EFIEES supports the approach taken by the European Commission, which aims to use a revised method for calculating the primary energy factor (PEF) for electricity in a more rigorous and transparent manner yet we remind in this paper that:

• Various European policies require the use of different PEFs: if a single PEF, average at the EU level is acceptable for the application of laws relating to products, it is absolutely not possible for the ones applicable to buildings.
• Indeed, the PEF depends greatly on the geographic area of the building and the seasonal needs for calculating the energy performance of a building, so one has to use a minimum seasonal PEF calculated at the national level.
• The “average” method cannot be used for new buildings, which use the means of production of marginal electricity.
• The PEF must be calculated with reliable real data, not by using uncertain projections.
• Self-consumed renewable electricity is not available on the network, and therefore cannot be included in the calculation of the PEF.
• The PEF of electricity produced by cogeneration should lead to additional works to reflect rigorously the primary energy savings.
• As explained in the present note, the “raison d’être” of the PEF is to compare the energy performance when several energy sources are used. The PEF has to be representative enough of the situation in order to allow this comparison in primary energy, on the basis of the real conditions: geographical zone, and temporality of the consumption, notably. As far as buildings are concerned, a unique PEF as envisaged will lead to wrong results, and will not steer decision-makers towards the optimal solutions in terms of energy efficiency.

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