To the kind attention of Kadri SIMSON 

Minister for Economic Affairs and Infrastructures of Estonia

Cc: EU27 Energy Ministers, European Commissioner Miguel Arias Cañete and Bendt Bendtsen MEP 

Brussels, 1 December 2017

Dear Minister, 

I am writing to you on behalf of the European Alliance to Save Energy (EU-ASE). EU-ASE is a multi-sectoral business organisation whose members have operations in your country and across the 28 Member States of the European Union, employ 340.000 people in Europe and have an aggregated annual turnover of €115 bn.

Considering the strategic relevance of the ongoing negotiations between the Council, the European Commission and the European Parliament on the Energy Performance of Buildings Directive (EPBD), we count on your full support for an ambitious revision of this key Directive, as put forward in the report adopted by the European Parliament on 11 October.

The revision of the EPBD is a unique opportunity to strengthen the business and investors’ confidence in the building sector to further develop a comprehensive approach to their efficiency (by looking both at optimized energy supply and their energy consumption) and to put new and existing buildings’ performance at the centre of the EU’s energy transition.

We call on you to include the following key provisions in the final legislative text:

• • Enrich long-term national renovation strategies with the inclusion of a 2050 objective, a differentiation of building typologies, the addition of trigger points, the concept of voluntary building renovation passport to support staged deep renovation, milestones in 2030 and 2040 and measurable progress indicators. Only credible and robust renovation strategies will incentivize private investments, facilitate access to financial tools and hence boost the very low buildings’ renovation rate;
• • Set a mandatory requirement for the equipment of building automation and control in non-residential buildings by 2023 to reflect the latest technological developments and enable buildings’ connectivity to the energy system. Ensure effective controls and monitoring in large residential buildings; enshrine appropriate control functionalities in individual rooms;
• • Require that the overall energy performance of the complete altered technical building system is assessed at part load;
• • Set a mandatory framework to define and implement the Smartness Indicator in all Member States on the basis of a design/methodology set in Annex Ia, while ensuring its complementarity with Energy Performance Certificates;
• • Ensure consistency in Annex I with the Energy Efficiency First principle through adequate consideration of energy needs in the energy performance calculation as well as the equal treatment for on-site and off-site renewables. In fact, it is essential to support an energy transition where both high energy efficiency solutions and integration of renewables are working together in a mutually reinforcing manner.

The EPBD is a key piece of legislation to enable the transition towards a smarter and more efficient building stock; it must not be set aside from the rest of the Clean Energy Package.

We trust you will take in due account our recommendation to go in the right direction, as set by the report adopted by the European Parliament.

Yours sincerely,

Monica Frassoni

President of the European Alliance to Save Energy (EU-ASE)

Brussels, 27 November 2017

Dear ITRE Member of the European Parliament,

We are a group of cross-sectorial companies bringing technologies and services for energy efficiency to the EU market, having factories and office locations in all EU28 Member States.

We would like to urge you to support the Compromise Amendments 1, 4 and 11b on the Revision of the Energy Efficiency Directive (EED) to be voted on 28 November in ITRE Committee.

The EU energy efficiency legislative framework post-2020 is fundamental for giving certainty and predictability for investors as in Europe 76% of the financial effort for meeting the Paris Agreement ambition must be in energy efficiency.
The EU 2030 binding 40% energy efficiency target and the continuation of the annual 1.5% energy saving obligation after 2020 are adequate to respect the EU commitments to the Paris Agreement and will unlock the cost-effective potential of energy efficiency investments in buildings and in the entire energy system. Decreasing this ambition would set policy goals below the business-as-usual energy efficiency improvement trajectory and will have no impact on the ground.
The Compromise Amendments 1, 4 and 11b give full flexibility to Member States to adapt the energy saving obligation to their national contexts by choosing obligation schemes and/or alternative measures.
Investments in energy efficiency create essential multiple benefits for our economies, creating local jobs, increasing energy productivity and competitiveness. Energy savings achieved through energy efficiency investments are an enabler of sustainable growth and the energy transition. Decoupling GDP growth and reduction in energy consumption is already a reality and the revised EED must ensure we keep and further support this trajectory.
We welcome the efforts by the European Parliament on the revision of the Energy Performance of Buildings Directive (EPBD) and consider that consistency and alignment with the EED should be ensured.
We trust that you will support these much-needed enabling policy measures in the revision of the EED, effectively embodying the “Energy Efficiency First” principle.

Dear Ambassador,

I am writing to you on behalf of the European Alliance to Save Energy (EU-ASE), a multi-sectoral business organisation whose members have operations across the 28 Member States of the European Union, including in your country. Our members directly employ 340.000 people in Europe and have an aggregated annual turnover of €115 bn.

We would like to underline the importance of the Energy Union Governance 2030 Regulation for businesses. Robust and straight forward governance in the realms of climate and energy is a key driver for any future business decision because it guarantees an adequate implementation of EU energy efficiency legislations, thus providing certainty and predictability. For the energy efficiency sector, this will strengthen businesses’ engagement, while setting the EU on track to reach its 2030 energy and climate targets and the Paris Agreement commitments.

We consider the ongoing discussions on the Energy Union Governance 2030 Regulation in the Council of strategic relevance. Therefore, we call on you to consolidate in the Regulation the ‘energy efficiency’ dimension and provisions related to the Energy Efficiency Directive (EED) and the Energy Performance of Buildings Directive (EPBD). Together, and if the current legislative procedure will be able to produce an ambitious result on their revision, they set the right framework to boost private investments and incentivise innovative financing models such as Energy Performance Contracting, which can reduce the need for public financial support in building renovations. Specifically, the following elements are key to reinforce Europe’s commitment to energy efficiency:

• maintain the binding nature of the EU 2030 energy efficiency target to strengthen investors’ confidence and set a stable legislative framework;

• ensure comparability of the Integrated National Energy and Climate Plans by supporting binding templates and a sufficient level of specific provisions for implementation at all levels;

• adopt clear and binding benchmarks and rules in case of an ambition gap as well as swift and credible measures in case of a delivery gap;

• integrate and mirror the key provisions of the long-term renovation strategies included in the currently revised EPBD in the National Integrated Energy and Climate Plans and in the Long-Term Low Emission Strategies, to ensure consistency in planning policies, setting a clear and coherent EU 2050 pathway and to unlock the necessary financing.

We call on the upcoming COREPER meeting on the Energy Union Governance 2030 Regulation to ensure a coherent legislative framework for energy efficiency is set.
EU-ASE is at your disposal in the forthcoming weeks to discuss the strategic importance of a solid EU regulatory framework for energy efficiency.
Yours sincerely,
Monica Frassoni

Dear Professor Gierek MEP, dear ITRE and ENVI Members of the European Parliament,

RE: More than 50 companies and business organisations unite in a strong call for an ambitious and comprehensive Energy Efficiency Directive (EED) to secure and stimulate investments in Europe.

The Clean Energy Package for All Europeans is a unique opportunity for the EU to show leadership and consistency in view of the implementation of the Paris Agreement. The most cost-effective way to meet our global commitments, achieve the objectives of the Energy Union and make Europe more competitive is to implement the “Energy Efficiency First” principle.

In this sense and ahead of the forthcoming ITRE Committee vote on the EED, a multi sectoral group of companies unite in a call to:

• Support the binding nature of the EU target to strengthen investor confidence;
• Increase the level of ambition of the target to a cost-effective 40% by 2030, expressed both in primary and final energy terms to ensure a holistic approach to energy efficiency investments and services and provide a legal basis to the promotion of both end-use and generation and distribution efficiency;
• Extend the 1.5% national energy savings obligation based on annual energy sales to final customers beyond 2020, eliminate loopholes and design energy efficiency obligation schemes and/or alternative policy measures that are in line with the “Energy Efficiency First” principle.

The positive impact of such measures is supported by strong evidence. A recent report published by the European Commission1 has outlined, once again, that energy efficiency can achieve up to 46.6% GHG emission cuts in 2030, increase EU’s GDP by 2.2%, create 2 million new jobs, save €77 billion in annual healthcare costs and lift millions of households out of energy poverty.

In this regard, energy efficiency is a clear business opportunity with a high return on investment and requires a solid regulatory framework that will provide incentives to all involved stakeholders.

Among the legislative dossiers proposed by the European Commission in November 2016, the reviews of both the Energy Efficiency Directive (EED) and the Energy Performance of Buildings Directive (EPBD) represent a major opportunity to strengthen the business and investors’ confidence.

The building sector, together with transport, represents the highest end-use savings potential according to in-depth evaluations2. And in its recent vote on the EPBD review, the European Parliament recalled its ambition to increase the rate and depth of building renovations benefitting consumers through lower consumption, lower bills and improved living conditions.

Yet for this to become reality, a fully coherent legislative framework is required with a matching ambition in the EED.

We trust that you will support these much needed policy measures through an ambitious revision of the EED, effectively embodying the “Energy Efficiency First” principle.

Dear Minister,

Re: Leading energy efficiency companies call for an ambitious revision of the Energy Performance of Building Directive (EPBD) during forthcoming legislative negotiations between the European Parliament and the Council of Ministers. 

I am writing to you on behalf of the European Alliance to Save Energy (EU-ASE). EU-ASE is a multi-sectoral business organisation whose members have operations in your country and across the 28 Member States of the European Union, employ 340.000 people in Europe and have an aggregated annual turnover of €115 bn.

We are writing to you to call for your full support for an ambitious revision of the Energy Performance of Buildings Directive (EPBD), considering the strategic relevance of the ongoing discussions on energy efficiency in the Council and the forthcoming negotiations with the European Parliament.

We are convinced that an ambitious revision of the EPBD is possible and can put existing buildings at the centre of the EU’s energy transition; all the more so after the Committee on Industry, Research and Energy at the European Parliament adopted with a large majority the ambitious report of Mr Bendt Bendtsen. The EPBD has the potential of addressing EU and national key priorities such as job creation, economic growth, improved health and energy security. A strong EPBD will also strengthen the business and investors’ confidence in the construction sector.

In this context, we would like to draw your attention on the recently revised Guidance Note on the recording of Energy Performance Contracts (EPCs) in governments’ accounts. The revision of the Guidance Note will greatly increase the possibilities for public bodies to use such contracts, by clarifying the criteria by which EPCs can be recorded off government balance sheets.

We are aware that the Italian government played an important role to remove this key barrier to investing in energy efficiency in public buildings.

The updated accounting rules are particularly important for countries like Italy, as they could further enhance the considerable potential for relaunching the construction sector – which was so heavily affected by the economic crisis – and improve the energy performance of the Italian building stock.

We also hope that the new Guidance can contribute to facilitate reaching a more positive and ambitious positioning by the Council in the up-coming negotiations, notably concerning four key priorities:

– Set an adequate framework for effective national long-term renovation strategies, that will boost private investments and will incentivize financing models, such as EPCs;

– Provide meaningful improvements for provisions related to technical building systems;

– Provide a comprehensive consideration of both energy efficient energy demand and supply solutions and services;

– Establish a clear and coherent EU 2050 pathway towards a highly efficient and decarbonized building stock.

For the business community, a consistent legislative framework is needed to open up markets for a broad variety of energy efficient technologies and solutions ranging from services enabling enhanced management of buildings to insulation, and from on-site and off-site heating and ventilation systems to lighting and control systems.

We trust you will take into account our recommendations and we are ready to meet you and further discuss in the forthcoming weeks the strategic importance of a solid EU regulatory framework for energy efficiency in buildings for the Italian and European economy.

More information about our positions on the EPBD are available in our Position Papers.