Legislators push for greater energy efficiency
Sustainability is high on the political agenda of many governments, as reflected in numerous national laws and regulations as well as international agreements and treaties. Property companies need to be aware of this mass of legislation when making investment decisions and managing their properties. It is also important to monitor ongoing legislative processes very closely in order to assess impacts at an early stage.
Ambitious objectives
The current German government has made energy transition one of its key initiatives. In addition to withdrawing from nuclear power and expanding the renewable energy sector, energy saving is the second pillar of this policy. Against this backdrop, the government launched its National Action Plan for Energy Efficiency (NAPE) during the current legislative period.
Property companies are particularly heavily affected by the German government's objective of reducing primary energy consumption in Germany by 20 per cent compared with 2008 levels by 2020, and of halving consumption by 2050. Buildings are the largest final energy consumers in Germany, with a share of almost 40 per cent. The German government has set itself the ambitious target of achieving a nearly "climate neutral" building stock by 2050.
Nearly zero-energy standard planned
For the commercial property sector, it is vital to keep sight of the National Action Plan for Energy Efficiency (NAPE), the third version of which was passed by the German cabinet on 18 June 2014. The individual measures in the plan include the Energy Saving Ordinance (EnEV), which has been in effect since 2002. The most recently amended version, EnEV 2014, came into force on 1 May 2014. Alongside tightening the rules on energy performance certificates, it imposes tougher energy requirements on new builds from 2016. Standards for energy efficiency upgrades of old buildings were also raised. EnEV is due to be amended again in 2016 to introduce a nearly zero-energy standard for new builds in accordance with the EU Buildings Directive. The new standard will apply to private buildings from 2021 and come into force for public buildings in 2019.
At European level, the EU agreed specific energy saving targets in 2007 as part of its climate policy. These include a 20 per cent reduction in primary energy consumption within the Union by 2020 (relative to 1990). This is the context behind the EU Energy Efficiency Directive, which obliges member states to ensure that all commercial companies, with the exception of small and medium-sized companies (SMEs), conduct an energy audit by no later than 5 December 2015 and thereafter at least every four years. These energy audits must also take account of the energy consumption of buildings.
In order to transpose the EU Energy Efficiency Directive into national law, the German Act on Energy Services and other Energy Efficiency Measures (“EDL-G”) has been amended accordingly.
Real estate industry accepts the challenge and formulates requirements
While Union Investment expressly supports saving energy and boosting energy efficiency as part of its own company philosophy, the effectiveness of some NAPE measures is debatable. In particular, many measures tailored to residential property cannot be applied unchanged to commercial buildings. Close cooperation with relevant industry bodies could help to avoid these difficulties.
As the voice of the German real estate industry, the German Property Federation – of which Union Investment is an active member – has already formulated a number of policy requirements and defined problem areas with regard to the National Action Plan for Energy Efficiency. From an industry perspective, it is essential to ensure that all planned measures take account of commercial constraints. Not everything that is technically possible is also economically viable.
The ZIA sees a crucial need for politicians and the industry to develop KPIs and benchmarks that reflect the diversity of properties, since reliable figures are essential for making comparisons and taking appropriate policy decisions. The German Property Federation and its member companies have already done some valuable groundwork in this regard.
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