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Implementation of the EPBD in 1. Introduction The implementation of the Energy Performance of Buildings Directive (EPBD) is the responsibility of the French Ministries of Ecology and Housing. In order to replicate the successful transposition of Directive 91/2002/EC, France has been working on implementing the Directive 2010/31/EU since its publication. Law 2010/788 of 12 July 2010 and the regulation that followed have significantly improved the Energy Performance Certificate (EPC) process, while the new thermal regulation, RT 2012, has brought energy efficiency of new buildings to the level of Nearly Zero‐ Energy Buildings (NZEB). This report is structured around four main parts, each one giving an overview of the EPBD current status of implementation on a certain topic. These four parts concern requirements on buildings’ energy performance, Technical Building Systems (TBS), EPCs and inspection for heating and Air‐ Conditioning (AC) systems. There is one last additional part highlighting a specific point considered in France successful within the EPBD implementation: the positive effect of mandatory advertising requirements of EPCs. 2. Current status of Implementation of the EPBD I. ENERGY PERFORMANCE REQUIREMENTS I.i. Progress and current status New residential and non‐residential buildings The first thermal regulation in response to the EPBD was the RT 2005 (Réglementation Thermique 2005), introduced in 2006. It concerned all new buildings, both residential and non‐ residential (including public buildings), and set maximum energy consumption along with minimum requirements on some elements such as envelope insulation, and Heating Ventilation and Air‐Conditioning (HVAC) systems. It has since been replaced by a new regulation, the RT 2012 (Réglementation Thermique 2012), mandatory only for some public buildings since the end of 2011, and for all new constructions since 2013. This regulation is the result of a two year‐long dialogue with all stakeholders, including seven consultative conferences where the work in progress was presented. The next thermal regulation is planned for 2018 and it will present even more ambitious objectives, since all new buildings would then be “positive energy buildings”. These requirements will first be applied during the year 2016 to public buildings. AUTHORS Marie‐Christine Roger, Niousha Rezaï, General Directorate For Urban Development, Housing and Nature (DGALN) Solenn Le Guen, General Directorate For Energy and Climate (DGEC) NATIONAL WEBSITES www.developpementdurable.gouv.fr, www.rtbatiment.fr, www.ademe.fr STATUS IN DECEMBER 2014 France

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Page 1: Implementation France of the EPBD in · (BBCR 2009), demanding a level of 80 kWh/m².year. For existing non‐residential buildings there is only one quality seal also called “Low

Implementationof the EPBD in

1. Introduction

The implementation of the Energy

Performance of Buildings Directive (EPBD)

is the responsibility of the French

Ministries of Ecology and Housing. In

order to replicate the successful

transposition of Directive 91/2002/EC,

France has been working on implementing

the Directive 2010/31/EU since its

publication. Law 2010/788 of 12 July

2010 and the regulation that followed

have significantly improved the Energy

Performance Certificate (EPC) process,

while the new thermal regulation, RT

2012, has brought energy efficiency of

new buildings to the level of Nearly Zero‐

Energy Buildings (NZEB).

This report is structured around four

main parts, each one giving an overview

of the EPBD current status of

implementation on a certain topic. These

four parts concern requirements on

buildings’ energy performance, Technical

Building Systems (TBS), EPCs and

inspection for heating and Air‐

Conditioning (AC) systems. There is one

last additional part highlighting a specific

point considered in France successful

within the EPBD implementation: the

positive effect of mandatory advertising

requirements of EPCs.

2. Current status ofImplementation of the EPBD

I. ENERGY PERFORMANCEREQUIREMENTS

I.i. Progress and current status

New residential and non‐residentialbuildings

The first thermal regulation in response tothe EPBD was the RT 2005(Réglementation Thermique 2005),introduced in 2006. It concerned all newbuildings, both residential and non‐residential (including public buildings),and set maximum energy consumptionalong with minimum requirements onsome elements such as envelopeinsulation, and Heating Ventilation andAir‐Conditioning (HVAC) systems. It hassince been replaced by a new regulation,the RT 2012 (Réglementation Thermique2012), mandatory only for some publicbuildings since the end of 2011, and forall new constructions since 2013. Thisregulation is the result of a two year‐longdialogue with all stakeholders, includingseven consultative conferences where thework in progress was presented. The nextthermal regulation is planned for 2018and it will present even more ambitiousobjectives, since all new buildings wouldthen be “positive energy buildings”.These requirements will first be appliedduring the year 2016 to public buildings.

AUTHORSMarie‐Christine Roger,Niousha Rezaï,General DirectorateFor UrbanDevelopment,Housing and Nature(DGALN)

Solenn Le Guen,General DirectorateFor Energy andClimate (DGEC)

NATIONAL WEBSITESwww.developpement­durable.gouv.fr, www.rt­batiment.fr, www.ademe.fr

STATUS IN DECEMBER 2014France

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Existing residential and non‐residentialbuildings

Following the publication of RT 2005, tworegulations were introduced for existingbuildings. The first one, called “RT parélément” (Regulation by BuildingComponent), was published in late 2007 andthe second one, called “RT globale” (GlobalThermal Regulation), was introduced in April2008. Figure 2 shows how to determine therelevant regulation, depending on therenovation type (major or minor).

I.ii. Format of nationaltransposition and implementationof existing regulations

New residential and non‐residentialbuildings

The RT 2012 is structured around threeperformance requirements:

> the requirement for minimum energyefficiency of buildings, which imposes alimitation on energy demand (heating,cooling and lighting) based on thebioclimatic conception (Bbio) of theproject, whereby the Bbio value has to belower than a maximum value called Bbiomax;

> the requirements for primary energy

consumption, which impose a limitationon primary energy consumed (Cpe) forthe combined use of heating, cooling,Domestic Hot Water (DHW), lighting andauxiliaries (pumps and fans), wherebythe Cpe has to be lower than a maximumvalue called Cpemax;

> the requirement for summer comfort,where the ambient indoor temperature ofthe building, reached after the 5 hottestdays of the year (Tic), cannot exceed areference level calculated for eachproject, whereby Tic has to be lower thana maximum reference value called Ticref.

These three coefficients are calculatedthrough TH‐BCE, a dynamic hourlymethodology (calculations are run everyhour of a full year), which describes eachcomponent of the building envelope, aswell as its energy systems[1].

The values of Bbiomax and Cpemax are absolutevalues, based on standard benchmarksdepending on the building type (Table 1)and are modulated by local climate, altitudeand immediate environment factors.

Additionally, in order to ensure thatresidential structures are correctly built,upon completion of the building,Qualified Experts (QEs) have to checktheir airtightness which cannot exceed0.6 (m3/h)/m2 for single‐family housesand 1 (m3/h)/m2 for apartment buildings.

Finally, the RT 2012 includesrequirements for renewable energy use.It takes different forms depending on theenergy type (for example a minimum of2 m² for solar panels), but it shouldamount to at least 5 kWhEP/m².year.

Existing residential and non‐residentialbuildings

As previously described, there are tworegulations for existing buildings. Whichof the two applies depends on thebuilding size and the extent of therenovation (Figure 2). The Regulation byBuilding Component is based on minimumrequirements for the differentcomponents of the building (envelope andsystems) (Table 2). Shading devices aremandatory only if they already existedbefore the renovation. There are nominimum requirements for thermalbridges.

The Global Thermal Regulation is basedon overall consumption with minimumrequirements for each component of thebuilding (envelope and technicalsystems). Energy performance is assessedusing a complex hourly methodology,called TH‐CE ex, based on the newbuildings’ methodology[2].

Figure 2:Thermal Regulations

for existing buildings.

Figure 1: Evolution of requirements (new buildings).

[1] Th­BCE calculation core: www.rt­batiment.fr/batiments­neufs/reglementation­thermique­2012/logiciels­dapplication.html[2] Table 2: Some requirements for existing buildings in the Regulation by Building Components.

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I.iii. Cost­optimal procedure forsetting energy performancerequirementsCost‐optimality of the French thermalregulations has been analysed incompliance with the EPBD. Theconclusions drawn are summarised below.

New residential buildings

Based on a representative sample ofnewly constructed residential buildings (3individual houses and 3 apartmentbuildings), the mean value of maximumprimary energy consumption (Cpemax) hasbeen calculated to 54 kWh/m².year. Inorder to determine the cost‐optimal level,approximately 140 calculations were donefor 4 construction packages in 3 areaswith differing climates and the costs werecalculated from both the macroeconomicand the financial perspective. Figure 3shows the plots for one type of individualhouse. The cost‐optimal level determinedis between 59.4 kWh/m².year and84.1 kWh/m².year, which represent a6.5% improvement beyond the cost‐optimal level.

Existing residential buildings

This study is based on a representativesample of existing buildings (4 individualhouses and 6 apartment buildings) and theresults depend on which regulation isapplied. The calculation procedure wassimilar to the one for new buildings, exceptthat there were 6 different improvementpackages, which bring the calculationnumber to 260. For both regulation cases,mean values have been weighted byrepresentative reference buildings.

The Global Thermal Regulation presents amean maximum consumption of134.2 kWh/m².year whereas the cost‐optimal level is between118.2 kWh/m².year and130.1 kWh/m².year. The mean deviationcalculated is just 3.1% below cost‐optimal.

The Regulation by Building Component hasalso been evaluated for major renovations.Its mean maximum consumption is133.1 kWh/m².year whereas thecost–optimal level is between105.5 kWh/m².year and124.6 kWh/m².year. This is 6.8% betterthan cost‐optimal.

New and existing non‐residentialbuildings

The methodology was the same for non‐residential buildings. The samplecontained 4 new buildings (an office, aschool, a large shop and a hospital) and 8existing ones (two office buildings, twoschools, a hotel, a shop, a gymnasium anda hospital), with 4 and 6 improvementpackages respectively. However, the plotsdid not consistently show a visible cost‐optimal level. When visible (as on Figure4), the difference between cost‐optimallevel and regulation was less than 15%.

Table 2:Some requirementsfor existing buildingsin the Regulation byBuilding Components.

Table 1:Bbiomax and Cpemax

for various newbuildings’ typologies.

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I.iv. Action plan for progressiontowards Nearly Zero­EnergyBuildings (NZEBs)

National application of the NZEBdefinition

In France, NZEBs are called “LowConsumption Energy Buildings” (BâtimentsBasse Consommation ‐ BBC), and wereoriginally a quality seal for buildings withvery low energy consumption, and in thecase of individual houses, they included inparticular a great proportion of RenewableEnergy Sources (RES). Since 2013, all newbuildings are mandatory NZEBs sincerequirements for Low Consumption EnergyBuildings match the RT2012. Therefore,the cost‐optimal level for NZEB has beenevaluated along with the RT2012 one.

Although regulations for existing buildingsare quite ambitious, renovated buildingsdo not systematically reach the NZEBlevel. The French Government hastherefore developed several quality sealsin order to encourage owners to gobeyond the regulation requirements.

For existing residential buildings there aretwo quality seals: “High PerformanceEnergy 2009” (HPE 2009), demanding alevel of 150 kWh/m².year, and “Low

Energy Consumption Renovation 2009”(BBCR 2009), demanding a level of80 kWh/m².year.

For existing non‐residential buildingsthere is only one quality seal also called“Low Energy Consumption Renovation2009” (BBCR 2009). It certifies that theconsumption of energy of the renovatedbuilding is at least 40% less than thereference building (the same building,with specified envelope and systems).

Figures and statistics on existing NZEBs

Three hundred thirty five thousand(335,000) new houses (300,000 apartmentsand 35,000 individual houses) werecertified NZEBs before the RT2012enforcement. In addition, there have beenaround 465,000 new houses certified sincethe enforcement of RT2012. Hence, thecurrent number of new NZEB houses can beestimated to be approximately 800,000.

On the renovation side, 26,172 houseswere given the Low Energy ConsumptionRenovation 2009 quality seal. For non‐residential buildings, more than 2 millionconstructed m² are certified NZEBs, andabout 640,000 renovated m² have beengiven the Low Energy ConsumptionRenovation 2009 quality seal.

Figure 4:Cost­optimality

curve for a non­residential building

(office building)– primary energy.

Figure 3:Cost­optimality

curve for one type ofnew individual house

­ primary energy.

Zone H1b

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I.v. Implementation of the EnergyEfficiency Directive (EED) regardingbuilding renovation and theexemplary role of public buildings

Article 4 of the EED

In order to promote thermal renovationFrance has established several measuresfor both residential and non‐residentialbuildings.

In 2013, the National Plan for HousingThermal Renovation was launched. It isbased on 3 pillars:

> assisting private individuals with freeindependent advice;

> improving financing thanks to optimisedgrants based on households incomes;

> raising the skills of the constructionsector to handle the cost and quality ofthe renovation.

Concurrently with this national plan, localauthorities made more than 80 projectproposals in order to work closer withboth private and public landlords. Thebest projects have been nationallypromoted as good examples of local work.

Concerning non‐residential buildings, acharter has been signed by the FrenchGovernment and major companies,showing a commitment for energyefficiency by everyone involved.

To encourage professionals to build‐uptheir skills, there will be some financialsupport to owners whose renovations aremade by qualified workers.

Finally, a fund for guarantee of loans withhigher risk that will reimburse banks incase of non‐payment will be established,aiming to mobilise investments.

Article 5 of the EED

In order to implement Article 5 of the EED,France has chosen an alternative option.Indeed, in the “Grenelle del’Environnement” laws (voted in 2009 and2010), there is a goal for a 40% primaryenergy reduction until 2020 for all thebuildings owned by the French Government.Based on the results of energy audits on arepresentative sample of the building stock,this would represent 10,131 GWh (primaryenergy) saved. In comparison, the 3%renovation proposed in the EED would leadto only 2,477 GWh (primary energy) saved.

Three types of action will help to reachthis ambitious goal:

> renovation carried out by Frenchauthorities;

> a better use of the building;> selling the unused buildings in order to

have them renovated by a private landlord.

II. REQUIREMENTS ONTECHNICAL BUILDINGSYSTEMS (TBS)

II.i. Coverage of heating, hotwater, air­conditioning and largeventilation systemsAs explained before, the thermalregulation for new buildings sets generalperformance objectives. Therefore, itdoes not include any requirements onsystems’ efficiency. However, suchrequirements exist in the two thermalregulations for existing buildings.

Both these regulations share some rules,especially for DHW, setting maximumheat loss depending on the boiler size,and giving European Norms 89 and 26 as areference for some systems’ performance.

The Regulation by Building Componentgives a minimum efficiency around 90%for boilers and a coefficient ofperformance (COP) of 3.2 for heat pumpson heating mode. For AC units under12 kW, the energy efficiency rating shouldbe at least 3.0. For other AC systems theefficiency should be between 2.6 and 3.0.Ventilation unit consumption should notexceed 0.25 Wh/m3 for residentialbuildings and 0.3 Wh/m3 for non‐residential buildings.

II.ii. Applicability to new,replacement and upgradedsystems in existing buildings

For existing buildings, each time a newsystem is installed or replaces an old one,its performance has to meet therequirements of Global ThermalRegulation if the project meets thecriteria of a major renovation. If it is notclassified as a major renovation, it has tomeet the requirements of the Regulationby Building Component.

II.iii. Provisions for installation,dimensioning, adjustment andcontrolInstallation, dimensioning, adjustmentand control are handled in theStandardised Technical Documents(“Documents Techniques Unifiés”), a setof rules acknowledged by theprofessionals, and they are not a purelyregulation matter.

If the planned installation is regarded asunder‐sized, the TH‐BCE and TH‐CE excalculation software will display an errormessage and may not run the calculationto the end. Over‐sizing penalises thecalculated energy needs, but there is nolegal limit.

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II.iv. Encouragement ofintelligent meteringIntelligent meters for both electricity(“Linky”) and gas (“Gazpar”) are to bewidely deployed, with a target of fullnational coverage by 2021. Thedeployment will be carried out by theElectricity Network of France (ERDF) andthe Gas Network of France (GRDF). Thereare no requirements for intelligentmetering for individual TBS.

The initial target for the number of houseswith intelligent meters by 2016 is set at3 million. As a test, by the end of 2011Linky was already installed in 300,000houses in two different regions, with morethan 90% satisfied household users. In2014, there have been several ERDFinvitations to tender, and the secondsemester of 2015 will see the beginning ofthe wide installation of these meters.

II.v. Encouragement of activeenergy­saving control(automation, control andmonitoring)For each energy use, the RT2012 and theRT Global include requirements to installactive energy‐saving control systems:

> Heating and cooling systems have to beautomatically regulated in accordancewith internal temperature and offer thepossibility to be switched off manually.

> For building with discontinuousoccupation, the heating system mustinclude four operating modes: comfort,reduced heating, frost‐free and switchedoff. These four modes should becontrolled by a clock‐based automation,but could also be manually programmed.

> Any door giving access to an air‐conditioned area must closeautomatically after crossing.

> For mechanical ventilation systems, airflow manual modification must betemporised.

> Artificial lighting systems must switchoff automatically when the lit area isnot occupied, or when natural lightinglevels are sufficient.

III. ENERGY PERFORMANCECERTIFICATES (EPCs)REQUIREMENTS

III.i. Progress and current statuson sale or rental of buildings

Overview and administration system

The French EPC, called “Diagnostic dePerformance Energétique (DPE)”, wasintroduced in France in 2006 and isproduced by a QE. For both existing andnew buildings, issuing an EPC involves theQE assessing the thermal efficiency of thebuilding following an on‐site visit, wherethe envelope, HVAC and DHW systems areinspected. Once issued, the EPC isautomatically sent to the EPC nationaldatabase (mandatory since 2013), and isvalid for 10 years.

How flats are certified in apartmentbuildings

As displayed on Table 3, the energyperformance can either be estimated(using a calculation methodology) ormeasured (using energy bills), dependingon the building’s nature. For buildingswith a collective heating system, if anEPC is issued for the whole building,individual EPCs can be drawn for eachapartment, using a factor that takes intoaccount its floor size, the size and thedirection of its windows and the size ofthe walls giving onto unheated premises.

Format and content of the EPC

The first page of the EPC shows thecalculated or measured consumption ofheating, cooling, DHW, etc., expressed infinal and primary energy and thecorresponding annual costs. It alsodisplays the energy label along with thegreenhouse gas emission label. Thoselabels classify buildings on an energyconsumption (or greenhouse gas emission)scale ranging from A (< 50 kWh/m².yearprimary energy or < 5 kg/m².year CO2equivalent) to G (> 450 kWh/m².year or> 80 kg/m².year CO2 equivalent). Thesecond and third pages show technicalinformation about the building and

Table 3:EPC method used.

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provide some common advice. The lastpage features specific recommendationsgiven to the building owner by the QE.

EPC activity levels

Following the set up of the national EPCdatabase, the precise EPC activity level asof April 2013 can be determined. Thenumber of EPCs issued since that date canbe seen on Table 5 with a total of1,251,000 EPCs registered on thedatabase. The number of EPCs before2013 can only be estimated.

The total figure (before and after 2013) isestimated to circa 6 million EPCs for allbuilding types, which represents a fifth ofthe national building stock.

Typical EPC costs

The cost of the certificate is notregulated. Average market prices arepresented in Table 6.

Assessor corps

Since 2006, QEs have to be certified by anaccredited body. In late 2011, theminimum requirements for becoming andcontinuing to practice as an expert wereincluded in the regulation in order tomake the EPC more reliable. There are 2levels of certification: QE for singleresidential buildings, and advanced QE fornon‐residential and apartment buildings.QEs with the advanced certification mayalso produce EPCs for single residentialbuildings.

The requirements for a QE in singleresidential buildings are:

(left) Figure 5:EPC cover page.

(right) Figure 6:EPC fourth page.

Table 4:kWh final energy toCO2 emissionconversion factor

.

Table 5:Total number of EPCsissued since 2013.

Table 6:EPC average prices.

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> initial education: 2 years after theFrench high school diploma in the fieldof construction;

> ongoing training: 3 days training in thefield of EPC every 5 years.

The training expert is assessed in twoexaminations: one theoretical and onepractical. A certification cycle lasts 5 years,after which experts must be re‐certified.

The requirements for an advanced QE(non‐residential buildings and apartmentsbuildings) are:

> initial education: 2, 3 or 5 years afterthe French high school diploma in thefield of construction and respectively 3,2 or 1 years of work experience in thefield of construction;

> ongoing training: 5 days training in thefield of EPC every 5 years.

As for the standard level, there are twoexaminations (theoretical and practical),focussing more specifically on non‐residential and apartments buildings.

The list of QEs is available to the publiconline. In early 2014, according to the lastavailable list, there were 9,700 QEsincluding 1,400 advanced QEs.

Compliance levels by sector

The EPC is part of the real estatediagnosis file, a set of documentsmandatory for a sale or a rental. Thisway, the notary in charge of concludingthe sale (or the real estate agent in caseof leasing) will not act withoutpresentation of a valid ECP. ECPs aretherefore produced for 100% of the salesand for the vast majority of the rents,with the exception of private transactions(when no estate agent is involved).

As a consequence, it is the buildingowner’s duty to have the EPC produced.Once issued, the owner has to give it tothe real estate agent who then presents itto the potential buyer (or tenant), helpingthe latter to make a choice.

Quality Assurance (QA) of EPCs

There is a Quality Assurance (QA) systemrequiring the work of each QE to bechecked on a continuous basis. Newexperts are checked 4 times during thefirst year, and 4 more times in thefollowing 4 years. Following this first cycle

of certification, experts are checked 4times every 5 years. Table 7 shows thetype and number of checks performed oneach expert by its certifying body.

In 2013, there were 1,200 new QEs, whichcorresponded to 4,800 checks. A fifth ofthe remaining QEs were also controlled (4EPCs checked per QE), corresponding to afurther 6,800 checks. These controlsrepresent a total amount of 11,600 EPCschecked in 2013. The certifying body mustverify that each point of the regulation isabided by and it can withdraw the expert’scertification temporarily or permanently incase some fields in the EPC are notcorrectly filled. Following this exercise in2013, a total of 682 QE certifications werepermanently withdrawn and a further 480QEs received a suspension.

The EPC database can also be used as aQA tool, since it allows landlords to checkthe accuracy of their EPC.

Finally, there is a directory of QEsavailable, so landlords can check that theQE is certified.

III.ii. Progress and current statuson public and large buildingsvisited by the public

Overview

Since 2007, all buildings over 1,000 m²occupied by public authorities andfrequently visited by the public must havean EPC issued. In 2013, the threshold waslowered to 500 m² and it will be loweredfurther to 250 m² in 2015. Once issued,the EPC must be displayed near theentrance point of the building clearlyvisible by the public.

Format and content of the EPC

Public buildings are mainly non‐residentialbuildings for which the EPC format andcontent is generally the same as forresidential buildings. The main differencerelates to the thresholds between thedifferent consumption classes on theenergy label. Non‐residential buildings areseparated in 4 categories, shown onTable 8.

Frequency of updating

EPCs for public buildings frequently visitedby the public are valid for 10 years.

Table 7:Number and types of

checks.

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Activity levels

As for the general activity level, the exactnumber of EPCs issued for this type ofbuilding can be determined since April2013. For buildings over 1,000 m², thedatabase shows around 1,600 EPCs issued.The number of EPCs issued for buildingsbetween 500 and 1,000 m² is around 700,although the real number is probablyhigher due to public bodies’ pro‐activeness (EPCs issued before registrationin the database started in April 2013).Indeed, the database shows around 400EPC issued for buildings between 250 and500 m², even though the mandatorythreshold is still 500 m².

Costs

For public and large buildings visited bythe public, it is not possible to provideaverage prices because of the multipletypologies of non‐residential buildings.However, the value of 1 €/m² has beenused in a study to evaluate the impact ofthe measure on public bodies.

Assessor corps

QEs have to be certified on an advancedlevel to issue EPCs for public and largebuildings visited by the public.

Quality Assurance (QA) of EPCs

There are no particular QA differencesbetween EPCs issued for public and largebuildings visited by the public, and otherEPCs.

III.iii. Implementation ofmandatory advertising requirement

Since 1 January 2011, it is mandatory forreal estate agencies to include some partsof the EPC in their advertising. Every typeof advertising is affected, but not in thesame way. Advertisements published innewspapers should display at least theenergy class letter. On the other hand,advertisements published on the internetor at the real estate office must displaythe full energy label. The picture of thelabel should be at least 180 X180 pixels onthe internet and should occupy at least 5%of the advertisement displayed at the realestate office.

In case of non‐compliance there are twotypes of sanctions: on the civil‐law sidethe client can demand the cancellation ofthe sale; on the criminal‐law side, the salecan be considered as fraudulent and canlead to a prison term of two years withoutremission and to a 37,500 € fine imposedby the General Directorate ofCompetition, Consumption and FraudRepression (DGCCRF). Such penalties havenever been applied. A simple call to orderhas always been enough to bring non‐compliant parties to compliancy. Yet, theDGCCRF estimates that in 15% of the realestate dealings the EPC is not displayed.

III.iv. Information campaigns

Periodically, the ministry in charge of theregulation on EPCs publishes guidebooksaiming to raise public awareness of thelinks between environment, energyperformance and economy. They covertopics such as thermal regulation, EPC,financial incentives and renovation.

The ministry also runs several informationwebsites, providing information toindividuals as well as professionals andhelping them to best understand andapply the different topics of the EPBD.

Finally, France collaborates closely withthe European association of localauthorities in energy transition, EnergyCities. One of their campaigns, ‘Display’,has pushed many French cities to issueEPCs for their public buildings,contributing in giving the EPC a goodreputation and leading to numerousrenovations.

Figure 7:Example ofadvertising on theinternet.

Figure 8:Example ofguidebook publishedin 2014.

Table 8: Consumption range (primary energy) depending on building type.

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III.v. Coverage of the nationalbuilding stockThe total number of residential units(houses and apartments) in France isaround 30 million, with a total number of5 million EPCs issued at the end of 2012.With the addition of the 1 million EPCsissued between April 2013 andSeptember 2014 for existing houses andapartments, we can conclude thataround 20% of the national existinghousing stock is covered.

The statistics show a number of 330,000new residential buildings, correspondingto an equal number of EPCs issued.

IV. INSPECTIONREQUIREMENTS – HEATINGAND AIR­CONDITIONING (AC)SYSTEMS

To transpose Article 15 about AC systems,France has chosen to adopt the defaultapproach, which consists of a periodicinspection scheme. For heating systems,an inspection scheme has been introducedfor boilers of more than 400 kW. Forboilers between 4 and 400 kW, alternativemeasures involving an annualmaintenance visit have been takenaccording to Paragraph 4 of Article 14 ofthe EPBD. The inspection of heatingsystems of more than 400 kW is similar toinspections for AC systems (Table 9).

Energy saving due to the enforcement ofArticle 14 and 15 of EPBD is part of the FrenchNational Energy Efficiency Action Plan in

order to reach the target announced in April2013 in application of Article 3 of the EED.

IV.i. Progress and current statuson heating systemsAlternative measures that have beentaken to improve the energy performanceof heating systems are the following:

> An annual maintenance visit is requiredfor systems with an output lower than400 kW. This visit can be performed byany professional in the field ofmaintenance. During the maintenancevisit, the professional must:• check the boiler and, if necessary,

clean it and tune it;• measure the concentration of carbon

monoxide (CO);• evaluate the energy and

environmental performance of theboiler:‐ evaluation of the energy efficiency of

the boiler, which is compared to theenergy efficiency of the best boilersavailable on the market today;

‐ evaluation of the polluting emissionsof the boiler, which are compared tothe emissions of the best boilersavailable on the market today (NOxfor gas and oil boilers, VOC andparticulates for biomass boilers);

• provide advice on best use, improvementof the boiler and of the heating systemin place and, if necessary, advice on thereplacement of the installation;

• a certificate of maintenance should beissued within 15 days after the visit,containing contain the results of themeasurements and evaluations listedabove, and includingrecommendations on best use andimprovement of the heating system inplace, as well as, if necessary, adviceon the replacement of theinstallation. The reports are notcollected in a central database;

• the Ministry in charge of the regulationon inspections together with the FrenchEnergy Agency (ADEME), have prepareda guide for the public in order toexplain the new provisions regardingthe annual maintenance of boilers. Itcan be downloaded free of charge fromthe ministry’s website. Also, a guide forprofessionals was prepared by the

Figure 9:Screenshot from thewebsite hosting the

EPC[3] database.

Table 9:Inspection or

maintenance scheme.

[3] In French: DPE.

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association “Énergies et Avenir”, anassociation of professionals dedicated tothe promotion of heating systems usinghot water.

> Financial support: The tax benefit“Sustainable Development” is availablesince 2005 and its name changed to“Energy Transition (CITE)” in 2015. It isa tax benefit for the purchase of themost efficient materials and equipmentin terms of energy saving and reductionof greenhouse gas emissions. Theamount of the credit depends on thesystem type and its price. The onlyproof needed to get the tax benefit isthe sales receipt. The expenditureamount for the tax benefit “EnergyTransition” shall not exceed 8,000 € forone person, and 16,000 € for a couple.In response to Article 7 of the EED thereis also an obligation for energy suppliersto practice energy saving (or to have itpracticed by their consumers). Tocomply with this obligation, energysuppliers, among other things, have topromote and support Energy SavingCertificates (ECS) among their clients.These Energy Saving Certificates cantake the form of standardised action, orthey can be more specific, and willoften imply heating system basedaction. The overall saving goal was54 TWh from 2006 to 2009 and 345 TWhfrom 2011 to 2013. Both goals werereached, and the new goal is 700 TWhfrom 2015 to 2017.Since 2009, the 0% Eco‐Loans (loans witha 0% interest rate) have enabledfinancing of work to improve the overallenergy performance of buildings and inparticular to improve heating systems.They are designed for property‐owningindividuals to finance major renovationwork. This loan is addressed to the ownerof a building, with a maximum amount of30,000 € over a 15 year period.In addition to that, the financial supportof the National Agency for HousingImprovement (Anah) helped low‐incomehouseholds to finance renovation work ifthey can reduce their energyconsumption by at least 25%. The levelof financial support varies depending onthe income of the beneficiaries, with amaximum amount of 10,000 €. A bonus“Habiter mieux” can also be given witha maximum amount of 2,000 €.Finally, a reduced VAT (5.5%) applies forrenovation works in residentialbuildings. To take advantage of this VATreduction, materials used shall respecttechnical characteristics adopted by aministerial order.

> Information campaigns: ADEME and theministry in charge of the regulation oninspections conducted publicitycampaigns in relation to the mostefficient heating systems and to financialsupport for replacement. Campaignshave also covered improving the energyperformance of a building as a whole andpossible financial support or tax benefit(Sustainable Development Tax Benefit,zero‐interest eco‐loans, etc.). The“Energy Info Sites” also provideinformation on how to improve theefficiency of boilers and heating systems.

Equivalence of the alternative measuresfor systems under 400 kW output

The equivalence has been proven in twostages. First, the impact of some financialsupport on energy saving (Tax Benefit“Sustainable Development”, 0% Eco‐Loans, and energy efficiency certificates)has been assessed by making a hypothesisto avoid double‐counting.

According to the French regulation, boilersof more than 400 kW are not supposed to beinspected every year. In fact, for boilersbetween 400 kW and 20 MW, inspectionsshall be carried out every two years. Duringthe inspection visit the QE must check andmeasure the same elements as regard toboilers from 4 – 400 kW. But for boilers ofmore than 400 kW a ‘boiler‐room handbook’has to be kept, recording all informationabout the system.

There has been a comparison between thehypothetical inspection scheme (thereference scheme) and the annualmaintenance visit (alternative scheme).The main differences between the twocalculations were the following:

> The scope is larger for the alternativescheme (for the default approach onlyboilers of more than 20 kW aretargeted, while maintenance concernsboilers of more than 4 kW).

> Inspections will not systematicallylead to renovation work and thusenergy saving, whereas a maintenancevisit would, although the energysaving following maintenance wouldbe lower than the saving following arenovation.

The assessment of the impact ofalternative measures and the onesresulting from the implementation of thedefault approach shows that thealternative measures taken by Francepermit more than twice the energy savinglinked to the implementation of a regularinspection scheme. Indeed, as explained inthe report requested by Article 14 of theEPBD, inspections would lead to savings

Figure 10:Cover page of theguide formaintenance ofboilers.

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between 5.12 TWh and 13.84 TWh,whereas alternative measures savingswould be between 47.68 TWh and70.94 TWh.

IV.ii. Progress and current statuson AC systems

Overview, technical method andadministration system

The French regulation on AC systems[4] hasbeen in application since 16 April 2010.France has chosen to implement Article 15of the EPBD by enforcing the followingpoints:

> inspection of AC systems and reversibleheat pumps with an output of 12 kW ormore;

> to be carried out once every 5 years;> person responsible for the inspection is

the owner or the manager of thebuilding;

> inspectors should be certified.A report is issued within one month afterthe inspection with the results and adviceon best use, improvement of the ACsystem in place and, if necessary, adviceon the replacement of the installation.Standard EN 15240 was used as a basis forthe methodology, but the methodology ofinspection is fully described in thedecrees.

The inspection should include:

> inspection of documentation;> assessment of system performance at

the time of the on‐site inspection;

> assessment of the sizing of the system inrelation to the cooling requirements ofthe building at the time of the on‐siteinspection;

> provision of the necessaryrecommendations concerning proper useof the system in place, possibleimprovements to the installation as awhole, any benefit from its replacementand other potential solutions.

In total, this mechanism covers some300,000 AC systems in France, whichamounts to around 10% of installed stock,as the vast majority has a thermal powerless than 12 kW.

To perform an inspection of AC systems,experts have to be certified according toISO standard 17024 ‘General requirementsfor bodies operating certification ofpersons’ by an accredited body. This bodyis accredited by the French committee ofaccreditation (COFRAC).

There are two levels of certification:

> the ‘simple systems’ level, for theinspection of AC systems and reversibleheat pumps with output from 12 kW to100 kW;

> the ‘all systems’ level, for theinspection of all such systems, large orsmall.

Experts have to pass a theoretical and apractical examination and are certified for5 years. There are currently 3 certifyingbodies and around 250 inspectors(Figure 11).

Arrangements for assurance, registrationand promotion of competent persons

Each accredited body has to makepublically available the list of the expertshaving a valid certificate, which providesa useful source of information for thepublic. There are currently around 200accredited experts.

Promotional activities

At national level, the details of theregulation are presented as much aspossible at relevant conferences. There isalso a relevant section on the website ofthe ministry. It explains the main pointsof the regulation and a frequently askedquestion section is reviewed on a regularbasis.

Enforcement and penalties

Provisions on controls and penalties areset in the regulation. Control can beperformed by officers of the GeneralDirectorate for Competition Policy,

[4] “Arrêté du 16 avril 2010 relatif à l’inspection périodique des systèmes de climatisation et des pompes à chaleur“ and“Arrêté du 16 avril 2010 définissant les critères de certification des compétences des personnes physiques réalisantl’inspection périodique des systèmes de climatisation et des pompes à chaleur“

Figure 11:Process of

certification ofinspectors.

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Consumer Affairs and Fraud Control. If theregulation has not been properly adheredto, the relevant authority can applyseveral types of sanctions:

> to carry out a new inspection of the ACsystem at the owner’s expense;

> to oblige the owner to deposit theequivalent of the inspection cost with apublic accountant. As soon as theinspection is carried out, the sum ofmoney is given back;

> to oblige the owner to pay a fine;> to force the owner to stop the AC system.Since many public bodies can performcontrols, feedback about the number ofthem is not available.

Quality control of inspection reports

The independent control system isincluded directly in the certificationscheme. Experts are certified by bodieswhich are accredited by the COFRACaccording to ISO standard 17024 “Generalrequirements for bodies operatingcertification of persons” (Figure 12).

During this period the accredited body hasto:

> check at least two reports per year;> check if experts perform enough

inspections;> accompany the expert during at least

one of his/her on‐site inspections.The COFRAC checks if the accreditedbodies meet the requirements of thestandard.

There are 4 bodies accredited by theCOFRAC according to ISO standard 17024“General requirements for bodiesoperating certification of persons” tocertify experts. So far they have certifiedaround 250 experts. An expert performs8 inspections per year on average, whichmeans that in 2013 around 2,000inspections took place. This is only anestimate as there is no central databaseof reports. A total of 150 reports werecontrolled in 2013, corresponding to 8% ofthe total number of reports.

Impact assessment

The reports are not collected in a centraldatabase so it is challenging to assessprecisely the impact of the inspectionscheme. Energy saving is variable becauseinspection does not lead systematically toan action on the system. This means thatenergy saving depends first on thedecision of the owner to do something ornot, and then on the extent of the work.According to owners’ feedback, saving caneasily reach 20% of the energyconsumption of the AC system.

Costs and benefits

Concerning cost‐effectiveness of theinspections, an expert needs one day toperform an inspection and that costs600 €. Given that inspections occur everyfive years, this is equivalent to120 €/year. As said above, energy savingis closely linked to the choice of theowner after an inspection, making it verydifficult to assess the impact in terms ofenergy saving. Indeed, when the system isnot well maintained or when there is nocontrol, the energy saving can beimportant enough to make the inspectioncost‐effective. But, if the system isrelatively new or properly monitored,then the price of the inspection providesno return.

3. A success story in EPBDimplementation

France’s success story lies in the numerouspositive effects of the mandatoryadvertising requirements of the EPC (seesection 2.III.iii). It is clear at first glancethat this measure has been successful,since 85% of the real estate agenciescomply with the obligation. The EPC hasconsequently gained high visibility.

Looking more closely, several positiveeffects of these requirements can bebrought out. First of all, it forces theowner to have an EPC issued, withoutwhich the estate agent will not put thebuilding on sale (or for rental). Indeed,before the enforcement of this measure,it was very common to have the EPCissued only a few days before the sale wasconcluded and the new owner was giventhe EPC only after that. Such behaviourfrom owners is no longer possible.

The potential buyer can now effectivelycompare several buildings in terms ofenergy performance, which is one of theoriginal goals of the EPC. Displaying it on

Figure 12: Organisation of participants in AC inspection scheme.

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advertisements has also increased theconsumers’ awareness of the EPC,contributing to its recognition.Furthermore, it has led consumers toestablish a dialogue with real estateagents about the EPC and to take note ofthe full four‐page EPC file.

Along with increasing consumers’awareness, this measure has also broughtgreater visibility to the most energyefficient buildings. In some areas this haseven translated into an increase of thevalue of such buildings; it is importantthat this raise of value can be balancedout thanks to the PTZ + (Prêt à taux zéro +),a 0% loan intended for buyers of energyefficient buildings. On the other hand, lowclass building owners are now encouragedto perform thermal renovation in order tocompete with efficient buildings,especially in unattractive areas. Theowners can also choose to lower the saleprice of their building. This second optionusually leads to the new owner having athermal renovation carried out with thehelp of financial incentives such as the 0%Eco‐Loan and the Tax benefit ‘SustainableDevelopment’. In the case of a majorthermal renovation both incentives aregranted.

In addition to official penalties for lack ofan energy performance indicator inadvertisements, the biggest sanctioncomes from the consumers themselves.Indeed, thanks to the numerous pressarticles published in both mainstream andspecialist press along with the help ofmost real estate agencies to pass theinformation, people are well aware of thismeasure. The EPC has now becomecommon practice. Consequently, anadvertisement without EPC seems rathersuspicious, and in non‐competitive areasit is put aside by most consumers.

Displaying the EPC in advertisements hasbeen a great success since the tool hasgained in visibility, but also inunderstanding. More and more people

think of the EPC as one of the mostimportant tools to help them make theirchoice. Moreover, the recommendationsare used to direct and orientate thermalrenovation, leading to the increase of thenational real estate efficiency.

4. Conclusions, future plans

Even though the Energy Performance ofBuildings Directive (EPBD) is now fullytransposed, France has the will to positionitself at the forefront of energyperformance in buildings, and plans tomake sustainable development the drivingforce of national growth. This will isexpressed by several measures to betaken in the short or medium term.

A new bill, called ‘energy transition for agreen growth’, was examined by theFrench Parliament at the end of 2014.Among many provisions relating to energyand the environment, there are somewhich concern buildings’ performance.

The next significant step of the Frenchthermal regulation, set for 2018, will beenergy positive buildings, since they willbe at the core of the new regulation.Preliminary work for this regulation willstart in early 2015. In addition and inorder to promote the Government’sexemplary role, a measure included in the‘energy transition’ bill stipulates that allnew public buildings should be energypositive whenever possible. It will alsogive construction professionals theopportunity to improve their skills in theconstruction of very high energyperformance buildings and to get readyfor 2018.

There is also a continuous assessment ofthe tools and measures by the ministrywith studies evaluating the reliability ofthe calculation, or through constantcontact with professionals, with the goalto identify and correct any dysfunctionalpoints in the EPBD implementation.

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The sole responsibility for the content of this report lies with the authors. It does notnecessarily reflect the opinion of the European Union. Neither the EASME nor theEuropean Commission are responsible for any use that may be made of the informationcontained therein.

The content of this report is included in the book “2016 – Implementing the EnergyPerformance of Buildings Directive (EPBD) Featuring Country Reports”,ISBN 978‐972‐8646‐32‐5, © ADENE 2015

More details on the IEE Programme can be found atec.europa.eu/energy/intelligent

This individual report and the full 2016 book are available atwww.epbd‐ca.eu and www.buildup.eu

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