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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Response to the Roadmap on the Digitalisation of the Energy Sector

The European Alliance to Save Energy (EU-ASE) welcomes the opportunity to provide feedback to the inception roadmap on the EU Action Plan on the Digitalisation of the Energy Sector.

Digitalisation is key to accelerate the decarbonisation of the economy while ensuring business competitiveness. Digitalisation makes it possible to deliver energy at the right time, in the right place and at the lowest cost. It provides excellent opportunities to further reduce energy demand and optimise energy consumption. Furthermore, the digitalisation of the energy system allows citizens to actively participate in the energy market and is the foundation for energy systems integration, ensuring better integration and use of energy from e.g. distributed energy resources directly powered by renewables (e.g. heat pumps, EV charging, on-site solar panels, etc.) and surplus heat. In support of this, according to the International Energy Agency (IEA), investments in digital electricity infrastructure and software has grown by over 20% annually since 2014.

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State Aid: Response to the public consultation on the CEEAG revision

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.

As part of the ongoing revision of the Climate, Energy and Environmental Aid Guidelines (CEEAG) and the General Block Exemption Regulation (GBER), the Commission pledged to set simpler, clearer, and easier-to-apply State Aid rules for Buildings renovation programmes, in particular in the residential and social sectors. Additionally, aid to energy efficiency investments was to be simplified and enhanced, as announced in the Sustainable Europe Investment Plan and in the European Green Deal Investment Plan.

The European Alliance to Save Energy is happy to provide its feedback on the revised CEEAG. 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 CEEAG insufficiently supports the uptake of energy efficient measures and exposes the EU to the risk of missing its GHG reduction target for 2030 and 2050.

EU-ASE calls on the European Commission to:

1.  Assess all measures against the Energy Efficiency First principle
2. Level the playing field in aid intensity for energy efficiency measures (CEEAG Annex 1 and Art 38 GBER)
3. Simplify the definition and methodology to determine cost eligibility (para. 125 and Art 38 GBER)
4. Provide clear guidance on current State Aid rules with a practical approach

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Read more in our paper: Boosting energy efficiency through the revision of State Aid rules

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