Energy efficiency and the Energy System Integration Strategy

Reducing emissions across all sectors and decarbonizing “hard-to-abate sectors”, which include buildings, industry and transport, will strongly depend on the EU ability to apply the energy efficiency first principle, which should be mainstreamed to all energy policymaking, planning and investments, including into the upcoming EU Strategy on energy sector integration. 

Energy efficiency is the first fuel and should be the starting point for all decarbonization efforts, and this according to the energy efficiency first principle as defined in the Governance for Energy Union Regulation. Together with renewables, it must represent the lion’s share of the measures needed to meet the 2050 target. Energy efficiency and renewable electrification are two key pillars of a 1.5C decarbonization pathway.

To achieve its climate neutrality goal by 2050, the Commission has announced an Energy System Integration Strategy as part of its Green Deal. This new strategy will look at how to facilitate the interlinkages between electricity, heating, building, transport and industry sectors, to better use synergies likely to emerge (including in energy conversion and storage), thereby enabling a more cost-efficient decarbonization of the energy system. This includes looking at how integrating sectors can improve the overall efficiency of the energy system through enabling reuse of excess/waste energy, storage of surplus electricity in thermal networks, buildings and transport as well as to incentivize the clean electrification of sectors, interconnectivity and energy storage.

The recommendations outlined in this paper put forward some key ideas to fully consider the potential for energy efficiency and its role in facilitating the transition towards more integrated energy and other sectors.​

 

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Recommendations for a neighbourhood approach to maximize energy efficiency in renovation and energy planification

This position paper calls on the European Commission to integrate the notion of neighbourhood approach in the EU building and energy efficiency policy framework, in the national programmes for buildings renovations and in the upcoming Renovation Wave strategy.

The current energy efficiency legislative framework in buildings already refers to the notion of a district or neighbourhood approach, in particular in Art.19, §2, of the Energy Performance of Buildings Directive (EPBD).

While the article refers to 2026, given the multiple benefits of a neighbourhood approach and the need for accelerating our climate actions, the EU should prioritize the integration of this principle in its climate and energy framework and any new initiatives linked to renovation and decarbonization. This is all the more relevant, as the main challenge today is not so much the construction of new buildings as the renovation of the existing ones.

We need to make sure that the renovation policies deliver fast and concrete results in terms of increased energy efficiency and overall system efficiency, reduced energy consumption and reduced GHG emissions. A neighbourhood approach could help us achieve these goals and the overall objective of a highly energy efficient and decarbonized building stock.

 

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EU-ASE response to the Inception Impact Assessment on the Industrial Emissions Directive

European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission’s publication of an inception impact assessment on the revision of the Industrial Emissions Directive (IED). 

While we believe the Directive has been responsible for solid progress against identified air and water pollutants, and the BREF process has contributed to identifying Best Available Techniques, in its current form the Directive is not able to contribute toward EU ambitions for climate neutrality. 

Based on this, EU-ASE would like to highlight the following recommendations to support the Commission in its ongoing work on the IED’s revision.

1. Broadening of the scope 

A change in scope is needed so that the IED becomes part of the EU’s arsenal for climate neutrality. The IED should not only look at industrial emissions from a qualitative perspective, instead it should go further and focus on use of resources in industrial manufacturing processes, circular economy and the reuse of resources in to order to have a real impact. 

2. Making the Energy Efficiency BREF mandatory for all sectors 

There is a general consensus that the Energy Efficiency BREF has not been made a priority focus in the past and needs strengthening of the requirements to reduce energy losses. Its implementation needs to be made mandatory for all sectors, taking into account the Energy Efficiency First principle. 

3. Tackling water scarcity and efficiency needs by reducing water consumption 

The issue of water scarcity and efficiency needs to be tackled before it becomes a larger, more critical issue for industry. In Europe, more than 50% of fresh water abstraction is for industrial purposes. While we welcome the inclusion of water reuse in the existing BREFs, the reduction of water consumption has clearly not been a key environmental issue addressed by the BREF technical committees as only 20 BAT conclusions (out of 850 in total) have included water usage reductions or increasing water reuse. 

4. Focusing on the energy-water nexus 

We believe that the IED should give greater priority to water consumption with a focus on reuse under circular economy principles. This should include a focus on water and heat in industrial processes (the “energy-water nexus”) where water efficiency leads to energy savings and emissions reductions.

5. New policy objectives 

We would like to see water efficiency and water reuse in industrial processes, waste water minimisation, and the digitisation of water management in industry become policy objectives of the IED. 

6. Horizontal BREF on water efficiency and reuse 

The Commission could consider developing a horizontal BREF on water efficiency and reuse to mainstream these practices across European industries. 

7. Fit for innovation and new technologies 

The slow incremental nature of the “available techniques” needs to be addressed to better promote innovation, and BREFs require a mechanism to adapt more quickly to rapidly advancing technologies (there is no backwards compatibility). 

8. Encourage behavioral change and incentive mechanism 

The Commission should seize this opportunity to encourage behavioural change amongst industry leaders and provide incentive mechanisms to help them realise the different benefits of water and energy efficiency measures (water, energy, emissions and industrial competitiveness).

 

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EU-ASE response to the Inception Impact Assessment on the 2030 Climate Target Plan

As European businesses and investors having energy efficiency and energy demand reduction at the heart of our activities, we strongly support President Ursula von der Leyen’s commitment to set the EU on a path to becoming the world’s first climate neutral continent by 2050 at the latest.

In view of this goal, we believe that the 2030 greenhouse gas emissions reduction target must be increased from the current 40% to at least 55% because a more ambitious target will put the EU on a more gradual and sustainable pathway to climate neutrality by 2050. An increased 2030 target is also critical because it reflects the absolute urgency, underlined by the IPCC latest Special Report on the impacts of global warming, to address climate change and reduce to minimum GHG emissions in the next ten years.

A growing number of Member States are already committed to increasing their climate ambition. A target of at least 55% by 2030 at the EU level is also feasible from both technical and economic point of view and, according to the European Commission’s own analysis, it is likely to lead to a net increase in GDP of 2%, a surge in employment and a reduction in costs linked to fossil fuel imports and health damages.

We believe that increasing the 2030 GHG target to at least 55% requires a comprehensive assessment which will consider the impact of such policy decision both in terms of direct benefits (e.g. employment, reduced energy costs and import dependency, competitiveness) as well as avoided costs (e.g. environmental damages, health costs, fossil fuel subsidies). We are also convinced that such assessment should be based on the analysis of the European energy infrastructure needs and must fully apply the energy efficiency first principle to prevent lock-in into carbon-intensive future pathways.

 

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EU wide Renovation Wave: where growth strategy and job creation meet climate goals and social inclusiveness

Unlocking the potential for energy efficiency and carbon footprint reduction that lies in the EU buildings stock is a top priority for the European Alliance to Save Energy.

 

As businesses and investors having energy efficiency and energy demand reduction at the heart of our activities, we look forward to seeing Europe’s global climate leadership translated in green measures which will lead to a sustainable recovery through stimulus packages. We strongly believe that the Renovation Wave as part of the EU Green Deal is a great opportunity to promote a European based industry, with technologies and expertise able to serve the renovation demand locally. This will help to maintain the competitive advantage of the European industry and will contribute to the European green recovery and local job creation while lifting millions of Europeans out of energy poverty.

We support a system-wide approach that puts highly energy efficient, renewable-based, smart and flexible buildings at the center of a fast-changing decentralized energy system.

With this in mind, we envisage an EU wide building Renovation Wave which revolves around the swift implementation of the Energy Efficiency First principle as the fastest and most cost-effective way to reduce emissions and stimulate sustainable economic recovery.

We are convinced that highly energy efficient and smart buildings are the first and indispensable step to:

  • Accelerate the deployment of renewable energy sources
  • Foster sector integration of buildings with other sectors, including industry,
    transport and energy sectors
  • Catalyse energy system decentralization and enhance overall system efficiency
  • Stimulate a sustainable economic recovery, and boost local employment

For this to happen Europe must back an ambitious and impactful Renovation Wave which aims to increase the energy efficiency of buildings by reducing their energy consumption and by fostering the greater quality, the rate, and the depth of comprehensive renovations encompassing envelopes and technical buildings systems. Concretely, and to stay on track with the EPBD goal of decarbonizing the EU building stock by 2050, the Renovation Wave should be designed to reach a minimum of a 3% renovation rate per year combined with an average energy efficiency improvement of 75%.

The social impact of an EU wide energy efficient Renovation Wave would be tremendous. Improved comfort, cleaner indoor and outdoor air quality, reduced energy bills, the emerging role of prosumers with the possibility to optimise and monetise their energy resources on a peer-topeer market place, better and more qualified local jobs are just a few concrete examples of the multiple benefits that Energy Efficiency First in buildings would deliver to those who need them the most, i.e. live in energy poverty.

 

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