Eurovent strongly supports policy option 3 to inscribe the ambition of the Renovation Wave initiative into legislation. The review should also focus on mainstreaming indoor environmental quality (IEQ) considerations into the Directive, for which a dedicated stakeholder workshop on IEQ should be convened. Eurovent makes the following specific suggestions for improvement:
- Better implement and enforce the requirements on long-term renovation strategies.
- Revisit the flexibility allowed for transposition, converge towards harmonised models.
- Introduce EU-wide Minimum Energy Performance Standards.
- Align the Ecodesign framework and the EPBD.
- Add IEQ aspects to technical building system requirements.
- Make access to funds for building renovation conditional upon IEQ criteria.
- Improve the EPC framework and include mandatory IEQ and SRI indicators in the EPC.
- Mandate the inspection of ventilation systems, add IEQ aspects to all inspections.
- Include information requirements related to IEQ.
- Make air quality objectives explicit in the review.
