EFIEES considers that the Energy Efficiency Directive (EED) has been a major breakthrough in the recognition by Member States of the issues of energy efficiency. The revision of this directive appears as a necessary step that will allow to widely spread its effective implementation and to consolidate its gains. Binding national targets, expressed in primary energy would be an important signal for the whole economy. Otherwise, the revised Directive must reach in reality the 1.5% target of energy savings/year (pursuant to Article 7). This is far from being certain today, particularly due to the implementation of “alternative measures”. Too accommodating definitions of alternative measures make some of them, in terms of energy savings, not measurable, or even ineffective.

Our responses to the questionnaire are based on the following principles which, in our opinion, will allow an
effective mechanism of improvement:

  1. EFIEES calls for the real and effective implementation of the provisions of the current EED.
  2. European policies should aim at promoting in priority energy savings in all sectors.
  3. The EU must adopt measures that reduce energy consumption and ensure that they are measured in primary energy savings, for comparison, and thus optimise the choice between different possible actions, in order to give the same weight to energy savings whatever their place in the energy chain
  4. Energy savings on the upstream, including the valorisation of the waste heat, allow to naturally increase the share with respect to renewables in the energy mix, which illustrates the complementarity of the two approaches (but not substitution: increasing the production by renewables cannot be recognised as an action to improve energy efficiency!), so as contributing to the two directives (EED / RES).
  5. The role of District Heating and Cooling and cogeneration as effective ways of efficient heat/heating production, emitting less CO2 emissions should be better recognised.
  6. There is a need for an approach focused on “energy-efficiency territory”, rather than on a building or use, so that the positive systemic effects are created. Urban planning should take into account in an integrated and coherent way heating, cooling and electricity needs (housing, mobility, water and waste treatment, etc.).
  7. The mechanism must give visibility to economic actors by extending the obligation of energy saving measures until 2030 adopted by the European Council to fix the new EU targets.
  8. Barriers and discriminations in the rapid dissemination of energy efficiency measures should be removed.
  9. Access to European funding schemes allowing facilitating financing of projects (grants, loans, soft loans, guarantees) should be improved.
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