To: Miguel Arias Cañete, Commissioner for Climate Action & Energy

Brussels, 5 June 2019

National Energy and Climate Plans

Pledging low on energy efficiency slows down the energy transition

Dear Commissioner,

The Energy Union is putting energy efficiency at its fore front. So must Member States if the energy transition is to become fast, fair and attractive. We agree that it is an important success that all 28 Member States have come forward with their draft NECPs in short time, but their quality leaves room for improvement.

A broad range of stakeholder analysis showed how the draft plans do not match legal requirements nor expectations. Our own initial assessment revealed that national energy efficiency contributions only reach 27.6% (primary energy) and 30.2% (final energy), well off the EU’s target of at least 32.5% energy efficiency by 2030. Also, the energy efficiency first principle has not been applied to inform energy infrastructure planning.

We noticed in several plans a tendency to be optimistic on economic growth, while shying away from taking strong action on energy efficiency. Exaggerating energy demand and ignoring the energy efficiency potential is not a smart risk hedging strategy. It will jeopardise energy efficiency investments, which are urgently needed to deliver additional greenhouse gas emission reductions, affordable quality housing, clean transport, local jobs and economic growth. This is a dangerous recipe which speeds up the climate and social crisis.

Through the publication of the recommendations on the draft NECPs at the end of June, the European Commission has a key role to play in encouraging governments to increase their contributions and close the 2030 target gap. It is important to remind Member States that they need to build on the successful EU energy efficiency policies and measures and plan for new national ones that will accelerate action and restore a decreasing trend in energy consumption.

Therefore, we call on you to be encouraging and bold in your recommendations for improving the NECPs, particularly on energy efficiency and show determination in protecting the achievements of the Energy Union.

Yours sincerely,

Stefan Scheuer, Secretary General 2

The Coalition for Energy Savings strives to make energy efficiency and savings the first consideration of energy policies and the driving force towards a secure, sustainable and competitive European Union. Its membership unites businesses, professionals, local authorities, cooperatives, consumer and civil society organisations in pursuit of this goal.

Coalition members represent:

• more than 500 associations, 200 companies, 1,500 cooperatives
• 15 million supporters and 1 million citizens as members of cooperatives
• 2,500 cities and towns in 30 countries in Europe

Members of the Coalition:

ACE – Architects’ Council of Europe | APPLiA – Home Appliance Europe | BEUC – The European Consumer Organisation | BPIE – Buildings Performance Institute Europe (advisory member) | CAN – Climate Action Network – Europe | CEE Bankwatch Network | ClientEarth | Climate Alliance | E.V.V.E. – European Association for the Consumption-based Billing of Energy Costs | E3G | eceee – European Council for an Energy Efficient Economy | ECOS – European Environmental Citizens Organisation for Standardisation | EEB – European Environmental Bureau | EFIEES – European Federation of Intelligent Energy Efficiency Services | ehi – Association of the European Heating Industry | Energy Cities | EPEE – European Partnership for Energy and the Environment | eurima – European Insulation Manufacturers Association | EuroACE – The European Alliance of Companies for Energy Efficiency in Buildings | European Alliance to Save Energy | European Climate Foundation | European Copper Institute – Copper Alliance | Friends of the Earth Europe | Glass for Europe | Housing Europe | PU Europe – European Association of Polyurethane Insulation Manufacturers | RAP – The Regulatory Assistance Project (advisory member) | REScoop.eu | T&E – Transport & Environment | WWF European Policy Office

1. Commit to accelerate actions to reduce greenhouse gas emissions by 2030 and reach net zero emissions as soon as possible.

The world is not on track to keep temperature rise to 1.5°C. We support the call from United Nations Secretary General António Guterres, upon all leaders to come to his special UN Climate Summit in September with additional commitments that will lead to halving global emissions by 2030 and achieving net zero  by 2050. By the Summit, EU leaders should agree to reach climate neutrality in line with the EU’s fair share of the effort to achieve net zero global emissions by 2050. Furthermore, EU leaders must agree on a plan to substantially increase its 2030 targets.

2. Plan the end of the use of fossil fuels and provide strong support to energy efficiency, renewable energy and emission cuts outside the energy sector

Our economic development no longer depends on fossil fuels. In fact, energy efficiency and renewable energy technologies have become cheaper and are more beneficial for all. EU decision makers need to plan to phase out coal, gas and oil use, starting with immediately ending all financial support to fossil fuel infrastructure. At the same time, they need to  increase support to research, innovation and deployment of clean alternatives, including through prioritising energy efficiency across all sectors and investing in sustainable renewable energy. Ambitious climate and energy targets should be complemented by stronger immediate action in all sectors to achieve quick emission cuts.

3. Safeguard a just and fair transition and ensure that the EU increases its support to developing countries to mitigate and adapt to climate change

The zero emissions transition needs to be just, orderly and fair, benefiting everyone and leaving no one behind. This should be done by integrating strong social measures, supportive industrial and business policies and safeguarding workers’ and human rights. Regions that are still highly dependent on fossil fuels, as well as regions highly affected by climate change, such as maritime regions, should be supported in this transition. Europe must also substantially increase its financial and other support for climate action and resilience in developing countries, which are being hardest hit by climate change.

4. Increase efforts to roll out the circular economy and increase resource efficiency

We live on a resource-constrained planet where using resources efficiently is necessary for continued prosperity and well-being. The EU should build circularity and resource efficiency into all future policies to facilitate the efforts to decarbonise all economic and industrial sectors.

5. Recognise biodiversity protection and ecosystem restoration as a crucial component of climate action

The zero emissions transition cannot happen without substantial investments in the restoration of our ecosystems. This must include efforts to protect and improve the natural capacity of forests and soils to absorb past and present carbon pollution, while promoting sustainable practices, within the EU and beyond our borders.

Time is running out and the urgency to act is crystal clear. Citizens, regional and local authorities, financial institutions, businesses, and other stakeholders are mobilising and acting at their level in every possible way to call for more climate action.

Now, more than ever, we look to our governments to govern, to set the necessary rules, targets, policies and measures to protect citizens in the EU and elsewhere from the negative impacts of climate change, and reap the full social, economic and environmental benefits of the transition.

To: EU Heads of State and Government

CC: President Juncker

Commissioner Arias Cañete

Brussels, 16 March 2019

We are writing to you on behalf of an alliance of European businesses, associations, investor groups, trade unions, local and regional authorities, and civil society organisations.

Unprecedented citizen mobilisations are taking place across EU member states calling for increased action against climate change, showing that climate action is an integral element of the future of Europe and that increasing the EU’s commitments under the Paris Agreement is an urgent necessity.

At the upcoming European Council on 21 March you have been invited to discuss these commitments, in particular the Commission’s vision for a climate neutral economy.

We welcome the Commission’s proposal to reach climate neutrality by 2050 at the latest.  As indicated by the Commission’s analysis, based on existing technologies and solutions, the just transition towards a net-zero emissions economy is feasible and provides numerous economic, environmental and social co-benefits. These include health for citizens, additional jobs, increased competitiveness and energy security, and more sustainable economic development.

Representing stakeholders from across sectors and across Europe, we believe it is high time for European leaders to rise up to the challenge of climate action. We need Europe to transition to a sustainable society and economy as soon as possible. Member states can count that our organisations, businesses, cities, regions, and trade unions will continue leading the transition to a zero-carbon Europe. We count on your leadership and determination to ensure a safer future for European citizens.

Therefore, in light of your upcoming discussions, we urge you to:

• Endorse the objective of net-zero greenhouse gas emissions by 2050 at the latest, as part of the future of Europe vision, at the special EU Summit in Sibiu in May 2019.
• Acknowledge that reaching net zero greenhouse gas emissions in 2050 in the most cost-effective manner requires raising and aligning the 2030 ambition level at the latest during the UN Climate Summit in New York in September 2019.
• Send a clear message that the EU stands ready to review its 2030 contribution to the Paris Agreement.

We hope that you will take these points into consideration during your discussions at the European Council and we remain at your disposal to further discuss ways to deliver an inclusive and sustainable climate transition in Europe.

To the kind attention of Ambassador Luminita Teodora Odobescu

Permanent Representative of Romania to the EU

Cc 27 Permanent Representatives and Deputy Permanent Representatives to the EU

Brussels, 14 March 2019

Dear Ambassador Odobescu,

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 operate across the 28 Member States of the European Union, with an aggregated annual turnover of €115 bn, directly employing 340.000 people in Europe.

The post 2020 Multi Annual Financial Framework (MFF) is a unique opportunity for the EU to demonstrate coherence with its long-term energy and climate objectives and show commitment to deliver tangible benefits to European citizens.

For the businesses community, the post 2020 MFF, including InvestEU, ERDF/CF and CPR Regulations, is a necessary trigger for outlining the much-needed long term political direction for mobilizing private investments towards a decarbonized European economy. InvestEU, ERDF/CF and CPR Regulations must give the right political signal to stimulate investments in clean technologies, and in particular in cost-efficient energy efficiency projects, which will only get unlocked if the EU provides clear direction and long term certainty to the private sector.

The impact that Regulations such as InvestEU, ERDF/CF and CPR can have in terms of employment creation, mainly youth employment, is also significant. In order to implement a sustainable energy transition, there will be a large additional demand for workers with different types and levels of qualifications, ranging from lower skilled workforce to highly skilled professionals. This is an opportunity that should not be missed, especially for regions that are suffering from high rates of unemployment, and those that will have to go through a challenging transition pathway.

According to the European Commission reflection paper on the 2030 vision[1], in Europe there are currently nearly 1.5 million jobs in renewables and energy efficiency. Industries operating in the area of building refurbishment represent more than 3.4 million jobs and the Commission impact assessment for the Clean Energy Package stated that there is a potential to create an additional 900.000 jobs by 2030, provided that public and private investments are sufficiently mobilised. Of these, up to 400.000 additional local jobs could come from the energy efficiency sector.

In view of the current and future trilogues negotiations on InvestEU, ERDF/CF and CPR we urge you to:

InvestEU

• Support the climate mainstreaming target of at least 40% and the earmarking of 65% in the sustainable infrastructure window for Paris-aligned investments as proposed by the European Parliament

The scale of the challenge posed by climate change and its devastating impact on the economy, society and the environment requires substantial public resources to mobilize the necessary private investments.

• End new fossil fuel investments and align investments with climate objectives

We welcome the sustainability proofing mechanism introduced by the European Parliament and the strong language on the need to orient investments to reach climate goals. We do not support fossil fuel exceptions (ref. Annex V) that would allow technological lock-in and short-sighted investments in new gas and coal infrastructures.

InvestEU should instead mobilise investments in energy efficiency improvements to unleash the multiple and collective benefits of energy efficiency in areas with high potential such as buildings.

• Prioritize energy efficiency, promote the Energy Efficiency First principle and support the European Parliament language in Art.7 concerning efficiency and buildings renovations

In the current Partial General Agreement of the Council, energy efficiency is only mentioned in recital and annexes. This means overlooking the energy efficiency potential across all sectors and its multiple benefits for citizens, businesses and the environment as a whole. Without stepping-up investment to first reduce energy consumption and only then generating the remaining energy demand from renewable sources, it will not be possible to achieve climate neutrality by 2050, while avoiding significant misallocation of resources.

ERDF/CF

• Increase to 40% the overall target of ERDF/CF expenditure supporting climate objectives

Such increase is necessary taking into account the magnitude of the climate change challenge and the level of support required to achieve climate neutrality by 2050.

• Prioritize investments in energy efficiency (both on the energy demand and supply sides) in all sectors

To prioritize energy efficiency investments, ERDF and Cohesion Fund Regulation should fully apply the Energy First principle and therefore embed the principle to first assess the economic opportunity to reduce energy consumption through cost effective energy efficiency solutions before investing in new sustainable supply capacities. In our view, all investment decisions in the field of energy and climate change must be guided by long term decarbonisation objectives.  Faced with the challenge of scarcity, public resources should be spent in the most intelligent, efficient and effective way, paying due attention to aspects such as just transition, and prioritizing areas with the highest economic, societal and environmental value.

• Exclude investments in new fossil fuels infrastructures

It does not make economic and environmental sense to invest in new fossil fuels infrastructures like allowed by the exceptions foreseen by Art.6 as proposed by the rapporteur. We should avoid at all cost misusing public resources. Investing in new fossil fuels-based facilities would lock-in investments in technologies of the past for decades and lead to the creation of stranded assets. Instead, we need to invest in the future efficient energy system which will bring multiple economic, environmental and social benefits.

• Ensure strategic alignment with the National Energy and Climate Plans (NECPs)

Those plans are set to outline Member States’ strategies and the necessary financial and regulatory means to implement the new energy framework for 2030 and unlock the growth and job potential of crucial directives it contains.

• Only support investments in energy efficiency projects that at least comply with the minimum legislative requirements

For example, in the building sector, ERDF and CF should be used only for energy efficiency improvements that go beyond the minimum energy performance requirements for buildings in line with the revised EPBD and with technological innovations available on the market.

CPR

• Keep the reference to Energy Efficiency First principle as proposed by the European Parliament

The Council proposal for an “assessment of the expected impact on climate change of investments in infrastructure with an expected lifespan of at least five years” is not enough. Only a full application of the Energy Efficiency First principle in energy planning, policy and investment decisions, would allow a meaningful prioritisation of measures that make the demand and supply of energy more efficient and can help transitioning our economy towards climate neutrality by 2050.

Dear ambassador Odobescu, in view of the current and future trilogues negotiations on these important files, we want to share our common understanding that there is a window of political and economic opportunities to support a climate-proof InvestEU, ERDF/CF and CPR regulations. You and your colleagues have an opportunity to build the foundation of a smarter, climate neutral, energy and resource efficient European society for the good of European citizens and businesses.

We remain at your disposal for further discussion on this strategic topic.

Yours sincerely,

Harry Verhaar

Chairman of the Board of Director of the European Alliance to Save Energy (EU-ASE)

Head of Global Public and Government Affairs, Philips/Signify

For more information, our position papers “A climate-proof  budget to drive the EU clean energy transition to a low carbon economy” (released in March 2018) and a “A climate-proof budget to leverage the necessary investments to deliver the Paris Agreement” (released in November 2018) outline in greater detail our views and calls for a full application of the Energy Efficiency First principle, increased climate mainstreaming and improved climate proofing in the MFF post-2020

[1] Reflection Paper on a Sustainable Europe by 2030. European Commission, 2019.

To the kind attention of the Members of the REGI Committee

Brussels, 14 March 2019

Dear Members of the REGI Committee,

I am writing to you on behalf of the European Alliance to Save Energy (EU-ASE). EU-ASE is a multi-sectorial business organisation whose members operate across the 28 Member States of the European Union, with an aggregated annual turnover of €115 bn, directly employing 340.000 people in Europe.

The post 2020 Multi Annual Financial Framework (MFF) is a unique opportunity for the EU to demonstrate coherence with its long-term energy and climate objectives and show commitment to deliver tangible benefits to European citizens. In the framework of the MFF post-2020, the ERDF and CF Regulation is a necessary trigger for outlining the much-needed long-term political direction and mobilizing private investments towards a decarbonized European economy.

The ERDF and CF Regulation must give the right political signal to stimulate investments in clean technologies, and in particular in cost-efficient energy efficiency projects, which will only get unlocked if the EU provides clear direction and long term certainty to the private sector.

The impact that ERDF and CF can have in terms of employment creation, mainly youth employment is also significant. In order to implement a sustainable energy transition, there will be a large additional demand for workers with different types and levels of qualifications, ranging from lower skilled workforce to highly skilled professionals. This is an opportunity that should not be missed, especially for regions that are suffering from high rates of unemployment, and those that will have to go through a challenging transition pathway.

According to the European Commission reflection paper on the 2030 vision^[1], in Europe there are currently nearly 1.5 million jobs in renewables and energy efficiency. Industries operating in the area of building refurbishment represent more than 3.4 million jobs and the Commission impact assessment for the Clean Energy Package stated that there is a potential to create an additional 900.000 jobs by 2030, provided that public and private investments are sufficiently mobilised. Of these, up to 400.000 additional local jobs could come from the energy efficiency sector.

In view of the ERDF and CF Regulation’s deadline for amendments (March 20) and following plenary vote (March 27), we urge you to:

• Increase to 40% the overall target of ERDF/CF expenditure supporting climate objectives

Such increase is necessary taking into account the magnitude of the climate change challenge and the level of support required to achieve climate neutrality by 2050.

• Prioritize investments in energy efficiency (both on the energy demand and supply sides) in all sectors

To prioritize energy efficiency investments, ERDF and CF Regulation should fully apply the Energy Efficiency First principle and therefore embed the principle to first assess the economic opportunity to reduce energy consumption through cost effective energy efficiency solutions before investing in new sustainable supply capacities. In our view, all investment decisions in the field of energy and climate change must be guided by long term decarbonisation objectives. Faced with the challenge of scarcity, public resources should be spent in the most intelligent, efficient and effective way, paying due attention to aspects such as just transition, and prioritizing areas with the highest economic, societal and environmental value.

• Exclude investments in new fossil fuels infrastructures

It does not make economic and environmental sense to invest in new fossil fuels infrastructures like allowed by the exceptions foreseen by Art.6 as proposed by the rapporteur. We should not misuse public resources. Investing in new fossil fuels-based facilities would lock-in investments in technologies of the past for decades and lead to the creation of stranded assets. Instead, we need to invest in the future efficient energy system which will bring multiple economic, environmental and social benefits.

Dear Members, ahead of the vote in Plenary, we urge you to support an ERDF and CF Regulation which envisages a smarter, climate neutral, energy and resource efficient society for the common good of European citizens and businesses.

We remain at your disposal for further discussion on this strategic topic.

Yours sincerely,

Harry Verhaar

Chairman of the Board of Director of the European Alliance to Save Energy (EU-ASE)

Head of Global Public and Government Affairs, Philips/Signify

For more information, our position papers “A climate-proof  budget to drive the EU clean energy transition to a low carbon economy” (released in March 2018) and a “A climate-proof budget to leverage the necessary investments to deliver the Paris Agreement” (released in November 2018) outline in greater detail our views and calls for a full application of the Energy Efficiency First principle, increased climate mainstreaming and improved climate proofing in the MFF post-2020

[1] Reflection Paper on a Sustainable Europe by 2030. European Commission, 2019.