EU-ASE response to the public consultation on the “Revision of Directive 2012/27 EU on Energy Efficiency”

Article 1 provides the general framework for the promotion of energy efficiency within the Union in order to ensure the achievement of the EU 20% energy efficiency headline target by 2020. In addition and more specifically, Article 3 requires that each Member State sets an indicative national energy efficiency target based on either primary or final energy consumption, primary or final energy savings or energy intensity. In setting the targets, Member States should take into account a number of provisions set out in Article 3(1).

 

As regards the EU energy efficiency target for 2030, the European Council agreed in October 2014 on an indicative target at the EU level of at least 27% (compared to projections) to be reviewed by 2020 having in mind an EU level of 30%. Therefore, the existing policy framework should be updated to reflect the new EU energy efficiency target for 2030 and to align it with the overall 2030 Climate and Energy framework.

 

 

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EU-ASE contribution to the public consultation on “A 2030 framework for climate and energy policies”

The 2020 framework was designed without a comprehensive assessment of the synergies and potential trade-offs between the three targets (as recognized by the Green Paper – page 7, 5th paragraph) and had only two binding targets: one for raising the share of energy consumption produced from renewables (RES) in the European Union (EU) and one for EU greenhouse gas (GHG) emissions reduction. The energy efficiency (EE) target, however, was not binding. In short, the framework is fragmented.

This situation has led to 1) a lack of the necessary regulatory support (i.e. binding targets) for energy efficiency (EE) for which the EU 20% improvement target by 2020 will not be met, 2) a remarkable growth for RES in general terms, but in a incoherent and inconsistent way among different Member States; and 3) the failure of the Emission T rading S cheme (ETS), conceived as the major driver for long term low carbon investments, due to a large surplus of ETS allowances. This only was caused in part by the economic crisis.

To date the EU’s 2020 Climate and Energy framework has been fundamental in reducing GHG emission and strengthen RES. However, it clearly has not delivered the amount of energy savings expected and did not create the right long term signals for investment in EE solutions. More efforts must be focused on EE across Europe to provide industry with certainty in the policy framework and improve consumer acceptance on EE technology, products and services. A holistic approach of this future package is needed to avoid sub- optimization of certain sectors.

When designing policies for 2030, for the business perspective it would be a mistake to see a trade- off between the need for a binding target- based regulatory framework for 2030 and the competitiveness of European industry.

What is in fact needed is a cohesive 2030 framework based on three binding European targets. This will, in our opinion, restore economic competitiveness, reduce energy costs and prices, increase security of supply and sustain economic growth in the EU.

 

 

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