To the kind attention of the Group Leaders of EPP, S&D, ECR, ALDE, GUE/NGL, Greens/EFA 

Cc: EED review Rapporteur and Shadow Rapporteurs 

Harry Verhaar 

Chairman of the Board of Directors

European Alliance to Save Energy (EU‐ASE)

Brussels, 15 January 2018

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 across the 28 Member States of the European Union, employ 340.000 people in Europe and have an aggregated annual turnover of €115 bn.

This week the Plenary of the European Parliament will vote on the report on the revision of the Energy Efficiency Directive (EED): this will be the last opportunity to set higher negotiating requests before trilogue starts with the Council, which has already adopted a weak position on this file in June, during the Maltese EU Presidency.

The vote has a strategic relevance for the business community and will have a long-term impact on investments and sustainable growth in Europe.

Investments in energy efficiency create multiple benefits for our society, improve energy productivity and increase the competitiveness of the European economy. Energy efficiency provides consumers with tangible benefits through reduced energy bills, creation of local jobs, improved air quality and comfort, and strengthened overall energy security.

In this perspective, the EU 2030 binding 40% energy efficiency target and the continuation of the annual 1.5% energy saving obligation after 2020 are two necessary and adequate measures to help the EU to meet its Paris Agreement commitments and strategically unlock the full cost-effective potential of energy efficiency investments in the entire energy system.

Any attempt to weaken these targets would mean to set policy goals below the business-as-usual energy efficiency improvement trajectory and will have no real-life impacts.

As such, we would like to reiterate that, far from imposing a burden on our economies, these targets are essential to create the needed certainty for investors and a common sense of direction enabling consistent investments and progress toward ambitious milestones.

With this in mind, we urge you to thoroughly consider the political relevance of the forthcoming vote on the EED revision and defend the report as adopted in ITRE Committee.

We would be extremely supportive of a vote on the EED revision, which is fully coherent with previous positions adopted by the European Parliament, is aligned with the satisfactory compromise on Energy Performance of Building Directive (EPBD) reached by co-legislators, and is consistent with the ongoing effort to simplify public government accounting rules to foster energy efficiency investments.

Yours sincerely,

Harry Verhaar

Brussels, 5 December 2017

Dear Member of the European Parliament,

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. Our members directly employ 340.000 people in Europe and have an aggregated annual turnover of €115 bn.

The Energy Union Governance 2030 Regulation is key for businesses.

We would like to urge you to support the Compromise Amendments 2A, 6A, 18A, 31A and 45 on the Regulation on Energy Union Governance to be voted on 7 December in a joint ITRE-ENVI Committee meeting. 

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 investments taken by public and private stakeholders. 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.

A robust framework should include the following elements:

1. A definition of Efficiency First to uphold the Commission’s promise to make Energy Efficiency First the guiding principle across the five dimensions of the Energy Union (CA 2A);

2. Linear trajectories made of biennial interim targets to ensure stable flow of investments over the period and adopt clear, responsive and credible measures in case of a delivery gap (6A and 31A);

3. To include in the Long-Term Low Emission Strategies the key provisions and mechanisms of the long-term renovation strategies as foreseen in the revised EPBD, to ensure consistency and comparability in planning policies, setting a clear and coherent EU 2050 pathway and to unlock the necessary financing (CAs 18A and 45).

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 a chief enabler of sustainable growth and the energy transition.

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

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

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