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Til horingen: Høring - forslag til nytt direktiv for bygningers energiytelse (EBPD)

The Norwegian Directorate for Cultural Heritage

Departement: Familiedepartementet 1 seksjoner
Regarding The EPBD/ Directive on the energy performance of buildings (recast) as presented by the European Commission with the reference COM (2021) 802 final.

To meet Norway's climate goals and obligations to which we are committed by the Paris Agreement, there is a need for immediate emission cuts and the implementation of climate measures - with rapid effect.

There is a risk of losing irreplaceable cultural heritage values ​​and real climate gains, which the reuse and proper restoration of older existing buildings constitute. We know that conservation, upgrade, and energy efficiency of existing buildings and the use if traditional building parts can contribute to reducing greenhouse gas emissions. Historic buildings can be made considerably more energy efficient without losing cultural-historical values.

Through the project Preserve construction - preserve climate Innlandet County Municipality looked at climate-neutral community development. Historic buildings and building environments were given lasting life, increased use value and lower energy consumption through various measures, and reduced the need for new constructions. As part of the project, energy consumption and greenhouse gas emissions were calculated for 24 different buildings. It showed that climate benefits can be achieved with continued use and upgrade. The findings are stated in the report Greenhouse gas emissions from upgrades of old buildings, prepared by Asplan Viak. For most of the buildings, the report concludes that upgrade gives lower greenhouse gas emissions than to demolish and erect a standard new building that meets current regulatory level. Furthermore, the project shows that the energy gain per invested krone is significant larger for upgrades than for demolition and new construction, and - the point - that gentle upgrading can provide significant energy saving without compromising conservation considerations and architectural qualities. See also our report from SINTEF researcher on the climate effect of conserving and reusing existing buildings ( https://www.riksantikvaren.no/wp-content/uploads/2021/12/RA_SINTEF_ENGELSK_21.09.2021.pdf ).

Input to the directive at hand

The Norwegian Directorate for Cultural Heritage wishes to comment on the following

Best regards, Anne Judith Munthe Kaas

The Norwegian Directorate for Cultural Heritage