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AGFW | Der Energieeffizienzverband für Wärme, Kälte und KWK e. V.

AGFW

AGFW is the German association representing companies in the district heating, cooling, and cogeneration sectors.

Lobbying Activity

German Energy Association Urges Simplified EU Taxonomy Heating Rules

5 Dec 2025
Topic — Review of technical screening criteria for the EU Taxonomy Environmental Delegated Act.
Message — The association requests removing mandatory life cycle assessments for geothermal energy and simplifying criteria for fossil gas. They also suggest including mine gas extraction and utilisation as a new taxonomy chapter.12
Why — These adjustments would reduce administrative burdens and facilitate investment in the district heating industry.3
Impact — Environmental groups lose out as stricter sustainability standards for bioenergy and gas are rejected.4
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AGFW urges EU to include district heating in hydrogen roadmap

5 Sept 2023
Topic — Strategy to double European hydrogen valleys and reach renewable hydrogen production targets.
Message — AGFW calls for the inclusion of hydrogen-ready CHP plants in the EU roadmap. They argue that hydrogen should be used in high-efficiency plants to supply heat via district networks.12
Why — This provides the district heating sector with the regulatory security needed for long-term investments.34
Impact — Providers of individual boilers lose out as the strategy shifts toward district heating.5
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German heating industry urges EU support for large-scale heat pumps

26 May 2023
Topic — This consultation addresses an action plan to accelerate heat pump market deployment.
Message — The association demands lower electricity taxes and faster permitting for large heat pumps. They also oppose short-term bans on synthetic refrigerants to protect current investments.12
Why — Lowering levies would make large-scale heat pumps more competitive against individual heating units.3
Impact — Environmental groups lose if the phase-out of harmful synthetic refrigerants is delayed.4
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

25 Mar 2022

Please find attached the feedback of our organization.
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Meeting with Eero Heinäluoma (Member of the European Parliament, Rapporteur) and Stripe, Inc. and AxHA

25 Mar 2022 · Anti-money laundering

Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

Please find AGFW´s contribution attached.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Please find AGFW´s contribution attached.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find AGFW´s contribution attached.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

19 Mar 2021

AGFW, the German association for DHC (district heating and cooling) and CHP (Combined Heat and Power), welcomes the possibility to voice its opinion on the revision of the Energy Performance of Buildings Directive (EPBD). AGFW is convinced that a revision of EPBD poses an important opportunity to develop a suitable framework that is positioned to offset the necessary decarbonisation of Europe´s building sector, by especially drawing the focus on the decarbonisation of Europe´s existing building stock- the sectors most carbon intensive segment. In order to support these efforts, AGFW would like to emphasize a couple of aspects that should be considered in the upcoming revision process: Establishing a non-discriminatory level playing field in buildings decarbonisation: The revision process of the EPBD should focus on promoting fuel switches from fossil to carbon neutral energy sources. This demands a level playing field between grid supplied heat and cold and on-site sources as well as an equal treatment of renewable and waste heat. As already mentioned in Annex I of the EPBD (Directive (EU) 2018/844) and reiterated in the Renovation Wave Initiative, both on-site and grid supplied renewable energy sources equally contribute to the decarbonisation of buildings and districts and should thus be treated on non-discriminatory basis. The Renovation Wave Initiative furthermore rightly outlined that both renewable energy sources and waste heat recovery play a key role in the decarbonisation of the EU building stock. Therefore, they should be treated equally when it comes to meeting the renewable targets for heating and cooling, DHC and buildings, especially in the framework of MEPS and Renovation Passports. Promoting a district approach to energy renovation: The upcoming EPBD revision should furthermore put a central emphasis on the implementation of the district approach-concept, which was first introduced in the EPBD (Directive (EU) 2018/844) under Art. 19 and was further reiterated in the Renovation Wave Initiative. This approach has numerous advantages when compared to building-by-building renovation: it can accelerate renovation efforts, promote faster decarbonisation of heating and cooling through the development and modernization of DHC networks and can help to identify possible interactions between various types of infrastructures and fuels, contributing towards the realization of smart sector integration. In thus unlocking further efficiency benefits for the overall energy intensiveness of Europe´s building stock, the implementation of district approaches would thereby also help to support the mainstreaming of the Energy-Efficiency-First-Principle across the European energy framework. Mandatory Minimum Energy Performance Standards (MEPS): The introduction of MEPS can play an important part in driving the decarbonisation of buildings. The effectiveness of these standards will however depend on their technical design as well as their subsequent implementation by Member States. In this context, it thus crucial to underline several important features that should be considered in the design of the MEPS framework: Firstly, MEPS should be based on primary energy, as this would guarantee a greater emphasis on the energy efficient decarbonisation of the building. Secondly, the possibility to connect to an efficient DHC network, where and when possible, should also be systematically evaluated and guaranteed within MEPS, since efficient heat supply is an essential component of a decarbonised building stock. Especially regarding the existing urban building stock – which remains the most carbon intensive building segment – efficient DHC continues to be the only accessible technology with a viable pathway to support 2030 ambitions. Thirdly, MEPS must furthermore be accompanied by a financial framework that comprises public and private subsidies, funding, and incentives.
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German heating association AGFW seeks realistic cogeneration emission thresholds

18 Dec 2020
Topic — The EU is establishing classification criteria for sustainable investments in the energy sector.
Message — AGFW recommends a threshold of 200gCO2e per kWh for co-generation plants. They advocate for a single methodology based on direct emissions during actual operation. They also demand equal treatment for all renewable technologies to ensure neutrality.123
Why — Predictable criteria would prevent asset stranding and secure long-term investment planning for the sector.45
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AGFW Calls for Expanded State Aid for District Heating

10 Dec 2020
Topic — Revision of EU state aid guidelines for environmental protection and energy systems.
Message — The organization requests including thermal storage and sector integration technologies in the guidelines. They propose raising notification thresholds and aid intensities for district heating and cogeneration. They also suggest removing tendering requirements for small-scale plants.123
Why — Member companies would benefit from faster funding and increased legal certainty.4
Impact — Supporters of strict waste hierarchy rules may see their priorities bypassed.5
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Response to Updating the EU Emissions Trading System

26 Nov 2020

AGFW, the German association on district heating and cooling and CHP (Combined Heat and Power), welcomes the possibility to voice its opinion on the amendment of the European Emission Trading System Directive. AGFW is convinced that the extension of the European ETS poses a unique opportunity to develop a carbon price signal that creates sufficient incentives for an efficient market based energy transition. In light of these considerations, AGFW would like to emphasize a couple of aspects that should underscore our decarbonisation efforts within this reform process. Firstly, regarding the possible extension of the European ETS to further sectors, AGFW is strongly supportive of the idea to establish a common European ETS for buildings to create a level playing field within the sector. However, AGFW is in favor of creating an individual and separate system outside the current ETS framework, because carbon avoidance costs greatly differ across sectors. Thus, an immediate inclusion of new sectors into the existing ETS framework would require a complete rebalancing of an otherwise functioning system and obstruct the intended steering effects. Nonetheless, both future pricing systems have to be coordinated in such a way that potential dual charges for CHP plants which are already covered through the current ETS will be prevented. Moreover, the future trading system should be aligned with the European energy taxation regime to prevent competitive distortions, especially to the detriment of small CHP plants. Regarding the actual design of a future carbon pricing for the buildings sector, the Commission should follow an upstream solution focused on the fuel wholesale trading. Extending the scope to individual households would be entirely unfeasible and become an additional obstacle to the transition process. Secondly, the utilization of the proceeds generated from an European buildings ETS. AGFW is in favor of building up EU level funding capacities and prioritize the Innovation Fund as the primary allocator of those additional resources with a separate exclusive funding line for targeted assistance to innovative flagship projects within the sector. This way, the sectoral carbon pricing mechanism could provide additional investment incentives focused particularly on the much needed modernization of the European heating and cooling systems. Regarding the future relationship between the Effort Sharing Regulation and the European ETS, AGFW again strongly emphasizes the need for a clear sectoral distinction to establish sufficient carbon pricing signals. Furthermore, some Members States have already adopted carbon pricing mechanisms on a national level. The Commission should therefore evaluate the impact of the extension of the ETS on existing national legislation to avoid a possible distortion of steering effects. Hence, AGFW favors the development of a clearly framed common European carbon pricing system along the lines of Option 3 put forward in the published Inception Impact Assessment for Regulation 2018/842 (Effort Sharing).
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Please find the AGFW's position paper attached.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Please find the AGFW's position paper attached.
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Response to Implementing act on a list of High-Value Datasets

24 Aug 2020

The AGFW, the German association on district heating and cooling and CHP (Combined Heat and Power), endorses the fact, that Commission acknowledges the importance of data and access to data for modern economy. However, regarding the definition of high-value datasets and the announced implementing act, the characteristics of the district heating and cooling (DHC) sector must be taken into account. The DHC sector examines already the possibilities of using the generated data to improve the customers’ satisfaction, enhance efficiency of the systems, prevent leakages and thus adjust the generation structure to the needs of the customers and to enable innovative solutions and reduce the emissions. Third parties acting as energy service providers, which could demand access to data on user profiles or heat use, are not always able to asses appropriately the heat consumption, especially if they take only the maximum heat consumption of the last few years into account. This could as a result have an adverse effect on the efficiency of the system, the deployed resources and emissions, not to mention the satisfaction and comfort of the consumers. An underestimated consumption of a customer can lead to a too low installed load and result in insufficient heat delivery, especially in cold winter. The demand in cold winter is thus representative while choosing the installed load. The data must therefore be subject to careful interpretation and over-simplistic conclusions must be avoided. It can negatively affect the dimension of the generation plant and lead to overinvestments as well as stranded costs, provided that the actual need is not taken into account. The user profiles, data on heat use and readings of the heat meters in any form are thus not to be considered high-value datasets. In this context, the question of ownership of these data is to be considered as well, what was so far neglected. The provisions of the GDPR apply in this context, which do not regulate the question of ownership of the readings of meters unambiguously. Data resulting from the reading of the meters might be considered as belonging to the consumers. What is more, accordingly to article 345 TFEU, the Treaties shall in no way prejudice the rules in Member States governing the system of property ownership. In Germany, own data are protected as property in the sense of article 14 of the German Constitution. Although data are not objects, all other rights are also covered by the concept of ownership under this provision (e.g. copyright, patent law, trademark law and ancillary copyright) and thus data are protected accordingly by art. 14 of the Constitution as well. This provision applies here at least as a definition of content and limits and the transfer of data would have to be justified by the company requesting the release of data.
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Response to A EU hydrogen strategy

8 Jun 2020

The AGFW, the German association on district heating and cooling and CHP (combined heat and power) welcomes the Commission’s announcement to publish an EU strategy on hydrogen. Hydrogen can play a substantial role in decarbonisation of industries, which struggle with the deployment of renewable energy sources. This requires especially, as the Commission rightly states, developing a well-functioning clean hydrogen market and a cost-effective infrastructure. A crucial step, though, is acknowledging, that a bundle of technologies will be needed for the decarbonisation of not only the energy system, but de facto the whole economy. Prioritising one of them could lead to loosing opportunities, which bring other technologies, and in the end could even lead to failure in achieving the targets. Having said this, what the Commission services should take into consideration while drafting the EU Strategy on Hydrogen is that even though hydrogen has a long-time role to play in the future energy system, it is only one of the needed technologies. As hydrogen is and will remain a highly valuable good, is will mainly be utilized in sectors, where the deployment of renewable energy sources faces several burdens (e.g. steel industry). In heating sector is to be applied accordingly to the “energy efficiency first” principle. It is therefore to be deployed in high-efficiency CHP plants in order to generate electricity and useful heat, rather than be directly injected into a gas grid and transported to end consumers. The AGFW strongly recommends also including in the EU’s Strategy on hydrogen an analysis on carbon cycles between hydrogen and other synthetic gases (for generating synthetic methane from hydrogen) and price sensitivities (hydrogen vs. synthetic methane) for all eligible sectors.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Jun 2020

The AGFW, the German association on district heating and cooling and CHP (Combined Heat and Power) welcomes the Commission’s initiative to review the guidelines for Trans-European Energy infrastructure in order to ensure its consistency with the 2050 climate neutrality objective. Intensified cross-border and regional cooperation will substantially contribute to achieving clean energy transition. A key solution to enable the energy transition and decarbonisation of energy system is sector integration. The AGFW endorses the acknowledgement by the Commission’s services, that sector integration offers substantial opportunities to decarbonise the infrastructure and manage the power system more efficiently. This requires both additional funding, appropriate regulation and a cross-border/regional cooperation of different players. As the Commission rightly states, sector integration projects contribute to the closer linking of the electricity with other sectors, heating being one of them. Heating infrastructure and district heating networks have only in few cases a cross-border character (3 cases in Germany). However, they are an important element of sector integration. District heating and cooling (DHC) systems integrate renewable electricity via power-to-heat, CHP plants (fired by natural gas, later by hydrogen or synthetic fuels), heat storage, waste heat integration and deployment of renewable sources. With these components, district heating offers effective and cost-efficient flexibility and stability for the electricity grid with an ever-increasing share of volatile renewable electricity generation and at the same time substantially contribute to decarbonizing the building stock in densely populated urban areas. A cooperation between the countries on renewable electricity production, which would be deployed in order to generate renewable heat/gas is therefore of pivotal importance. Same applies to generation of decarbonised gases and hydrogen. However, while assessing the current TEN-E framework and designing the future form of it, the Commission should take into account, that the provisions were designed for specific types of infrastructure and large projects. Heating networks are local, though. Therefore, especially the provisions on the organisation of the permit granting process (art. 8 et seqq. of the Regulation 347/2013) cannot be applicable towards heating infrastructure. There is no one national competent authority responsible for facilitating and coordinating the permit granting process, but the permit granting procedure is administered by the local authorities. Assigning one national authority would be detrimental in case of heat projects. In Germany, public participation process is already now transparent and unburdensome. The overall duration of permit granting process is therefore much shorter than provided in art. 10 of the Regulation. What is more, the features of district heating sector would have to be taken into account. DH is operated as a system of generation structure and network. Generation and distribution match precisely, what guarantees security of supply and facilitates an efficient and climate-friendly operation mode of the generation facility. They are therefore interdependent on each other and an investment decision must take both aspects into account, otherwise an investment decision would be counterproductive. The AGFW therefore strongly recommends the Commission’s services to take these specific features of the heating networks into account, while extending the provisions of the guidelines on the Trans-European energy infrastructure to heating/sector integration infrastructure.
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German heating association AGFW urges realistic gas CHP thresholds

20 Apr 2020
Topic — EU rules defining which economic activities qualify as environmentally sustainable for investors.
Message — AGFW wants high-efficiency natural gas CHP recognized as a sustainable transition technology. They recommend setting CO2 limits that are technologically achievable rather than unrealistic thresholds. They also advocate for including waste-to-energy and power-to-heat technologies.123
Why — Inclusion ensures district heating operators can still attract private capital for their projects.4
Impact — Climate advocates lose as these higher thresholds permit continued reliance on natural gas.5
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Response to 2030 Climate Target Plan

15 Apr 2020

The AGFW, the German association on District Heating and Cooling and CHP (Combined Heat and Power) endorses the European Commission’s roadmap on the 2030 Climate Target Plan. With the view to the climate neutrality until 2050, what the European Union will pursue, the decisive investment decisions must be taken now. Much before 2050 or even 2030. Increased 2030-targets leave only 10 years for action, which is challenging for the energy sector and puts it under immense pressure, especially in the buildings sector (under the scope of Effort Sharing). The increase of ambitions must be accompanied by plausible and profound considerations on how to achieve them, as it requires increased investments, financing, workforce, licensing, enough time span etc. for building the necessary infrastructure. Time is the critical factor and the European law should enable and encourage appropriate decisions. It must be consistent, reduced to the core minimum, valid within foreseeable time horizons and adapted / implemented in appropriate time. It is also to be taken into account, that climate protection and economic development are not competitors. They can and must go hand in hand. This especially gains importance in the context of the “Corona crisis”, which will have immense impact on the European economy. It is therefore of vital importance to acknowledge, that investments in sustainable solutions have an incredible impact on economic growth and have job-creating effects. A perfect example is the development of district heating (DH) systems, that do not only contribute substantially to the environmental targets (reduction of CO2, deployment of renewable energy sources, increasing energy efficiency), but are real value added for the municipalities. A study carried out by the AGFW (40/40-Strategie, Unser Konzept für die Wärmewende) shows, that every million euros in turnover generated by the expansion of DH means approximately 7 to 9 jobs created in the municipality. What is more, from each euro the customer pays for DH, the municipal utility keeps 80 cent in the city / municipality (85 cent remains in the region). This will have further spill-over effects in the regions and empower citizens, giving them the feeling of directly profiting from the energy transition. More than 50% of the final energy used in European Union is consumed in heating and cooling sector (Strategy on Heating and Cooling, COM(2016) 51 final ). This number is even higher taking individual households into account: heating and hot water account here for 79% of total final energy use (Heating and cooling. Facts and figures, https://ec.europa.eu/energy/en/topics/energy-efficiency/heating-and-cooling). Therefore, the heating market and its impacts as well as opportunities in decarbonising the European energy sector must be acknowledged. DH shows a huge potential for integration of renewable energy of different origin and waste heat and for delivering it to customers in agglomerations. However, the sector faces several challenges, which should be addressed in the EU law, should the ambitions anchored in EED / RED II be increased. Helpful could be the promotion of sector integration (Power-to-Heat, heat pumps connected to DH systems). Appropriate funds will be needed too. To this end, the AGFW urges the European Commission to apply a modelling exercise, which takes regional solutions into account. Focusing on traditional options available everywhere, such as electricity and gas distorts the whole picture and misses the opportunities which are already there, on local level, though. Please do not hesitate to contact us in case of further questions!
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Response to Revision of the Energy Tax Directive

1 Apr 2020

The AGFW, the German association on District Heating and Cooling and CHP (Combined Heat and Power) endorses the European Commission’s roadmap on the revision of the so called Energy Tax Directive (ETD). The decarbonisation of the European economy is the main objective of the policy framework of the EU and the European Green deal and an integrated approach is needed. The AGFW welcomes, that - heat is not covered by the ETD in force and - electricity generated in high-efficient CHP plants and fuels used for CHP may be exempted from the provisions of the Directive. CHP is a highly efficient technology which helps save resources and thus reduces CO2 emissions. In a CHP plant which can be fuelled by diverse fuels, also renewable, along electricity useful heat is generated, which is fed into a DH network. Therefore, additional heat for heating houses or warm water does not have to be provided and hence the use of primary energy is reduced. The AGFW is of an opinion that it is of vital importance to consider further sector integration technologies in the ETD. The AGFW recommends therefore an obligatory exemption of the renewable electricity deployed in Power-to-X, particularly Power-to-Heat, from the levy. This would trigger the use and development of PtX technologies and streamline the usage of excess renewable electricity and allow renewables to enter the heat market (art. 24 (8) Renewable Energy Directive 2018/2001). This could be anchored in art. 21 (3), as currently applicable towards consumption of electricity not produced within the curtilage of an establishment used for fuel production, or alternatively in art. 2 (4)(3), as currently applicable towards electrolytic processes. The electricity and other purchased energy consumption for the production of fuels for electricity generation is thus to be exempted from tax – this exemption should be obligatory and not optional and extended towards heat production (Power-to-Heat) as well. What is more, in order to adequately promote greenhouse gas emission reductions in the non-ETS sector, the already existing ETS system should be supplemented by appropriate provisions of the ETD. In this respect we suggest introduction of a CO2 related tax on the top of the energy tax, which would be imposed only on the non-ETS sector (double burden for the ETS sector must be avoided). A simple extension of the ETS to non-ETS is not recommended. However, an EU-wide emissions trading system designed specifically for the current non-ETS sector (buildings and transport in particular) could be introduced. Reductions in the buildings sector could also be achieved by deleting the part of art. 15 (1)(h), which exempts electricity, natural gas, coal and solid fuels used by households from the tax. The individual installations have higher emissions than system solutions (district heating), what leads eventually to higher emissions and difficulties with fulfilment of the environmental goals and runs counter to the decarbonisation targets. The suggested solutions would also introduce level playing field on the heat market into the EU law, as currently highly efficient technologies like CHP with rated thermal input above 20 MW and District Heating (DH), which is usually fed with heat generated in installations exceeding 20 MW, and which contribute to achieving the environmental goals, compete with smaller individual installations (boilers below 20 MW), which do not have to take the costs of the allowances into account and are not subject to any levy. As the Commission services rightly state, the possible revision of rates and of the exemptions for households could have a social impact, especially on financially weak customers, but also on industry. The AGFW welcomes therefore the proposal of a reduction of other taxes, a compensation or a refund of the levy (e.g. accordingly to the Swiss model). In this context it is important to ascertain, that this measure does not constitute State aid.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

The AGFW, the German association on District Heating and Cooling and CHP (Combined Heat and Power) endorses the European Commission’s proposal for a Just Transition Mechanism (JTM) and Just Transition Fund (JTF). Especially in the regions which are highly reliant on coal, it is necessary to offer the citizens a viable alternative. However, the AGFW is of an opinion, that the transformation of the energy systems must follow the principles of security of supply and cost-efficiency. Only a continuous and affordable energy supply will allow the affected regions to benefit from the transition. In order to use the renewables to the maximum extend, it is necessary to support innovative concepts with the potential to decarbonise heating and electricity, like sector integration. Synergies and flexibility are important in a decarbonised system to ensure grid stability and security of supply. Through the deployment of surplus renewable electricity in Power-to-Heat installations renewables can be integrated into the heating sector, what reduces the need for redispatch. The fuels produced in Power-to-Gas installations are best used in highly efficient CHP plants. The AGFW suggests thus the extension of art. 4 (2)(d) to sector integration. The investments supported by the JTF must avoiding lock-in effects and stranded costs. However, in order to ensure security of supply they must allow for investments in transition technologies with potential for becoming climate-neutral (e.g. gas-fired CHP which could be fuelled by synthetic natural gas or hydrogen), which enable a long-term transformation of the energy sector. These technologies enable a sensible transition towards decarbonisation and serve as backup capacity to guarantee a constant heat and electricity supply. We recommend therefore a rewording of art. 5 (d) into “investment related to the production, processing, distribution, storage or combustion of solid fossil fuels” or alternatively allowing for investments with a credible plan for a continuous increase of renewables in the system, accordingly to the energy lending criteria of the EIB. The AGFW welcomes the Commission’s proposal for a facilitation of access to State aid for district heating (DH) in the Sustainable Europe Investment Plan (SEIP), as DH has the capacity to which bundle heat of different origin (renewables/waste heat). However, the specific features of DH, which is always local in its nature and thus poses no risk to competition, must be taken into account. Due to technical circumstances DH differs from the electricity and gas supply, hence enforcement of unbundling and Third Party Access in DH would lead to synergy losses and increase administrative costs without advantages for customers. DH are closed systems of generation and transport with an individual operation plan to ensure, that a given pressure, temperature and mass flow are sustained. Generation and transport match precisely, different than in case of electricity, what facilitates an efficient, resource and climate-friendly operation of the generation plants. A free choice of connection point to the grid is thus impossible due to technical, economic and environmental reasons. State aid for all DH networks should therefore generally fall outside the control. We strongly support the suggested application of the funding gap approach to DH projects, as it takes into account, that DH is operated as a system including the generation facility and the network. The application of the two different calculation methods for eligible costs leads to questions, including: how to distribute the revenues between the plant and the grid, how to determine the revenues from the grid operation, as this is connected to expenditures only (the revenues arise from heat sale which is generated by the generating facility); how to account the income from the electricity sale in a CHP plant. It would therefore be desirable to base the funding for DH on the funding gap.
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Response to Climate Law

6 Feb 2020

The AGFW, the German association on District Heating and Cooling and CHP (Combined Heat and Power) endorses the European Commission’s initiative to convert Europe into a carbon-neutral continent by 2050. Climate change is the biggest challenge of our times, which however, could be for the EU a chance for a transformation into an innovative and just society and a growing economy. It is therefore crucial to anchor the climate-neutrality into the European law and ensure that all sectors, not only the energy sector, contribute to reaching the target. Important steps on the way to carbon neutrality need to be implemented by 2030, which is a challenging timespan for energy sector. The policy and regulatory framework supporting these efforts should be consistent, reduced to the core minimum, adapted and implemented in appropriate time. The earlier the conditions will be clear, the earlier substantial decisions can be taken and implemented. The AGFW is of strong opinion that while the transformation of the energy sector will be pursued, it must follow the principles of security of supply and cost-efficiency. Without reliable energy supply the European economy cannot remain competitive and grow. Without supplying cost-efficient energy we risk leaving parts of the society behind, what could entail further growth of disappointment and radicalism. In this context the energy sector should be understood broadly and comprise heating and cooling. The AGFW calls therefore for putting energy efficiency at the core of the new Climate Law. The best energy is the one which is not consumed and thus the principle contributes to the achievement of the CO2-reduction target. The examination of the principle “Energy Efficiency First”, understood both as primary and end energy savings, should be mandatory while taking decisions on implementation of measures throughout the acquis communautaire. The key to untapping the potential of energy efficiency is a massive expansion of District Heating, which provides flexibility and enables sector integration, CHP, connecting the existing sources (waste heat), Power-to-Heat, heat storage and renewable sources, alongside with the building renovation. 50 % of the energy is used in the heating sector and thus energy savings in this sector are decisive for an achievement of the overarching target. Priorities should accordingly be set on sector integration, which has the potential to decarbonise simultaneously heating and electricity. A comprehensive approach, which makes use of the existing interlinkages between technologies and sectors, is hence necessary. Synergies and flexibility are important in a decarbonised energy system with a large share of renewables, to ensure stability of the grids and security of supply. The mammoth task of becoming climate-neutral entails massive investments in all sectors. It is thus vital to ensure level playing field amongst diverse technologies to allow for competition. The existing obstacles should therefore be removed (CO2-pricing in the non-ETS sector), because a bundle of technologies is necessary to achieve the climate targets. Moreover, it is necessary to streamline the public and private funding in order to mobilise the capital, while avoiding lock-in effects and stranded costs, but simultaneously allowing for investment decisions, which enable a long-term transformation of the energy sector. It is thus important to invest in so called transition technologies, which have the potential for becoming climate-neutral. An example is gas-fired CHP, which could be fuelled by synthetic natural gas or hydrogen. Last but not least it is important for the Green Deal to succeed, to get the consumers on board and offer long-run stability and affordable prices. A further education on sustainable behaviour is also necessary to drive the energy transition. Let’s make the European Green Deal a success story together! Please do not hesitate to contact us, if you have any questions.
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Response to Methodology for assessing the potential for efficient heating and cooling

10 Jan 2019

AGFW, the German Energy Efficiency Association for Heating, Cooling and CHP, endorses the European Commission’s proposal to amend and strengthen the framework on the promotion of efficiency in heating and cooling under article 14 EED (2012/27/EU) and thus reviewing the assessment rules in the annex VIII EED. We welcome the fact, that the European Commission takes into account technology and policy developments as well as the lessons learnt in the first reporting period, which can provide the necessary trigger to utilize the vast potential of efficient District Heating and Cooling and Combined Heat and Power. The review is the logical next step following the changes in EU energy framework such as the consideration of waste heat and cold in the new Renewable Energy Directive and the introduced Governance Regulation. Having said this, it needs to be ensured that the reviewed annex reflects the progress and lessons learnt as well as the characteristics of the sector in the best possible way. AGFW would like to point out, that accordingly to art. 14 EED the comprehensive assessment focuses on the potential for the application of high-efficiency cogeneration and efficient District Heating and Cooling, which in our opinion fall too short in the draft annex. Therefore, a stronger concentration on District Energy and a differentiation of supply options is needed. The current differentiation of options under point 2 (a) is unclear and leaves room for interpretation. The differentiation is not exclusive and allows for various competing ways of reporting and could also lead to double counting. To solve this, the AGFW suggests a new list that reflects the difference between onsite and district energy solutions, introduces a separate point under which cooling technologies are considered and ensures that all options can be reported in a clear and distinguished way. Whereas the AGFW endorses the explicit consideration of waste heat sources, it needs to be ensured that the reporting follows the waste heat definition of the new RED. Accordingly, the AGFW suggests including a new point 2 (b) vi in which tertiary sector would be considered. High-efficiency cogeneration, which has significant potential for saving primary energy, is an acknowledged aspect of efficient District Heating and Cooling as established in the respective definition in the Energy Efficiency Directive and is also recognised in heating-relevant articles of the Renewable Energy Directive. Therefore, it needs to be ensured that the whole potential of cogeneration and thus efficiency in District Heating and Cooling is considered. Hence, the heat generation in CHP plants must be reported. District Heating and Cooling has a great potential regarding sector coupling (sector integration). Utilising surplus renewable electricity in District Heating and Cooling is one of the options that will contribute to the decarbonisation of heating and cooling sector. Accordingly, AGFW suggests adding this highly relevant area with a focus on the utilisation of renewable electricity by means of e.g. Power-to-Heat process and deployment of heat storages. The potential of DHC refurbishment und upgrading across Europe must not be underestimated. Accordingly, AGFW supports the notion of DHC improvements in part II point 5 and calls for the focus on DHC and Combined Heat and Power specific aspects regarding the five Dimensions of the Energy Union mentioned in the Governance Regulation. Last but not least, the potential for further development of efficient District Heating and Cooling as well as high-efficiency cogeneration must be examined. The potential for additional district heating and cooling and high-efficiency cogeneration, which could replace onsite heating solutions, should be considered as well. Please find our suggestions as comments directly in the draft annex attached.
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Response to A New Deal for Consumers – revision of the Injunctions Directive

28 Nov 2017

Please find AGFW's feedback attached.
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