Representative image of a residential building. Image: Canva
Building Modernization Act: natureplus statement
natureplus position paper on the draft Building Modernization Act (GModG)
Preliminary note on the process: Democratic deficit in legislation
natureplus e.V. strongly protests the manner in which participation in this draft law has been handled. The non-public invitation to comment and the extremely short deadline deprive civil society and professional associations of the opportunity for a thorough review. A law intended to set the course for the construction transition for decades to come must not be pushed through behind closed doors and in a rush. This approach undermines the requirements for a transparent, democratic legislative process and puts non-profit organizations at a particular disadvantage compared to well-funded industry lobby groups.
1. Fundamental assessment
The current draft of the GModG falls far short of the necessary ecological transformations. While life cycle assessment (LCA) is formally introduced, the law remains ideologically fixated on new construction and isolated technical solutions, rather than recognizing existing buildings as our most valuable resource.
2. Key criticisms and demands
A. Life cycle assessment (§ 88b): Progress without steering effect
- Criticism: The introduction of a mandatory LCA is a long-overdue paradigm shift. However, in its current form, it remains a toothless tiger. The draft merely provides for a reporting obligation but fails to set binding limit values for greenhouse gas emissions during the construction phase. Without such caps, the LCA remains a bureaucratic exercise with no steering effect on material selection.
- Demand: Immediate coupling of the LCA with binding maximum values for "embodied carbon."
B. Neglect of renovation and preservation of existing buildings
- Criticism: The GModG sets the wrong priorities. While complex requirements are defined for new construction, there is a lack of a clear preference for preserving existing buildings. The draft indirectly encourages climate-damaging demolition and replacement construction, as the ecological advantages of renovation over new construction are not sufficiently privileged by law.
- Demand: Introduction of a "demolition moratorium through mandatory assessment." Every demolition project must demonstrate that a replacement building, including its embodied energy, is ecologically more advantageous than a renovation.
C. Material Ecology and Healthy Living
- Critique: The focus on CO₂ equivalents in LCA neglects material quality. Sustainability also means healthy living and circularity. The draft fails to provide incentives for non-toxic, renewable raw materials that can be easily returned to the material cycle at the end of their life cycle.
- Demand: Material requirements for construction products must go beyond the pure GHG balance and incorporate criteria such as low pollutant levels (VOC limits).
D. The "Bio-Staircase" as a fossil fuel lifeline
Critique: Diluting the 65% renewable energy requirement with the "bio-staircase" is a step backward. It suggests an availability of biogenic fuels that does not exist for the broad heating market and delays the necessary focus on the energy-efficient retrofitting of the building envelope.
3. Conclusion
In its current form, the GModG is not a modernization act, but an instrument for perpetuating the status quo. natureplus calls for a fundamental revision that places existing building protection at the center, supports LCA with strict limit values and recognizes the material quality of building materials as an equivalent protection goal.