EU-ASE Response to the EU Fitness Check on Energy Security Architecture

 

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the EU Fitness Check on Energy Security Architecture. 

The Recent geopolitical crises and heightened climate risks have underscored the urgent need for a resilient and independent EU energy security framework. While the EU has made notable advances in reducing fossil fuel imports following the Russian invasion of Ukraine, the reliance on other non-EU countries remains a significant vulnerability.

We advocate for a comprehensive and systematic approach to energy system efficiency (ESE) to achieve genuine independence from fossil fuels, thereby increasing energy security, fostering EU competitiveness and supporting a smooth, inclusive transition for all Europeans.

 

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EU-ASE Feedback to the 2040 Climate Target Consultation

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the European Commission`s public consultation on the 2040 climate targets. 

We support a binding EU-wide climate target for 2040 to address the more and more frequent impact of the climate, energy and water crisis.

In order to achieve climate neutrality by 2050, the European Union should adopt a comprehensive and ambitious set of climate and energy targets. The synergy between energy efficiency, renewable energy sources and GHG emissions targets is crucial to strengthen EU’s climate resilience and accelerate the energy transition. It is becoming more and more evident that such set of three targets is essential to reduce our dependence on external resources.

 

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EU-ASE Feedback to the Public Consultation on the Revision of the Industrial Emissions Directive

The European Alliance to Save Energy (EU-ASE) welcomes the Commission’s proposal to revise the Industrial Emissions Directive (IED) and supports the high level of ambition in tackling emissions from large industrial installations as well as the stronger emphasis on energy and resources efficiency, including water.

While the directive marks a very positive development, there is still room for improvement notably on the application of the Energy Efficiency First principle, the scope, the granting of permits and the crucial role of digital technologies. You can see all feedback on the Commission’s portal.

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Response to the Commission’s consultation on the Energy Performance of Buildings Directive

The The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the expost consultation on the EPBD revision.

Together with the rest of the ‘Fit for 55’ legislative ecosystem, the revision of the Energy Performance of Buildings Directive (EPBD) is crucial to address challenges the European Union is facing: the climate emergency, the soaring energy prices and the European dependency on fossil fuels from third countries. In this document, EU-ASE reacts to the Commission’s proposal to revise the EPBD and proposes recommendations to align the Directive with the EU’s climatic and energy objectives for 2030 and 2050.

 

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Response to targeted review of the GBER with revised rules for State aid

The European Green Deal target to reach climate neutrality by 2050 calls for unprecedented levels of public and private investments accompanied by deep reforms. In this context, well-designed State Aid schemes will be key to unlock investments and make the best use of public funds.

The European Alliance to Save Energy is happy to provide its feedback on the revised GBER. Energy efficiency is the bedrock of a decarbonised EU energy system: energy efficiency gains are essential to achieve the increased GHG emission target reduction of 55% by 2030 and full decarbonisation by 2050.

In its current form, the revised GBER offers some welcomed added flexibility for the application of state aid to energy efficiency projects. Energy efficiency is a precondition for a full integration of renewables and the phase out fossil fuels. Yet, in its current form the GBER does not provide the necessary level playing field with renewable energy sources and other energy supply measures. In particular the aid intensity levels for energy efficiency are lower and the rules on eligible costs are far more complex to apply.

EU-ASE therefore calls on the European Commission to:

1. Enshrine and enforce the “Energy Efficiency First principle” in the GBER
2. Level the playing field between energy efficiency measures and renewable energy sources (Art. 38 & 39 GBER)
3. Simplify cost eligibility and conditions for total cost eligibility (Art. 38)
4. Simplify the cconditions for the “incentive effect” (to favour the transition to MEPS)
5. Extend the scope of the Green Bonus (+ 15 points percentage) for high energy-efficiency projects

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Download related response to the CEEAG
Read more in our paper: Boosting energy efficiency through the revision of State Aid rules

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