In September 2020, EFIEES has submitted its feedback on the EU Comission’s Energy Efficiency Directive Review Roadmap. 

We reminded that if the EU really commits to step up its ambition for emissions reduction in 2030 to at least to 55%, more efforts on energy efficiency, both in primary and final energy consumption, are urgently needed and a proper implementation of existing legislation must be prioritised. Should this imply a revision of the EED.

Thus we preliminarily recommended the following:

  • Energy Efficiency First, along the whole energy chain, should be the guiding principle

A revised EED should primarily integrate the Energy Efficiency First principle, as defined in the Governance Regulation, requiring to prioritise energy efficiency actions along the whole energy chain. This principle did not exist back in 2012 and should thus find its place in the EED reflecting the current definition, as both supply and demand-side measures are essential to make energy consumption efficient.

  • Energy efficiency targets should be binding

Unlike the renewables’ target in the RED, also revised in 2018, the EU energy efficiency target is not binding. Moreover, the RED foresees a clear formula for calculating national contributions by Member States and a gap-filler mechanism is envisaged in case of insufficient progress. There is no similar approach to energy efficiency. This can weaken even further the fragile progress in energy consumption reduction. It can also result in unbalanced efforts by Member States to achieve renewables and energy efficiency targets, which instead, should be mutually reinforcing. That is why the EU energy efficiency target, and national targets as well, should primarily be made binding.

  • Focus on the optimisation of energy consumption through effective energy management

Energy management solutions, such as those offered by energy efficiency services (EES), are an essential tool to optimise energy consumption, and thus reduce CO2 emissions, in both buildings and industrial facilities. The current EED already promotes EES, notably in Article 18. However, many provisions just call on Member States to encourage the development of the EES market, without requiring the enforcement of mandatory measures.

  • Foster energy efficiency in Heating & Cooling

Solutions such as efficient district heating & cooling, highly efficient cogeneration and waste heat recovery, which facilitate energy system integration, should be further promoted and accompanied by the necessary support, in the EED and other pieces of legislation, to become key elements of any energy planning strategy at local level.

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