Response to the Roadmap on the revision of the Energy Efficiency Directive

The 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 Energy Efficiency Directive (EED). The Alliance brings together businesses, think thanks and Members of the European Parliament to ensure that the voice of energy efficiency is heard across the business and political community.

The EU-ASE welcomes the strong narrative on energy efficiency in the roadmap as well as its proposal to revise the current EED. The Directive has played a significant role in bringing energy efficiency up in the political agenda, stimulated increased national efforts, and resulted in some energy efficiency improvements. However, it did not lead to the creation of the much needed binding and long term legal framework to mobilize the investments required to tap the savings potentials across sectors and deliver the multiple benefits of energy efficiency to citizens, businesses and the environment. This shortcoming also stems from the imperfect implementation of the Directive. As a consequence, in many countries, the energy savings delivered fell short of the minimum required and are insufficient to achieve the national targets. We note that the Commission is rightly stepping up enforcement and we fully support strengthening the legal requirements for more effective implementation.

The current review should ramp up the ambition in light of the EU’s new climate objectives. The EED targets must be aligned with the European Green Deal and its goal to achieve climate neutrality by 2050 at the latest, as well as intermediary targets. According to the International Energy Agency (IEA), 76% of the European greenhouse gas emission reductions required to keep temperature increases below 1.5°C must come from energy efficiency. Therefore, the overall energy consumption reduction is the foundation for achieving climate targets while ensuring a deep economic transformation that is supporting a circular, resilient and equitable post-COVID recovery.

For policy-makers, investing in energy efficiency means investing in a fast, smart and sustainable recovery which is ‘made in Europe’. The International Patent Classification green patents inventory of the World Intellectual Property Organization shows that among the countries with a higher concentration of filings for patents in energy conservation technologies, there are the EU Member States such as Germany, France, and the Netherlands. Investing in energy efficiency means supporting the growth, competitiveness and long term sustainability of European manufacturers, solution providers and local value chains. The EED review is paramount in that respect and should be carried out in such a way to support job creation, sustainable growth and climate change mitigation and adaptation in one of the most innovative and strategic sectors of the European Union.

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

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EU-ASE response to the Inception Impact Assessment on the Revision of the UWWTD

The 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 Urban Waste Water Treatment Directive (UWWTD).

While the Directive has played a substantial role in improving the quality of European water resources and reducing pollution levels in water bodies, we believe that Europe remains some way from full compliance with collection and treatment requirements and has made little progress with water reuse.

We believe the 29-year-old Directive should be updated to better address these critical issues and today’s challenges including climate change, resource scarcity, increased energy consumption and population growth.

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

1. Digitalisation as a key opportunity.

2. Make use of data transparency and advanced data analytics for a knowledge based
approach.

3. Preserving natural water resources with smart water management.

4. Better legal framework for urban runoff and storm water management.

5. Carbon neutral waste water management.

6. Circular economy for water.

7. Supporting investments. 

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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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