Position on Fitness Check on the Water Framework Directive

EU-ASE is grateful for the opportunity to submit a response to this public consultation and welcomes the European Commission’s initiative to undertake a Fitness Check on the Water Framework Directive and the Floods Directive. EU-ASE believes that these REFIT Evaluation provide a timely opportunity to understand how these well-established legislations should be updated in light of the European long-term energy and climate strategy and increasing demands on Europe’s water resources. 

 

The 2012 Blueprint to Safeguard Europe’s Water Resources identified several gaps in the EU’s water policy agenda including the need to integrate a water dimension into other EU policies in order to address all aspects of water use and consumption.1 One of the important themes identified in the Water Blueprint is water efficiency and resiliency which looks beyond specific water quality issues to address more broadly issues of water quantity and water use.  Taking such an approach is even more important in today’s context of increasing water stress and competition for water resources amongst a growing population and the needs of agriculture and industry.  

The REFIT evaluation offers an opportunity to consider water policy in terms of the EU’s sustainability agenda, including the circular economy principles and energy and climate considerations.  In this regard, principles of sustainable water management should be mainstreamed across all EU policy making and in particular with regard to more refined guidance that promotes water treatment, distribution and usage, as well as energy efficiency.  

As energy plays a key role in production, transfer, distribution and treatment of water and wastewater, it is necessary to optimize its usage to increase the level of sustainability and to minimize specific costs. We consider that the EU has much to gain from considering the “energy-water nexus” in all EU policies, both in terms of making Europe’s waters more resilient and in terms of supporting Europe’s energy efficiency objectives. Accordingly, we encourage the Commission to look closely at these areas in its REFIT evaluation.  

On this basis, EU-ASE would like to make the following comments to support the Commission in its ongoing work. 

Sustainable water management  

The Water Framework Directive has its main objective to protect freshwater sources. According to the report of the European Environmental Agency2Europe’s waters are affected by several pressures, including water pollution, water abstractions, droughts and floods. The same report considers sustainable water management as a critical element to ensure healthy and resilient ecosystems. 

With increasing pressures on freshwater resources it is estimated that by 2030, global water requirements would grow from 4500 billion m3 today to 6,900 billion m3. This is 40% above the current accessible, reliable supply.3 At an EU level, it is estimated that water stress and scarcity will likely affect half of EU river basins.4  

At the same time, however, water resources are being lost as a result of leakages in distribution networks and inefficient water technologies. All this is significant cost both from a financial and resource perspective. At present, around 24%5 of all treated water in public water supplies is lost within the distribution network as a result of leakage. In some municipalities, this figure rises to 60%.  This means that around one quarter of the drinking water for the public must be treated again to enable access to clean drinking water for human consumption, adding to the high energy consuming profile of the drinking water sector. 

In this context, the sustainable water management encapsulates activity at several levels: the minimization of water usage through technological and systemic efficiencies, the elimination of water and waste water leakages in the distribution systems to reduce water abstraction, the digitalization and use of real-time data to measure water consumption and use for critical analysis, the optimization of energy performance of industrial processes and wastewater treatment, rain water management through green infrastructure and innovative solutions such as the recirculation of domestic water to reduce water and energy consumptions in households.   

Furthermore, in order to contribute to a more sustainable management of water, we suggest updating monitoring rules of the Water Framework Directive in line with technological innovations available on the market, including intelligent sensors, network and digital solutions.  

The ‘Energy-Water’ Nexus 

The role of energy in the EU water policies and the role of water in the energy sector are issues which have been so far widely neglected. The water and wastewater sectors account for 3.5 % of electricity use in the Union, and this share is expected to rise in the future.6 

Reducing energy waste in the water policies makes economic and environmental sense as it delivers tangible, multiple and collective benefits to European citizens and businesses and should be a priority for an update of the Water Framework Directive. This update should include specific linkage to EU energy efficiency legislation and opportunities to promote energy and water saving solutions. 

The replacement of the old infrastructure with energy efficient solutions can be achieved at a positive return on investment when considering the energy savings over the life time of the new products and systems7. As such, the EU Member States should provide policy and financial incentives to enable industry to take action.  

In the perspective of promoting energy efficient solutions, the water sector would also benefit from adopting public procurement rules based on the full cost of ownership and not just on the up-front capital investment of the solutions and systems that are specified. The REFIT of the water framework directive is an opportunity to support sustainable investments by linking in the Green Public Procurement Directive.  

In conclusion, EU-ASE believes that applying sustainable water management and energy efficient measures, can lead to a more sustainable water management that is in line with the Sustainable Development Goals, the Paris Agreement objectives on climate change and the urgent path towards climate neutrality by 2050 at the latest. 

We hope that the comments above can be useful in the debate surrounding these REFIT Evaluations.  

We remain at your disposition for further discussion and to answer questions on this important topic.  


[1] Opinion of the European Economic and Social Committee (15 June 2011) on the Integration of water policy into other EU policies

[2] EEA Report No 7/2018 – European Water Assessment 2018, European Environment Agency.

[3] Charting our water future, 2009, 2030 Water Resources Group.

[4] Report on the Review of the European Water Scarcity and Droughts Policy , 2012, European Commission.

[5] World Energy Outlook 2016, chapter 9: Water – Energy – Nexus. International Energy Agency

[6] Ibid.

[7] Powering the Wastewater Renaissance. Upgrade an industry and cut global emissions in half … at neutral to negative cost, 2015, Xylem Inc.

Open letter from the Coalition for Higher Ambition ahead of EUCO

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.

Businesses call for climate-proof InvestEU, ERDF/CF and CPR regulations

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.

Businesses call for prioritization of energy efficiency investments in ERDF and Cohesion Fund (CF) Regulation

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.

EU-ASE is female! Happy International Women’s Day 2019

According to a study carried out by the International Renewable Energy Agency (IRENA), it is projected that by 2050 there will be around 40 million jobs directly related to renewable energy and energye fficiency worldwide. Women comprise half the world’s population and half of the workforce, hence their full inclusion is vital to ensuring that the new energy economy is based on the largest pool of talent, knowledge and skills.

On 8 March 2019, International Women’s Day, EU-ASE wants to celebrate the powerful, capable women that make sure every day that the energy efficiency voice is heard across all sectors of the European Union. We want to recognise them, their achievements and their leadership. And to remind the energy community that, without their work, progressive climate and energy advancements would not be possible.

 

“There’s no talking about future without progressive climate policies, same as there’s no talking about future without women.”

Monica Frassoni, EU-ASE President

Happy International Women’s Day!