So you want to say you are building a Kfw55 only with gas, without solar thermal support and without controlled residential ventilation with a building permit after 01.01.2016
So getting below 51 for the PE is already not easy. But getting below 35 for the PE ops:
No, we naturally have a controlled residential ventilation system, otherwise in my opinion that is definitely not possible. We were only able to save on the solar we did not want through a somewhat improved building envelope.