criteria enforced by the Energy Efficiency

Directive (EED) and the Energy Performance in Buildings Directive (EPBD) The challenge here is that

the directives only define the concepts of the aforementioned indicators and give considerable

latitude to Member States to refine them Therefore the nZEB and EPC scopes definitions and

methodologies can differ across the EU

Nearly Zero Energy Building (nZEB) According to the EPBD [a nearly zero energy building is a]

ldquohellipbuilding that has a very high energy performancehellip The nearly zero or very low amount of energy

required should to a very significant extent be covered by energy from renewable sources including

renewable energy produced on-site or nearbyrdquo As mentioned above the nZEB concept is very flexible

with no single harmonised nZEB definition across the EU The EPBD neither prescribes a common

approach to implement nearly Zero-Energy Buildings nor describes the assessment categories in

detail Thus Member States and in some cases regions within them have established different

parameters both in terms of quantity and quality in their nZEB definitions

To date out of the 29 countries (EU28 and Norway) 16 jurisdictions have adopted nZEB definitions

for new buildings and 12 are developing definitions In most countries the nZEB definitions refer to

maximum primary energy as one of the main indicators In a few cases (eg the Netherlands and the

Belgian Region of Flanders) the primary energy use of the building is assessed through a non-

dimensional coefficient comparing the buildingsrsquo primary energy use with a ldquoreferencerdquo building with

similar characteristics (eg building geometry) In several countries (eg the United Kingdom Norway

and Spain) carbon emissions are used as the main indicator while in others (eg in Austria and

Romania) carbon emissions are used as a complementary indicator to primary energy use For

residential buildings most jurisdictions aim to have a primary energy use not higher than 50

kWhmsup2year To control for different property types and climate different requirements are

established for single family houses as well as apartment buildings and higher values are established

for regions with a colder climate (eg in France and Romania)

Format and structure

First data needs to be available in an electronic format and stored in a database which can be easily

accessed Today a significant amount of data is already available but only in paperpdf format As

such it can be problematic to accessanalyse and entails digitalisation difficulties because some key

data points can be stored in different formats (eg EPCs have four values - a letter and a number in

kWhmsup2 per year for energy consumption and a letter and a number in kg CO₂msup2 per year for carbon

emissions) Indeed EPCs enforced by the EPBD can take several forms depending on whether it is

expressed as a label a final energy consumption quantitative estimation a carbon emission estimate

or a scoreindex that measures the buildingrsquos overall primary energy performance as a ratio to a

reference value) The lower the scoreindex the more energy-efficient the building is

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 32: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3249

323 Calculation methods and comparability issues

Definitions of data points can be different even within one country (ie at regional level like in

Belgium Italy or Spain) making analyses and comparisons difficult as shown in Table 9

EPC calculation methods

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 33: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

Table 8 EPC Conversion table EPC class

France Austria Sweden Germany Portugal Belgium Czech Rep

Romania Norway UK Netherlands Denmark

Label A lt50 lt80 lt 50 lt50 le25 45 lt43 lt 150 9033 32 A++ (EI lt= 05) lt 20

Label B 51-90 81-120 100 51-100 26-50 95 43-82 150 - 259 12567 33-65 A+ (EI 051 lt 07) lt 300 + 1000 A

Label C 91-150 121-160 150 101-150 51-75 150 83-120 259 - 389 16167 66-100 A (EI 071 lt 105) lt 525 + 1650 A

Label D 151-230 161-280 200 151-250 76-100 210 121-162 389 - 557 20233 101-135 B (EI 106 lt 13) lt 700 + 2200 A

Label E 231-330 281-340 300 251-350 101-150 275 163-205 557 - 785 24367 163-170 C (EI 131 lt 16) lt 110 + 3200 A

Label F 331-450 341-400 400 351-400 151-200 345 206-245 785 - 1150 30333 171-200 D (EI 161 lt 2) lt 150 + 4200 A

Label G gt451 gt400 gt400 gt401 201-250 gt345 gt245 gt1150 lt303 gt200 E (EI 201 lt 24) lt 190 + 5200 A

Figure 7 EPC energy consumption levels according to EU selected countries

Sources BPIE ZEBRA 2020

32 25 43 45 5080

50 5090

65 5082 95 90

120100 100

12567100

75120

150 150 160 150 150 16167135

100

162210

230

280

200

25020233

170150

205

275

330 340300

350

24367200 200

245

345

450

400 400 400

30333

UK Portugal Czech Rep Belgium France Austria Sweden Germany Norway

Bu

ildin

gs

ener

gy c

on

sum

pti

on

(k

Wh

msup2

year

Label A Label B Label C Label D Label E Label F

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 34: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3449

Valuation assessment

As mentioned above property valuation is a pillar of the EEM framework and key indicators for its

assessment must figure in the common data portal to correctly measure the effect of energy efficient

homes on property value and derived indicators such as the Loan to Value There are two main

valuation methods used in line with current EU regulations (Capital Requirements Regulation and the

Mortgage Credit Directive) The Mortgage Lending Value and the Market Value methods The EeDaPP

data portal as a first objective and as previously developed needs to gather as many data fields and

information available as possible In a second step there is a need for harmonisation of definitions

calculation methods and coverage of property valuation assessments across European countries and

the EeDaPP initiative will need to process country-level valuation estimations and assessments

Automated Valuation Models (AVMs) are statistical valuation solutions that provide an estimate of

value of specified properties using modelling techniques based on a comparison approach The use of

AVMs has increased considerably in Europe over recent years and their features (coverage

automation and digital format) can play an important role in the development of Energy Efficient

Mortgages in terms of their reporting and the establishment of a data portal especially for portfolio

analysis In the EeDaPP context AVMrsquos must integrate relevant characteristics regarding energy

performance such as the EeMAP valuation Energy Efficiency Checklist31 In doing so they can be a

potential solution to provide granular property valuation assessments with a direct link to energy

performance features The support and the implication of European level actors such as the European

AVM alliance can play a key role here

The following table details the practices and calculation methods used for property valuation and the

use of AVMs for selected EU countries

Table 9 Selected EU Countries Property Valuation Standards and Calculation Methods

Valuation Method Valuation Assessment Use of AVMs

Belgium Market Value based on notarial information and internal minimum standards

Internal independent review by the lender (valuation report asked for property gteuro2 bn)

Yes

Denmark Market Value (defined by the Danish Valuation Order)

Internal amp external comparison method for residential properties and Investment Value for Commercial properties

Yes for portfolio analysis and upon the approval of the Danish FSA for origination

Germany Mortgage Lending value and Market Value as both laid

Methodology provided by the Real-Estate Valuation Guidelines

Yes for Portfolio analysis and from BaFin best practices may be used at

31 Available here httpeemapenergyefficientmortgageseuwp-contentuploads201811Valuation-and-Energy-Efficiency-Checklistpdf

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 35: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3549

down by the Pfandbrief Act

origination if they comply with all requirements for valuation reports

Italy Market Value Guidelines laid down by Italian Banking Association (ABI)

Not permitted for individual valuations

Spain Mortgage Lending Value as basis Market Value and Replacement Value

List a ldquoreliable standardsrdquo set out in national legislation (Norma ECO 8052003)

Not allowed at origination allowed for portfolio analysis and asset quality review for specific cases

United Kingdom

Market Value (with special assumptions for commercial properties)

Rules and guidelines laid down by external professional association (RICS) Valuation report upon onsite inspections

Quality control tool at origination and portfolio monitoring

Source EMF-ECBC Study on the Valuation of Property for Lending Purposes (2017) 32

33 Data minimum quality and representativeness

At the time of writing the EeDaPP Consortium is experiencing difficulties in finding tangible and robust

statistical evidence for two reasons The first is that the implementation of Energy Efficient Mortgages

is too recent and insufficiently harmonised to offer a strong set of exploitable data Hence the main

determinants of such events are difficult to model and lack robustness The second is that for the past

few years the existing conventional mortgages in Europe exhibit very low default rates

331 Sampling problem coverage and data history

Data on EPCs covers on average less than 10 of the building stock As shown in Figure 8 from 2014

data there is a lack of observations at each tail of the EPC distribution and some heterogeneity given

the country Registered EPCs in Europe in 2014 do not show any ldquoGrdquo labels and very few ldquoArdquo labels

although there is an upward trend to that latter issue ldquoArdquo and ldquoBrdquo labels account for less than 20 in

all selected countries but Slovakia and Romania (where EPC coverage doesnrsquot pass 2 of the total

building stock)

32 Available here httpshypoorgappuploadssites3201709EMF-ECBC-Study-2017-FINALpdf

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 36: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3649

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014

Sources Zebra

332 Lack of default data for the relevant period

The period for which we wish to investigate the impact of energy efficiency features in housing on the

probability of default of the borrower is peculiar from a macroeconomic cycle point of view Indeed

energy efficiency and performance labels in Europe appeared mostly after 2009 in a post-global and

banking crisis era in the EU Hence for the period 2010-2018 relatively speaking very few occurrences

of default in the residential housing market were witnessed in Europe

34 Data processing monitoring and usage

341 Privacy and contractual considerations

The main EU law measures applicable to the collection of energy data are the General Data Protection

Regulation (GDPR) and the (future) recast of the Electricity Directive

GDPR analysis

The objective of EEM banks and their partners is to handle individual loan-level data with the aim of

monitoring the correlation between energy efficiency and other risk metrics such as probability of

default and arrears This activity falls within the scope of ldquodata processingrdquo under the GDPR Metering

and consumption data are included in the definition of ldquopersonal datardquo in the GDPR because they are

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 37: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3749

inextricably linked to a natural person via a unique identifier Therefore all activities under the EEM

umbrella need to be GDPR-compliant

The first step towards GDPR compliance is identifying the data controller(s) processors and

recipients The responsibility of correct data management will lie with the organisation(s) identified

as the controller while processors and recipients will act on behalf of the controller and will have to

be disclosed to the subject The controller determines the purposes and means of the data

processing In the case of EEMs the purpose is informing the bankrsquos risk management processes with

a view to granting (favourable) credit and therefore the bank shall be the controller

Secondly it will be necessary to identify the most appropriate legal basis Three different GDPR legal

bases may apply for the purpose of EEMs consent contractual performance and legitimate interest

Consent would likely be the most solid however it may prove difficult with ldquoprivacy-consciousrdquo

consumers especially in certain markets (eg Germany) However respecting the purpose-limitation

and minimisation principles origination of a EEM may be made conditional on giving consent to the

collection of energy performance data which would be considered as ldquonecessary to provide the

servicerdquo A consent form would have to be properly designed in accordance with the GDPR (ie be

intelligible and easily accessible in clear and plain language) and include consent to being subject to

prospective automated decisions Furthermore the data subject must be allowed to withdraw

consent and terminate processing This may prove challenging since ldquoterminating the servicerdquo would

mean the loan has to be paid in full when withdrawing consent Importantly even if contractual

performance were chosen as the legal basis the obligation to communicate to the subject all the

information relevant to the processing would still apply as part of the right to transparency

The data processing should be designed in accordance with the GDPR principles in particular purpose

limitation and data minimisation This means that data collected should be used only for the declared

purpose and only data necessary for that purpose should be collected Other relevant principles

include time limitation (data stored only for as long as it is needed) integrity and confidentiality

Finally the privacy by design principle would potentially imply a certain degree of ldquomodularityrdquo in the

collection of data but this is more an orientation principle than a requirement

The controller must also ensure that the data subject is granted the GDPR rights which include

Transparency all relevant information with regard to the processing must be communicated

including potential transfer of data

Access to hisher data and right to portability on request the controller must provide the

data in structured machine-readable format and allow the transmission to another controller

This could actually constitute an advantage in the context of the EeDaPP because it would

allow customers to request their energy suppliers to provide them (or banks directly) with

their data

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 38: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3849

Right to have hisher data erased (ldquoright to be forgottenrdquo) this poses the problem that

ldquoterminating the servicerdquo upon withdrawal of consent is not simple in the case of a loan

It is worth noting that data processed for statistical purposes at an aggregate level would be excluded

from the scope of the GDPR therefore analysis aimed at proving the correlation between energy

efficiency and financial performance would be lawful even without consent if the information is not

attributable to a specific natural person

EEM related activities will unlikely match the criteria for the requirement to appoint a Data Protection

Officer and carry out a Data Protection Impact Assessment However such a measure would greatly

simplify compliance Banks may already have within their organisational structure a Data Protection

Officer therefore costs would not be impacted

Electricity directive

As part of the Clean Energy Package in 2016 the European Commission proposed a recast of the

Electricity Directive (Directive on common rules for the internal market in electricity) The Directive is

currently at the Trilogue phase within the European Institutions therefore the detailed final wording

is still not known Member States will have 12 months to transpose the provisions after the Directiversquos

adoption

The Directive foresees specific provisions (Art23) for the management of energy data In particular it

is stated that Member Statesrsquo authorities will have to list entities that can access and exchange energy

metering and consumption data (the European Parliament proposes to explicitly include data required

for automated energy efficiency programmes and energy management services) ldquowith explicit

consent and in accordance with GDPRrdquo Eligible parties shall include at least ldquocustomers suppliers

transmission and distribution system operators aggregators energy service companies and other

parties which provide energy or other services to customersrdquo Eligible parties should be provided with

the data on a non-discriminatory manner and no additional charges may be applied to the customer

for the collection of data

342 Practical Issues Dynamic monitoring

Regulatory revaluation requirements

In December 2016 the European Banking Authority (EBA) published a set of recommendations on

monitoring and revaluation requirements of LTV measurements for an up-coming EU framework for

covered bonds

bull Where cover asset eligibility is based on loan-to-market value limits the value of the property

securing a particular loanmdashand the corresponding regulatory LTV limit determining the

contribution of that loan to the coverage requirementmdashare monitored and updated (eg at

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 39: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

3949

least via an indexation or other statistical method) at least on a yearly basis for both residential

and commercial properties and more frequently where either the management of the

covered bond programme or the cover pool monitor or the competent authority deem

appropriate

bull Where cover asset eligibility is based on loan-to-mortgage lending value limits the general

level of market prices for the relevant real estate market is to be monitored and the basis of

valuation of property collateralising individual loans is to be reviewed (as a minimum) when a

general reduction in market prices suggests an impairment of the mortgage lending value or

if the affected loan becomes delinquent

bull Revaluation of the properties securing the loans should be based on transparent valuation

rules and be carried out by an agent who is independent from the credit granting process As

a minimum the valuation process should be compatible with either the conditions laid down

in the first or the second subparagraph of Article 229(1) of the CRR

bull When deciding upon the frequency of revaluation qualitative aspects such as robustness of

the revaluation process should also be taken into account

Energy savings dynamic monitoring

Ensuring the compliance of energy efficiency funding to a minimum performance threshold can imply

the monitoring of energy savings Those requirements can be met by the deliverance of an Energy

Performance Certificate after the renovations that shows the improvements in a buildings

performance and energy consumption compared to its precedent state It can also be done via the

monitoring of empirical energy consumption and expenditures data from households living in that

building Energy efficiency gains are monitored and verified with the dynamic monitoring and

assessment of quantitative data such as daily weekly monthly or even annually energy consumption

and expenditures The assessment measurement and monitoring of such data is not within the

competence or the core expertise of banks and such schemes suggest the implication of a third-party

partner such as the energy expert of Energy Services Companies (ESCOs) for example under the

Energy Savings Certificates (or ldquoWhite Certificatesrdquo) schemes Such funding scheme based on empirical

energy consumption measurements that for example make the use of smart meters and appliances

connected to the Internet of Things (IOT) to procure real time energy consumption and gains granular

data The challenge for the EeDaPP initiative is to make room for such innovative solutions and

integrate into the reporting protocol yet another possible information source data type and provider

(energy providers servicers distributershellip)

343 Evolving sustainability targets

The Sustainable Development Goals and national pledges regarding the fight against climate change

following the Paris Agreement on Climate are deemed to be re-evaluated to allow for a smooth

transition towards a post-carbon economy

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 40: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

4049

The European Commission sets out intermediate targets overall and within key sectors such as the

building sector The ldquoClean Energy for all Europeans Packagerdquo also called the ldquoWinter Packagerdquo

published in November 2016 sets the EU 2030 targets aimed at enabling the EU to deliver on its Paris

Agreement commitments 33 The ldquoWinter Packagerdquo includes an overall (cross-sectoral) energy

efficiency target for the EU for 2030 of 325 with an upwards revision clause by 2023 Against this

background ldquoEU measures therefore focus on sectors where the potential for savings is greatest such

as buildings The EU has set itself a 20 energy savings target by 2020 (when compared to the

projected use of energy in 2020)rdquo The ldquoWinter Packagerdquo triggers the revisions of both the Energy

Efficiency Directive and the Energy Performance of Buildings Directive The EPBD ldquoCreates a clear path

towards a low and zero-emission building stock in the EU by 2050 underpinned by national roadmaps

to decarbonise buildingsrdquo The intermediate target sets the objective that all new buildings starting in

2021 must be nZEBS (nearly-zero energy buildings)

As mentioned by exiting taxonomy and requirements for the issuance of long-term ldquogreen bondsrdquo

energy efficiency policy has to fulfil dynamic and long-term sustainable targets In its ldquoGreen Bondrdquo

certification methodology the Climate Bond Initiative uses a tool and methodology described in Figure

9 to select eligible assets in a green bond portfolio with a medium to long-term maturity

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector

Source Climate Bond Initiative

33 httpseceuropaeuclimapoliciesinternationalnegotiationsparis_en

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 41: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

4149

To boost a nascent market especially regarding portfolios backed with assets comprising existing

buildings with energy upgrades a grandfathering clause can be a solution to guarantee the eligibility

of assets while regulation updates are setting stricter criteria and targets valid for new issuances A

grandfathering clause is an exemption that allows persons or entities to continue with activities or

operations that were approved before the implementation of new rules regulations or laws Generally

speaking a grandfathering clause only exempts people or entities engaged in specified activities prior

to new rules being put in place while all other parties must abide by the new rules

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 42: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

4249

4 Conclusions and next steps

Notwithstanding substantial market heterogeneity the energy efficient market needs standards and

guidelines to provide European stakeholders the possibility to build a profitable business model with

minimised transaction and implementation costs These stakeholders need access to a pooled

harmonised and robust dataset to provide the statistical evidence of the lower risk profile of an EEM

product Furthermore the EeDaPP platform can serve as a reporting framework for the diversification

of institutional funding whilst offering a comprehensive data set towards research and policy analysis

The EeDaPP initiative aims to establish a reporting protocol and design and structure a common data

platform that is secured and relevant to the different stakeholders and fulfil its objectives to

1 Gather and collect data of different natures (energy financial loan-level aggregated) coming from

different sources (borrower bank energy provider valuer energy expert) and from different

jurisdictions (institutions and countries)

2 Provide a robust and reliable database for research and data analyses purposes that can deliver in

due course robust statistical evidence of the positive impact of energy performance and efficiency

on risk (via its main financial indicators Probability of Default Loan to Value and Loss Given

Default)

3 Provide reporting standards on funding in line with existing and forthcoming reporting initiatives

(Securitisation Regulation Covered Bond Directive COP21 etc)

The EeDaPP data framework reporting protocol will need to overcome several challenges

1 Data availability

2 Data collection and consolidation

3 Data harmonisation

4 Energy and financial performance assessment and monitoring

5 Disclosure levels and needs

The reporting framework must be built according to data sensitivity and specificity of the reporting

ldquolayersrdquo and sources (households banks valuers energy experts and public institutions) and pay close

attention to the different levels of complexity and granularity This is especially so given that the data

includes significant strategic elements that can lead to privacy issues such as bank risk profiles and

capital costs real consumer consumption data retrofit profitability and building performance

monitoring and insurance A fair share of this information is owned collected and monitored by non-

bank stakeholders the common data portal and reporting protocol will have to include inputs and

expertise from third-parties partners such as energy service companies public institutions (national

energy agencies) or real-estate data providers Where possible in the future the EeDaPP initiative

could make use of system modelling techniques such as AVMs and theoretical EPCs and related

technologies to infer preliminary AVMrsquos and Energy Performance assessments

Finally for funding purposes the protocol and requirements must be aligned with existing best

practices in terms of reporting asset eligibility criteria (impact) reporting and disclosures and include

the relevant stakeholders present in the market

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 43: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

5 Annexes

51 List of Figures and tables

LIST OF FIGURES

Figure 1 Stakeholders on the retail market origination side and on the capital markets funding side 6

Figure 2 Energy Label Atlas in the Netherlands ndash screenshot 13

Figure 3 Difference in mortgage arrears (high energy efficiency vs low energy efficiency) 15

Figure 4 Venn diagram of the building energy performance data availability 25

Figure 5 Mapping of the access to EPC databases 27

Figure 6 Schematic view of the different sources within the EEM Database 30

Figure 7 EPC energy consumption levels according to EU selected countries 33

Figure 8 Distribution of residential building stock registered in EPC database per label in 2014 36

Figure 9 CBI CO2 emission target calculator for Green Bond certification in the building sector 40

LIST OF TABLES

Table 1 Reporting ldquoLayersrdquo and information sources 8

Table 2 Existing Data Templates 9

Table 4 Annual energy costs (in GBP) by type and energy efficiency of the property 15

Table 5 Impact reporting template ndash example from ABN AMRO (the Netherlands) 18

Table 6 CBI Location Specific Criteria for Residential Buildings on European Markets 20

Table 7 National EPC Registers 27

Table 8 Total stock of residential buildings registered in EPC database 28

Table 9 EPC Conversion table 33

Table 10 Selected EU Countries Property Valuation Standards and Calculation Methods 34

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 44: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

4449

52 EPC coverage

Total Dwelling Stock thousands units

2000 2011 2012 2013 2014 2015 2016 2017

Austria 3833 4441 4463 4489 4507 4506 4542 4600

Belgium 4659 5131 5180 5229 5277 5319 5361 5412

Bulgaria na 3900 3909 3918 3928 3935 3944 3951

Croatia na 1924 na na na na na na

Cyprus 288 431 437 441 444 446 na na

Czech Republic na 4700 4729 4754 na na na na

Denmark 2568 2786 2797 2812 2827 2844 2861 2878

Estonia 621 656 658 na na na na na

Finland 2295 2556 2580 2600 2618 2634 2655 na

France 28988 32860 33212 33575 33917 34225 34537 34800

Germany 38384 40630 40806 40995 41221 41446 41703 41970

Greece 5455 6425 6462 6485 6499 6508 6514 6521

Hungary na 4349 4394 4402 4408 4415 4420 4427

Ireland 1406 1999 2003 2007 2014 2022 2004 1974

Italy 27422 31791 31576 na na na na na

Latvia 796 1019 na na na na na na

Lithuania 1309 1283 1289 1298 1396 1408 1417 7734

Luxembourg 118 223 na na na na na na

Malta na 224 na na na na na na

Netherlands 6651 7266 7386 7449 7535 7588 7641 7741

Poland 11845 13560 13723 13853 13983 14119 14272 na

Portugal 5007 5879 5898 5910 5920 5926 na na

Romania 7908 8722 8761 8800 8841 8882 8929 na

Slovakia na 2036 na na na na na na

Slovenia 712 850 854 857 860 na na na

Spain 20376 25209 25271 25245 25209 25171 25126 25094

Sweden 4273 4524 4551 4634 4669 4717 4796 4859

United Kingdom 25319 27614 27767 27914 28073 na na na

Australia na 7760 na na na na na Brazil 62117 63768 65130 67039 68037 69223 69773

Iceland 105 131 132 132 134 135 136 138

Japan na na na 60629 na na na na

Norway 1942 2369 2399 2427 2456 2485 2516 2548

South Korea 17739 18082 18414 18742 19161 19559 19877

Russia 55100 60800 61500 61300 62900 64000 64900 na

Turkey 15070 19482 na na na na na na

USA 116264 132168 132600 133199 133946 134764 135660 136570

Sources EMF-ECBC Hypostat 2018

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 45: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

53 Data Availability Overall Assessment

Category Variable Description Variable Format Possible Data

Source Availability to Data Servicer

EeDaPP Consortium Comments

Borrower Information

at origination

Age Quantitative Mortgage Servicer System

Good At origination (however current age can be calculated)

Borrower credit rating QuantitativeQualitative

(score) Credit Bureau

Bank Poor

Not registered in every jurisdiction In the Netherlands a check will be done on current outstanding debt at other financial institution in the Netherlands - called the BKR check Next to this there is no European definition FICO-like currently

Education Level Qualitative (discrete) Credit Bureau

Bank Poor Level of Education used as credit scoring assessment

Employment status Qualitative (discrete) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household income Quantitative (euro) Mortgage Servicer System

Medium At origination to best of our knowledge this not updated in most jurisdictions

Household size Quantitative Credit Bureau

Bank Poor In most cases only the primary and secondary (if applicable) borrower are known

Property Information

Property Current value Quantitative (euro) Bank IT-system Good Often indexation Mortgage Lending value or AVM

Fuel heating type Qualitative (discrete) Borrower Poor This variable is not commonly reported and asked at origination specific need of EEM (at ldquogreen bondrdquo certification for carbon emission calculations)

Historical value (monthly quarterly or yearly

frequency) Quantitative (euro) Bank IT-system Good Often indexation or AVM

Number of bedrooms Quantitative Credit Bureau

Bank Poor

Occupancy information Qualitative (discrete) Mortgage Servicer System

Medium Could be in Mortgage Servicer System question is if this will be updated at all

Original value at mortgage origination

Bank IT-system Good Standard in regular mortgage reporting and performance data

Property rentable area Quantitative (in msup2) Credit Bureau

Bank Poor

Requested for commercial property this variable is not commonly reported and asked at origination

Property type Qualitative (discrete) Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 46: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

4649

Property year built Quantitative (date) Mortgage Servicer System

Good

Total floor area (m2) Quantitative (in msup2) Credit Bureau

Bank Poor

The information is probably in most mortgage deeds however we doubt to which degree this is currently digitalised

Zip code location Quantitative (spatial) Mortgage Servicer System

Good Available however due to GDPR it is often anonymized truncated

Derived Information

at origination

DSCR (debt service coverage ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

DTI (debt-to-income ratio)

Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

House value relative to the area median value

Quantitative - ratio Derivable Medium Depends on available information per jurisdictions Could be calculated by use of land register cadastre AVMs regional statistics

LTV (loan-to-value) Quantitative - ratio Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Price per square meter Quantitative euromsup2 Valuation

assessment Medium

If the square meters per dwelling are available this could easily be calculated However statistics per area city tend to be available

Energy Performance Information

Energy Performance Certificate (EPC

periodicity amp frequency)

Various (quantitativediscretescore)

EPC register Medium Depends on Jurisdiction In the Netherlands the EPC data is public and free information accessible to anyone This is not the case for al jurisdictions

Building Labels Discrete Building

Certification Provider

Poor Label delivered at origination from certification entities (LEED BRREAM HQE etc)

Operational Energy Consumption

Quantitative Utility Provider Poor This information undoubtfully exists at utility providers There are however some legal GDPR and logistical hurdles to combine this information with regular mortgage reporting and performance data

Loan information

Actual rate (mortgage note rate adjusted by

points) Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 47: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

4749

at origination Amortisation period Quantitative

Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Days in delinquency Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Interest-only periods Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Margin and cap if an ARM Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Maturity date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Original balance Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Origination date Quantitative Mortgage Servicer System

Good Standard in regular mortgage reporting and performance data

Prepayment provisions Quantitative Mortgage Servicer System

Medium In some jurisdictions there are prepayment penalties These are captured in the mortgage deed or reps amp warranties They depend on the product type In general one should say that this information should be available to the servicer

Rate index for adjustable-rate mortgages (ARMs)

Quantitative Bank IT-system Medium If applicable this will be available in most cases

Location information (optional)

CoolingHeating degree-days

Quantitative Eurostat Good Standard in carbon savings assessment to control for the specific climate in selected countries

Distance to central business district

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System access depends on data granularity and privacy issues

Distance to closest public transportation hub

Spatial (in meters) Mortgage Servicer System

Calculation Derived information from address and city level geographic Information System

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 48: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

D32 Technical Report on Market Needs and Gaps

4849

Electricity price Quantitative (euro) Eurostat Good Energy Prices reported at macrolevel for specific users (households industrials) and given their level of annual electricity demand (small medium or big users)

Number of foreclosures Quantitative EBA NPL Template

Medium EBA discloses bank or country level information not loan by loan

Unemployment rate Quantitative Eurostat Good Macroeconomic indicator displayed at national or regional levels

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu

Page 49: EFFI IENT MORTGAGES [ REPORTING · 2019-01-16 · EFFI IENT MORTGAGES [ REPORTING PROTOCOL AND DATA PORTAL IMPLEMENTATION Setting on the necessary requirements for a harmonised reporting,

This project has received funding from the European Unionrsquos Horizon 2020 research and innovation programme under grant agreement No 784979

EeDaPP ndash Energy efficiency Data Protocol and Portal - is an initiative by the European Mortgage

Federation - European Covered Bond Council (EMF-ECBC) Carsquo Foscari University of Venice CRIF

SpA European DataWarehouse GmbH Hypoport BV TXS GmbH and SAFE Goethe University

Frankfurt For more information visit wwwenergyefficientmortgageseu