European Federation of Intelligent Energy Efficiency Services
EFIEES
EFIEES promotes companies that help customers improve energy efficiency through long-term contracts and optimised energy management.
Lobbying Activity
Energy efficiency group seeks simplified EU Taxonomy reporting rules
5 Dec 2025
Message — They propose aligning Taxonomy criteria with existing EU energy laws to simplify reporting. They specifically seek to remove life-cycle assessments and align bioenergy rules with directives. They also request expanding energy service definitions to include industrial facilities.123
Why — This would reduce administrative burdens and eliminate technical bottlenecks for energy service companies.45
Impact — Environmental groups may lose as these proposals weaken currently stricter sustainability thresholds.6
Energy efficiency industry urges demand-side focus for energy security
13 Oct 2025
Message — EFIEES argues energy security must systematically integrate demand-side considerations and efficiency measures. They advocate for promoting decarbonized thermal solutions like district heating and waste heat recovery. These measures should be recognized as a central pillar of the security architecture.123
Why — This shift would create more opportunities for their members' energy management projects.4
Impact — External energy suppliers would face reduced demand as the EU cuts imports.5
EFIEES urges energy efficiency focus in EU heating strategy
9 Oct 2025
Message — The group demands that energy efficiency remains the central priority of the new strategy. They call for a stable regulatory environment and a dedicated, independent plan for cooling. Additionally, they propose a guarantee fund to protect waste heat recovery projects.123
Why — Predictable rules and risk-sharing funds would protect their twenty-year investments and improve competitiveness.45
EFIEES urges prioritizing energy efficiency in EU electrification plan
9 Oct 2025
Message — EFIEES demands that the plan consistently upholds the energy efficiency first principle. They call for safeguarding clean thermal solutions like district heating. The federation also seeks a predictable regulatory framework to manage volatile prices.123
Why — A stable legal environment would reduce investment risks for long-term energy efficiency projects.4
EFIEES urges state aid access for third-party energy services
6 Oct 2025
Message — The federation asks that energy service companies qualify as beneficiaries under third-party financing. They suggest rules include environmental improvements resulting from other entities in the infrastructure chain. They also propose a bonus in public support for projects based on guaranteed performance.12
Why — Opening aid to third-party investors would allow these service companies to secure project funding.3
Impact — Standard energy projects lose financial competitiveness against those offering performance-based guarantees.4
Energy efficiency services group warns against EU over-legislation
15 Sept 2025
Message — EFIEES requests that the 'Energy Efficiency First' principle guides the new target. They emphasize the need to prioritize existing 2030 goals before setting new sectoral sub-targets.12
Why — A stable regulatory environment would protect the investments of energy service companies.3
Impact — Advocates for stricter sectoral regulations lose out to the demand for stability.4
EFIEES urges inclusion of energy performance contracts in package
11 Sept 2025
Topic — This consultation addresses protecting and empowering consumers during the energy transition.
Message — The federation requests the inclusion of energy management solutions like energy performance contracts in the package. They advocate for large-scale energy efficiency programs and public support for building renovations.123
Why — These measures would expand market opportunities for private energy service companies.4
Impact — Fossil fuel importers lose market share as households reduce their energy reliance.5
Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)
31 Jul 2025
EFIEES is the voice of private energy service companies (ESCOs) and their national associations across Europe. Our members represent over 100.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of district heating & cooling networks. EFIEES welcomes the Commissions intention to support Member States in addressing housing affordability and sustainability by revising the Services of General Economic Interest (SGEI) rules to offer more flexibility to Member States to support affordable housing. The EU is indeed facing a dual challenge: the urgent need to increase the availability of affordable housing, and the equally pressing need to reduce the environmental impact of the buildings sector. These challenges are closely interconnected, and housing affordability is significantly influenced by energy costs, notably as regards heating and cooling which account for 62,5% of housing energy costs. Any revision of the SGEI State Aid rules should thus be done in accordance with and to support the EU 2030 and 2050 climate objectives. First, when revising the SGEI rules to provide greater flexibility for Member States to support entities that provide SGEI through either the construction of new buildings or the renovation of existing ones, the European Commission should ensure that all existing and available efficient and decarbonised solutions are fully considered and integrated by these entities. In the context of collective housing, it is particularly important to make sure the entity which operates the housing related public service prioritise collective energy solutions, such as hot water loops and connections to district heating and cooling networks, in order to avoid the lock-in effects caused by the installation of individual heating systems. District cooling solutions, recognised as climate adaptation infrastructure, should also be prioritised. These collective approaches can deliver greater efficiency and support long-term decarbonisation goals. Heating and cooling solutions at district level facilitate the use of renewable energy, and allow the recovery of waste heat sources, which improves circularity, competitiveness, economic stability at local level. Moreover, energy efficiency measures and more specifically energy management solutions such as Energy Performance Contracting in large condominiums and social housing should also be fully supported by the SGEI revision. These solutions, though often unfamiliar to social landlords and condominium associations, offer guaranteed energy (and often CO) performance over time and provide a tailored approach for each building. By consuming less energy, consumers pay less, generating a dual benefit of economic savings and environmental impact. In a context of limited public financing resources, it is and will be of utmost importance to ensure that renovations supported by State Aids achieve and deliver the expected energy performance and CO emissions reductions. New SGEI rules should mention that a bonus in the intensity of public support should thus be granted for projects based on guaranteed performance. By the same token, that would facilitate the mobilisation of private co-financing in such projects. Energy and CO performance can notably be effectively guaranteed through energy management solutions such as Energy Performance Contracts (EnPCs), under which an ESCO contractually commits to a public or private asset owner to achieve guaranteed levels of energy performanceand increasingly, CO emissions reductionsover time. The implementation of energy efficient solutions should of course be fully aligned with competition and non-discrimination rules between potential operators on the market of heating and cooling solutions.
Read full responseEFIEES demands simpler carbon audits and extended heating allowances
8 Jul 2025
Topic — Review of the EU emissions trading system for maritime, aviation, and stationary installations.
Message — EFIEES asks to streamline audit processes and extend free carbon allowances for district heating until 2040. They oppose adding waste incineration or smaller facilities to the system's scope.123
Why — Reduced administrative requirements and continued free allowances would lower costs for energy service providers.45
Impact — Financial traders would lose profits from carbon speculation if stricter market rules are established.6
Response to European Affordable Housing Plan
4 Jun 2025
EFIEES is the voice of energy service companies (ESCOs) and their national associations across Europe. Our members represent over 100.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of DHC networks. EFIEES welcomes the Commissions intention to support Member States in addressing housing affordability and sustainability with an Affordable Housing Plan. The EU is indeed facing a dual challenge: the urgent need for more affordable housing and the equally pressing need to reduce the buildings sectors environmental impact. In recent years, the Commission has proposed several important initiatives to support the renovation of the EU buildings stock and improve energy efficiency. To pursue this effort, the Affordable Housing Plan should support energy efficiency measures and staged renovations, with a particular focus on the worst-performing buildings, to both reduce rental costs and increase the supply of sustainable housing. Beyond their vast potential for energy savings, energy efficiency solutions and renovations are also a key enabler of a just transition towards more affordable and sustainable housing, delivering a wide range of energy and non-energy benefits. Energy efficiency and more specifically energy management solutions such as Energy Performance Contracts indeed help containing households energy consumption and can thus lower their overall housing-related costs and contribute to greater economic stability. We need to foster and implement large-scale energy efficiency programmes to achieve significant reductions in energy costs. By consuming less energy, consumers pay less, generating a dual benefit of economic savings and environmental impact. Furthermore, energy efficiency upgrades can serve as a real economic buffer during energy crises. By improving a buildings insulation and enhancing the overall efficiency of its energy systems, households become less vulnerable to energy price volatility. This not only strengthens their economic resilience but also reduces reliance on (potentially imported) fossil fuels thus protecting them against shortage and price shocks. Moreover, with the entry into force of the ETS2, Energy (and Carbon) Performance Contracts will be even more useful on helping avoid CO2 related costs by reducing energy consumption and facilitating switch to renewables. Supporting the renovation and improved functioning of the worst-performing buildings within the Affordable Housing Plan would also help enhancing comfort and climate resilience for vulnerable households, while ensuring more assets are available on the market. Renovating these worst-performing buildings, which are often occupied by the most vulnerable households, while improving their energy performance over time, contributes to better living conditions in winter and greater resistance to heatwaves in summer. In addition, such efforts could help preventing these buildings from being withdrawn from the market due to ongoing or upcoming regulations that restrict the sale or rental of buildings below certain energy performance thresholds. To support energy efficiency in a way that contributes to addressing the housing crisis, the Plan should encourage the use of Energy Performance Contracts in large condominiums and social housing. These solutions, though often unfamiliar to social landlords and condominium associations, offer guaranteed energy (and often CO) performance over time and provide a tailored approach for each building. It will also be essential to promote new financial incentives, such as innovative loan schemes and de-risking mechanisms, that can facilitate staged renovations and energy efficiency upgrades. These efforts should be complemented by additional measures at EU or national level to address the skills gap in the building sector and to strengthen professional training.
Read full responseMeeting with Rosalinde Van Der Vlies (Director Energy) and
7 May 2025 · Action Plan for Affordable Energy
Meeting with Andrea Wechsler (Member of the European Parliament)
18 Feb 2025 · EU Energy and industry policy
Meeting with Bruno Tobback (Member of the European Parliament, Shadow rapporteur)
18 Feb 2025 · Energy Efficiency and grid infrastructure
EFIEES Urges EU to Make Energy Efficiency a Security Pillar
26 Nov 2024
Topic — A fitness check evaluating the performance of the EU’s energy security legislative architecture.
Message — EFIEES demands that the EU energy security framework shifts focus from supply-side measures to demand management. They want efficient district heating networks and energy management solutions integrated as central pillars.12
Why — This would expand the market for energy management solutions and local thermal infrastructure projects.3
Impact — Fossil fuel importers lose business as efficiency gains significantly decrease the demand for energy imports.4
Meeting with Bruno Tobback (Member of the European Parliament)
4 Oct 2024 · Energy efficiency and energy savings
28 May 2024
EFIEES is the EU trade association representing energy management solutions, covering heating & cooling needs, ventilation, lighting, designed and operated by ESCOs to a wide range of clients: public or private buildings, including collective housing, tertiary buildings, public equipments such as hospitals, sports installations, railway stations, airports, etc, industries (H&C needs, process H&C needs). They commit on long term energy performance/energy efficiency and CO2 gains, notably with energy performance contracting. Some members also operate district heating and cooling (DHC) networks. When defining the orientations on the eligibility of measures and actions to be funded by the Climate Social Fund, the Commission should of course take into account the DNSH, to ensure full consistency with EU energy and climate policies, and to properly steer investments, public support and actions to low or zero carbon solutions. The Social Climate Fund will be key to accompany the costs of the energy transition in the buildings sector that needs a considerable effort to reduce its energy needs and emissions, and therefore a strong public support to energy efficiency actions, as a first step to switching to RES. That includes public support to deep or staged deep renovation, with long-term guaranteed energy performance contracts, support to connection efficient DHC, reduced VAT (not only to energy performant equipment, but to the whole energy management service, and to efficient DHC connection and services). Member States should be able to grant bonus on aid intensity for projects with guaranteed energy performance MS (energy performance contracting). The reflections on how to implementat the DNSH in the Social Climate Fund are a good opportunity to introduce the idea of such a bonus, as it reflects the need to optimise the use of public expenses by promoting actions with contractually guaranteed results.
Read full responseResponse to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)
26 Feb 2024
EFIEES, is the voice of energy efficiency services companies, ESCOs, operating energy management solutions for their clients. As a starting point, conditions to massively deploying energy efficiency projects have to be strengthened, together with conditions for facilitating financing solutions, based on resource from the clients, or from ESCOs, or, last, from third parties. Energy Performance Contracting (EnPCs) is an instrument to initiate and manage projects, not a financing tool as such. It plays the crucial role of an aggregator of tasks, investments and financing, by ensuring guaranteed energy performance, securing investments and cash flows/energy savings. This is why the recommendations by EC Commission to Member States to unlock energy efficiency financing must consider the development of EnPCs as a priority. 1. There is a need for a conducive environment for projects. Regulatory stability is essential to initiate projects, secure their economic and financial aspects. High energy prices are generally speaking a trigger for action, including tools such as a progressive and appropriate carbon price, energy taxation, to be accompanied with instruments to help economic actors, in particular households, to finance the shift to energy and CO2 gains. Conditions and programmes to attract and train skilled staff should also be set up. 2. Public support can be a lever to private financing, with State Aids ensuring projects to reach economic balance. In the buildings sector, staged deep renovation, depending upon projects conditions, should always be eligible to public funds, as deep renovation is, as a trigger for complementary private financing. State Aid intensity should be linked to the size of its beneficiary, not to the projects service providers size, and to the level of the savings not according to the level of investment only. There should be a bonus on State Aid intensity for EnPC based projects, as they contractually guarantee the energy performance over time and thus an efficient use of public support. 3. The role of energy management solutions must be recognised, and their deployment facilitated. As regards the industry sector, professional energy efficiency services to industry should be introduced in the Taxonomy. Generally speaking, more focus should be given on energy efficiency projects in the industry e.g. projects based on the recovery of industrial waste heat, of any origin - with a full recognition at EU and national level. Regarding public clients, public procurement rules must be made compatible with EnPCs, in MS where it is not yet the case. As multitask and long-lasting contracts, they dont always fit with public requirements designed for simpler purchase. In the housing sector, the decision making process in multi-appartments buildings should prioritise energy management and EnPCs solutions. Equipment-only solutions, or works-only solutions, are often easier to decide than contracts with energy performance engagement over time. 4. ESCOs role should be recognised as projects facilitators, as aggregators of all tasks, public support, financing solutions for a given project. EnPCs are one-stop shops. They should be clearly viewed as the final beneficiarys agents for collecting and agregating projects public support. Public subsidies should help ESCOS strengthen the competitiveness of energy efficiency operations. 5. To attract financing from banks and financiers, there is a need for projects to strike the right balance between some standardisation and taylor-made solutions and contracts. An appropriate framework at national level for third party financing, payment by installments, must be developed at national level. Risk hedging mechanisms, providing initial funding, complemented by projects contributions, should be set up to secure the ESCOs investments.
Read full responseResponse to Assessment of the energy efficiency public funding support at Union and national level
26 Feb 2024
EFIEES is the voice of private energy service companies (ESCOs) and their national associations across Europe. Our members represent over 100.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of district heating and cooling networks. EFIEES members report the use of both national and EU public funding for their energy efficiency projects. At EU level, the European Regional Development Fund (ERDF) and the Recovery and Resilience Facility (RRF), are, among others, frequently used for such projects. At national level, there is a great diversity of public fundings for energy efficiency across Europe. Based on its members feedback, EFIEES draws the following two general conclusions when assessing public funding for energy efficiency in the EU. 1) Public funding for energy efficiency should focus more on guaranteed savings overtime. As rightly emphasised by the Commission in its call for evidence, energy efficiency is instrumental to achieve EU carbon neutrality by 2050 while enhancing EU competitiveness and ensuring energy security and affordability. Thus, designing and using public funds in a cost-efficient way is key, especially at a time when public spending is limited. To optimise the use of public subsidies, funding instruments for energy efficiency should prioritise guaranteed energy performance overtime, through solutions such as Energy Performance Contracting (EnPC). Hence, ESCOs - which provide these solutionsshould be able to access certain EU public fundings like the ERDF for their energy efficiency projects. Moreover, depending on how they are designed, public fundings for energy efficiency are often in competition with successful energy efficiency solutions such as Energy Performance Contracts. In some countries like Slovakia and Romania, for a given project, clients will rather turn to a single-action solution under a public funding, focused on equipment or works on the envelop of the building, than to an EnPC project with multiple actions and benefits, combining equipment, works and services. In these cases, we see that public subsidies fail to finance the projects with the highest and longer-term energy savings. Beyond that, public fundings for energy efficiency generally seem to be mostly used for single-action projects. A more efficient way to use these funds would be through projects that include a combination of actions, with ESCOs to play the role of aggregators of tasks, as they have the skills to manage and design multi-actions projects with guaranteed savings overtime. 2) Public funding for energy efficiency should be more predictable and simpler to access. In some Member States, most of energy efficiency projects would not happen without public support. Yet, public fundings for energy efficiency sometimes seem quite difficult to access, to use, or to identify. They can also be perceived as volatile. For instance in Italy, Slovakia and Belgium, EFIEES members report several cases of very attractive - yet limited in time - incentives, which have heavily disrupted specific energy markets (renovation, heat-pumps). A better understanding of available public fundings for energy efficiency would benefit the whole system, leading to a more efficient and tailor-made use of public money. Longer-term funds, coupled with simplification would guarantee a better predictability and mitigate markets distortions. Moreover, there are a lot of well-functioning national public fundings across the EU, like in France and Italy, that allow to boost energy efficiency on the ground. If a EU mechanism could better support energy efficiency projects, it would need to build on and feed already existing and well-designed national funds, while allowing to provide financial support to ESCOs implementing EnPCs and making sure that it does not add complexity to the whole system.
Read full responseEnergy Service Providers Urge Balanced 2040 Climate Targets
23 Jun 2023
Message — EFIEES stresses prioritizing the 'Energy Efficiency First' principle and current 2030 goals. They advocate for energy management solutions and coaching to influence user behavior. The group also warns against creating additional administrative burdens through over-legislation.123
Why — Energy service companies benefit from performance-based service demand while avoiding new costs.45
Impact — Environmental groups lose if fears of over-regulation prevent the adoption of stricter standards.6
Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU
30 Mar 2022
EFIEES welcomes the European Commission’s proposal to recast the Energy Performance of Buildings Directive (EPBD), and notably the focus on cost-effectiveness, as it is of utmost importance to decarbonise the building sector and especially worst-performing buildings, to ensure a just and efficient transition.
EFIEES represents energy service companies (ESCOs) and their national associations in 10 EU Member States. They account for over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling (DHC) networks.
In reaction to the proposal published in December 2021, and with regards to our mission we would like to highlight two key elements that need to be enshrined in the EPBD recast:
1) On the top of accelerating renovation rate, the EPBD should also focus on dynamic energy performance and further promotion of effective energy management
2) Linking energy and environmental performance, especially at a district level, is needed to ensure an effective roll-out of EPBD tools
Please find EFIEES' full feedback on the EPBD recast proposal attached.
Read full responseMeeting with Stefano Grassi (Cabinet of Commissioner Kadri Simson) and Transport and Environment (European Federation for Transport and Environment) and
2 Dec 2021 · EPBD - Energy efficiency - Minimum Energy Performance Standards
Response to Review of Directive 2012/27/EU on energy efficiency
18 Nov 2021
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of private energy service companies (ESCOs) and their national associations in 12 EU Member States (MS). Our members represent over 130.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of District Heating and Cooling (DHC) networks.
We truly welcome the European Commission’s proposal on energy efficiency and support fully the aim of providing a legal basis for applying the Energy efficiency first (EE1st) principle. Below are our main comments and suggestions. For our full feedback, see attachment.
Energy efficiency targets – Raising the Union’s energy efficiency (EE) ambitions into binding targets expressed in both primary and final energy consumption is crucial for the Union’s climate ambitions. However, it is equally important that national efforts align with the targets and that the Union properly monitors, supports, and regulates to achieve them.
Energy savings obligation – Enhancing the energy savings obligation is crucial for achieving the EE targets. However, the way that the MS can count towards fulfilling the obligation must properly serve the aim to increase EE. To this end, we would like to:
> Keep in parallel requirements of counting CO2 savings stemming from the new separated ETS that covers the building sector and energy savings stemming from Article 8 based measures, because hindering “double counting” would be detrimental to successful instruments such as white certificates.
> Delete the exclusion of counting “policy measures regarding the use of direct combustion of fossil fuel technologies” because it would disincentivise important energy savings in existing installations.
> Keep the possibility to count EE improvements of DHC networks as measures for the transformation/distribution/transmission activities to enhance the incentive to decarbonise the heating and cooling system beyond 2023.
Public sector leading on energy efficiency – The renovation rate requirements for public bodies should better promote the benefits of complementary approaches, including energy management solutions such as Energy performance contracting (EnPC) to ensure resource- and cost-efficient energy savings over time.
Heating and cooling – We welcome the new definition of an efficient DHC system in Article 24 towards full decarbonisation of heating and cooling. However, we believe that:
> Some MS or regions (that predominantly rely on coal, facing challenging and massive investment needs, and where DHC is a cornerstone of the heating system) will need more time and support to live up to the milestones in the criteria.
> District solutions should be further recognised for their general benefits and as critical tools for systemic EE gains at the local level.
> A specific definition of efficient district cooling (DC) is formulated following a definition of DC.
Energy management systems and energy audits – We believe that:
> The definition of an Energy management system (EMS) should include a requirement to clearly describe the involved actors, clarify the parties' responsibilities, and ensure the full implementation of the EMS's strategy and objectives.
> A broader scope of exemptions should be possible beyond what is covered under the definition of an EnPC, provided that energy performance criteria and EE improvements are settled.
> EMS and energy audits should result in concrete and duly executed plans to be effective.
Energy services – We are very satisfied that the proposal aims at improving the uptake of energy services and EnPCs in particular. However, work remains to ensure coherence between the measures and increase stringency for mandatory requirements (such as the feasibility assessments of implementing an EnPC) rather than simply encouragements.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
18 Nov 2021
EFIEES is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they also ensure the efficient operation of DHC networks.
To deliver EU climate objectives, energy efficiency and renewable energy developments must go hand in hand, mutually reinforce, and be consistently supported, both at EU and national levels.
EFIEES welcomes the increased overall EU objective for renewable energy (RES). Tackling the untapped potential for energy and emissions savings within the industry sector is also a positive aspect of the proposal, with an overall indicative target of 1.1 ppt annual RES increase (Art. 22a). The positive role of waste heat should also be supported through this new objective.
Yet, the “Energy Efficiency First” principle and energy efficiency measures should be better recognised and supported in the Renewable Energy Directive (RED). To that end, dynamic energy management solutions, such as Energy Performance Contracts, which are key tools targeting both energy and CO2 performance/savings, should be better promoted within the revised RED.
Setting an indicative EU target of 49% renewables in buildings by 2030 is a strong first step to support the sector’s decarbonisation. Nevertheless, the new Article 15a should also support waste heat, potentially by including it in the target, while reminding the importance of the “Energy Efficiency first” principle and focusing on cost-efficiency. Moreover, non-discriminatory treatment between on-site and nearby renewables, already established in the Energy Performance of Buildings Directive (EPBD) must be guaranteed and recalled in this article.
EFIEES welcomes the increased focus on heating and cooling (H&C) decarbonisation and especially the newly binding target of 1.1 ppt annual RES increase in this sector (Art. 23). The role given to waste heat in reaching Member States’ targets will also help to effectively support decarbonisation. The new paragraph (Art. 23 1b) requiring Member States to carry out an assessment of their potential of energy from RES and of the use of waste H&C, and to set out milestones and measures in that regard is also very positive, as it incentivises decarbonisation while adapting to Member States’ different situations. Nevertheless, setting higher targets will require facilitated access to support to Member States, especially in countries still relying mainly on coal as a heating source.
We welcome the more ambitious yet progressive new definition (EED) of efficient District Heating and Cooling (DHC) systems or networks (DHN) promoted in the RED revision, as these are key to support the large-scale decarbonisation of H&C while bringing the best solution to energy poverty. To ensure an effective transition and a smart energy system integration, it is crucial to foster integrated energy planning at the local level (Art. 20a). The raised indicative target for the increase of RES share in DHC sector (2.1 ppt/year) will also reinforce the DHC contribution to the decarbonisation of EU economy. To accelerate this process, the definition of “renewable energy communities” should be opened up so that efficient DHN (and operators) can further participate to local energy projects.
However, when supporting renewables for DHC, coherent and comprehensive system management are key. Thus, on Third Party Access to DHC systems, while the proposal states that “Member States may allow an operator to refuse to connect”, the operator should directly be able to accept or refuse connection, under the defined conditions. Moreover, as transparency is required from DHN operators when refusing to connect a third party (Art. 24(5)), this should be reciprocal and apply to third parties refusing to supply the system with waste heat.
Read full responseResponse to Revision of the Energy Tax Directive
17 Nov 2021
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of private energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals committed to the design and implementation of energy efficiency measures in public and private buildings, industrial facilities, as well as to the efficient operation of district heating and cooling (DHC) networks.
We welcome the European Commission’s proposal for a recast Energy Taxation Directive (ETD), which sends a clear pricing signal to benefit both energy efficiency (EE) and the uptake of renewable energy. The proposal aims to effectively align the tax system for energy products with the Union's energy and climate policies, promote clean technologies, reduce the scope of applying outdated exemptions and reduced rates, and prevent the implementation of divergent national rates.
We believe that this recast should be an occasion to foster and facilitate the decarbonisation of the heating sector through:
> Enabling the most favourable treatment of solutions such as biomass;
> Focusing on the potential of EE measures as a prerequisite to fuel switch and key to optimising any heating installation, whether using renewable energy sources or not.
Decarbonising the heating sector:
We welcome a higher price on the highest emitting heating fuels as an essential tool to enhance the attractiveness of EE and decarbonisation. However, we believe that the levels proposed for biomass products do not reflect their main carbon neutrality advantages. Since biomass products are the most price-efficient and accessible tools for fast transitioning to a renewable heating system while benefiting the local economy, the ETD should adapt the pricing signals and further increase the differential between fossil and renewable energy.
Therefore, we propose that the minimum level of taxation applicable to heating fuels living up to the sustainability and greenhouse gas emission saving criteria for biomass in the Renewable Energy Directive (RED) is reduced to zero. Doing so, the ETD would also be more consistent with the proposed revision of EU ETS, having an emission factor of these products set at a default value of zero.
Reduced and better conditioned exemptions:
We welcome the proposal’s intention to reduce the number of possible exemptions and reductions to ensure consistency and a level playing field. However, while certain exemptions and reductions will remain necessary, we believe they must be duly justified and conditioned based on environmental performance and EE.
In the industry sector, in particular, taxation schemes should be designed to avoid creating any significant disadvantage against competitors outside the EU, and an adequate tax level should act as a price signal to support EE. Hence, tax reductions should be linked to a stringent definition or verifiable efforts (see Article 18). In addition, they should be attached to effective commitments to adopt solutions such as energy management systems, energy performance contracting, or similar arrangements based on a guaranteed energy performance criterion.
Likewise, we believe that too generous reductions for households might lead, in some cases, to skewed incentives. Fighting energy poverty should be prioritised. However, pricing incentives to reduce consumption of fossil fuels should remain and be coupled with support to EE actions that reduce energy bills.
For example, targeted support should be possible for district heating consumers. District heating ensures indeed better energy efficiency at a community level, including for vulnerable- and energy-poor households. Adequate pricing levels coupled with energy efficiency actions would help to alleviate energy poverty in the long run. If necessary, additional social instruments at the European, local or national level should be available, targeting the households needing it most.
Read full response8 Nov 2021
EFIEES is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they also ensure the efficient operation of District Heating and Cooling (DHC) networks.
We welcome the proposed revised EU ETS, with new, stronger, ambitions, and the introduction of a carbon price in the sectors that are currently not covered by emissions trading, notably the building sector, provided that such a scheme is properly implemented, reliable, while avoiding heavy additional administrative burden.
Introducing an ETS mechanism for buildings is the direction chosen by the EU Commission to support this sector’s decarbonisation. In this respect, creating a separate ETS, while following an upstream approach, seems to be the best available option. The priority must be to ensure a coherent carbon price across different sectors, to allow for a fair “burden sharing” and a real level playing field within the heating and cooling sector, between individual and district solutions for buildings.
This new ETS scheme must be introduced in a progressive manner, to prevent market distortions and ensure affordability to protect the most vulnerable households.
Maintaining the building sector under the Effort Sharing Regulation (ESR) will also help guarantee that the carbon price mechanism and the overall ETS review are effective and conducive to actual CO2 emission reduction in this sector. The ESR is indeed essential so that Member States maintain committed national climate policies and thus ambitious energy efficiency measures, and carbon pricing must be accompanied by the right regulatory tools.
EFIEES welcomes the prioritisation of Energy Efficiency actions under the Modernisation fund, and the creation of the Social Climate Fund (SCF). However, to be effective, the SCF needs to be given sufficient financial resources, even more so as it is a key tool to ensure that the introduction of carbon price for buildings does not penalise most vulnerable households.
Moreover, when designing the SCF and resulting national Plans, the “Energy Efficiency First” principle and energy efficiency measures should be better recognised as essential means to support vulnerable citizens.
Thus, the eligibility for support through SCF of energy management solutions, such as Energy Performance Contracts (EnPCs) must be guaranteed. We advocate for their inclusion and recognition as energy efficiency and building renovation tools, given they allow to target both energy performance and CO2 savings.
The Social Climate Fund should also support the decarbonisation of DHC systems, as they accelerate the decarbonisation of the buildings, enable sector integration, while protecting citizens against energy poverty. To ensure a level playing field, no differences should be made between on-site and nearby renewables, following the non-discriminatory principle affirmed in the Energy Performance Buildings Directive . We thus propose to amend the definition of “building renovation” (Art. 2 SCF proposal) to include a switch to renewable and low carbon energy from nearby sources.
Following the same goals of social acceptance and affordability, in countries where a vast majority of DH systems are very large and based on coal, the Modernisation Fund should continue supporting, in a transitory manner, investments enabling the switch from coal to natural gas, where the availability of renewable solutions is limited in the short term. To benefit from such a support, the concerned DHC operators should engage in a roadmap, compatible with the national 2050 carbon neutrality plan, based on growing use of RES/Waste heat, and energy efficiency gains.
Read full responseResponse to Updating the EU Emissions Trading System
8 Nov 2021
EFIEES is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they also ensure the efficient operation of District Heating and Cooling (DHC) networks.
We welcome the proposed revised EU ETS, with new, stronger, ambitions, and the introduction of a carbon price in the sectors that are currently not covered by emissions trading, notably the building sector, provided that such a scheme is properly implemented, reliable, while avoiding heavy additional administrative burden.
Introducing an ETS mechanism for buildings is the direction chosen by the EU Commission to support this sector’s decarbonisation. In this respect, creating a separate ETS, while following an upstream approach, seems to be the best available option. The priority must be to ensure a coherent carbon price across different sectors, to allow for a fair “burden sharing” and a real level playing field within the heating and cooling sector, between individual and district solutions for buildings.
This new ETS scheme must be introduced in a progressive manner, to prevent market distortions and ensure affordability to protect the most vulnerable households.
Maintaining the building sector under the Effort Sharing Regulation (ESR) will also help guarantee that the carbon price mechanism and the overall ETS review are effective and conducive to actual CO2 emission reduction in this sector. The ESR is indeed essential so that Member States maintain committed national climate policies and thus ambitious energy efficiency measures, and carbon pricing must be accompanied by the right regulatory tools.
EFIEES welcomes the prioritisation of Energy Efficiency actions under the Modernisation fund, and the creation of the Social Climate Fund (SCF). However, to be effective, the SCF needs to be given sufficient financial resources, even more so as it is a key tool to ensure that the introduction of carbon price for buildings does not penalise most vulnerable households.
Moreover, when designing the SCF and resulting national Plans, the “Energy Efficiency First” principle and energy efficiency measures should be better recognised as essential means to support vulnerable citizens.
Thus, the eligibility for support through SCF of energy management solutions, such as Energy Performance Contracts (EnPCs) must be guaranteed. We advocate for their inclusion and recognition as energy efficiency and building renovation tools, given they allow to target both energy performance and CO2 savings.
The Social Climate Fund should also support the decarbonisation of DHC systems, as they accelerate the decarbonisation of the buildings, enable sector integration, while protecting citizens against energy poverty. To ensure a level playing field, no differences should be made between on-site and nearby renewables, following the non-discriminatory principle affirmed in the Energy Performance Buildings Directive . We thus propose to amend the definition of “building renovation” (Art. 2 SCF proposal) to include a switch to renewable and low carbon energy from nearby sources.
Following the same goals of social acceptance and affordability, in countries where a vast majority of DH systems are very large and based on coal, the Modernisation Fund should continue supporting, in a transitory manner, investments enabling the switch from coal to natural gas, where the availability of renewable solutions is limited in the short term. To benefit from such a support, the concerned DHC operators should engage in a roadmap, compatible with the national 2050 carbon neutrality plan, based on growing use of RES/Waste heat, and energy efficiency gains.
Read full responseResponse to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information
2 Jun 2021
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions. We are welcoming the ambition to increase transparency by creating a Taxonomy that aims at enhancing sustainability-related disclosure by financial and non-financial undertakings. In this respect, we believe that an effective non-financial reporting relating to the Taxonomy could be achieved, provided that certain conditions as regards usability, coherence, and proportionality are met and properly clarified in the upcoming delegated act, to be adopted under Article 8 of the Taxonomy Regulation.
1. Sustainable activities should be deemed so throughout the economic lifetime of the corresponding assets: whilst we recognize that technical screening criteria and thresholds require a periodic review and update, to ensure compliance with the zero-net emission target by 2050, it is essential to provide investors and companies with the necessary regulatory stability and visibility. Therefore, it is of utmost importance to ensure that activities that are compliant with the technical screening criteria developed by the Taxonomy at the time when they are reported, can be considered as environmentally sustainable throughout the entire economic lifetime of the assets on which they operate. This is key to guarantee that virtuous investments are encouraged and not prevented by lack of stability and uncertainty about the status of future investments.
2. Reporting should include Taxonomy-aligned activities in companies’ portfolios if considered sustainable in the past but yet not meeting today’s criteria for Taxonomy eligibility: the extension of the Taxonomy reporting obligations beyond financial market participants needs primarily to ensure that companies are incentivised in greening their portfolios, making them actors of the energy transition, and in increasing their share of Taxonomy-eligible activities. For the whole course of the remaining depreciation time of the corresponding assets, activities, and investments that have been promoted or supported by EU and national legislation over the past few years should nevertheless be able to be reported as ‘sustainable’ by undertakings, to the same extent as those already classified in the Taxonomy and even if they do not necessarily meet the relevant technical screening criteria established by the latter. The real economy needs indeed a reasonable timeframe for adapting to the requirements of the Taxonomy and support to certain economic activities cannot be denied overnight, without any expedient to accompany the transition. The inclusion of activities supported by such assets that were deemed, at the time of the investment, as supporting the climate transition could be limited to those complying with the Do-No-Significant-Harm (DNSH) conditions in force at the time of the reporting.
3. Striking the right balance between transparency and complexity/cost: EFIEES supports the objective of presenting in the non-financial reporting relevant KPIs to assess the extent of sustainability of undertakings’ activities and provide the appropriate supporting information. However, the required level of detail should not constitute an administrative burden for actors already actively engaged in supporting the energy and climate transition. The disclosed information should be limited to what is necessary for the private investor to evaluate the activity’s Taxonomy eligibility and alignment of activities. For instance, reporting on OPEX will not give useful information to investors, and may even pose confidentiality problems, while increasing complexity of the reporting. Similarly, as historical data are available in the previous years’ reporting, EFIEES suggest limiting the requirement of art.9.3, to 2 years.
Read full responseResponse to Revision of the Energy Performance of Buildings Directive 2010/31/EU
22 Mar 2021
EFIEES represents energy service companies and their national associations in 12 EU Member States. They account for over 130.000 professionals engaged in the design and implementation of energy efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling networks.
In light of the renewed climate ambition for 2030 and of the long-term climate neutrality goal, EFIEES welcomes a review of the Energy Performance of Buildings Directive (EPBD), in line with the objectives and actions announced in the Renovation Wave.
As buildings are expected to play a critical role in the decarbonisation efforts which will be required in the years ahead, it is important not only to ensure the EPBD adequately contributes to the achievement of the EU’s climate and energy objectives, but also that it is fully consistent with the entire legislative framework which is going to be addressed by the “Fit for 55 Package”.
Furthermore, a proper implementation of existing legislation remains key and should be further secured.
Considering these elements and the options specifically outlined in the inception impact assessment for the EPBD review, we would recommend the following:
- Consider dynamic energy performance and promote effective energy management -
A revision of the EPBD would represent an occasion to focus not only on increasing renovation rates and depths, but also on the role of solutions that allow to keep and improve energy performance over time, through proactive energy management. These should systematically be considered as a complement to building renovations, and they should be mandatorily required, where relevant, depending on buildings’ type, use and needs.
Hence, energy management options, such as Energy Performance Contracting (EnPCs), which additionally guarantees a certain level of energy performance, should be further promoted within the EPBD and be better reflected in a strengthened framework for Energy Performance Certificates and potential Building Renovation Passports. In both contexts, primary energy gains should remain the main indicator of energy performance.
A possible “deep renovation” standard should also encompass a more dynamic approach to buildings’ energy performance and require relevant projects to include at least energy management and monitoring of energy performance.
If mandatory Minimum Energy Performance Standards (MEPS) are going to be set for certain categories of buildings, it is also essential to ensure that these are efficiently operated over time.
- Link energy and environmental performance, possibly on a district scale -
If energy efficiency must be the prerequisite for any other decarbonisation action (Energy Efficiency First), it is nevertheless essential to improve the overall environmental performance of buildings, by enhancing efficient and renewable energy supply.
The current EPBD already allows for that in its Annex I, on the general framework for the calculation of buildings’ energy performance. The Annex rightly refers to primary energy as the main performance indicator. Moreover, it allows to consider in the relevant calculations renewable energy supplied through the energy carrier as well as generated on-site, based on a non-discriminatory treatment. Should possible RES requirements be introduced for the building sector, it is essential to fully apply this principle and ensure a non-discriminatory treatment between on-site and nearby RES.
Buildings should then be inscribed in broader decarbonisation plans addressing entire neighbourhoods and districts, necessarily linking renovations with local energy planning, in particular when it comes to decarbonising heating and cooling.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
18 Dec 2020
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they operate district heating & cooling networks.
Considering the numerous exchanges and the advocacy efforts carried out in the last two years, we are rather satisfied with what is now proposed in the first draft delegated act, in particular concerning technical screening criteria developed in the building sector.
However, some issues in the present draft and in the overall Taxonomy-design still need to be clarified and possibly reviewed.
More specifically, and notably in relation to climate change mitigation activities, we would like to highlight the following, in relation to draft technical screening criteria:
- We strongly welcome the inclusion of the new category “Professional services related to energy performance of buildings”, covering key solutions such as energy management services, energy performance contracts and other energy services provided by ESCOs as enabling activities. This is a very important step forward to finally recognise the role of effective energy management in delivering actual energy savings over time and in any category of buildings.
We nevertheless regret that the benefits of energy management are currently neglected in the industrial sector, in which they have a high potential as well. We therefore call for the inclusion, in the Manufacturing section, of a new correspondent category encompassing “Professional services related to energy performance in industry”.
- A similar approach should also be applied to the ICT sector, particularly for data centres, which equally need to become more efficient and where effective energy management can help identify and implement solutions to optimise energy consumption in the long-term. Criteria developed for “Data processing, hosting and related activities” should thus include a specific reference to the above-mentioned energy management services, envisaged at present only for buildings.
- Considering the key role of bioenergy in greening the energy mix across Europe, we are disappointed to see that the use of sustainable biomass for energy generation is currently indicated as a transitional activity in the draft act, differently from other renewable energy sources. Moreover, as long as biomass, biogas and biofuels comply with the relevant sustainability criteria, their use for the purposes of energy production should be fully considered as sustainable.
As additional general remarks, we would also add that:
- It is crucial to ensure that activities that are compliant with the relevant technical screening criteria at the time when they are evaluated, can be considered as Taxonomy-eligible at least throughout their economic lifetime. As already reiterated in the past, this point should be explained and stated in a clearer way, to provide companies and investors with the necessary stability and certainty they need.
- Similarly, it is essential to make sure that activities which in the past few years have been promoted and even benefited from public support, both at the EU and national level, because of their environmental contribution, can still be considered as sustainable, also within the framework of the Taxonomy and even if they do not necessarily meet the new specific thresholds, for the duration of their residual economic lifetime.
- Finally, while it is clear that for achieving climate neutrality much deeper efforts will be needed in the next three decades, thresholds – notably for CO2 emissions – should evolve in a gradual and progressive way, in line also with technological development, and taking into account the specific starting points of Member States.
Read full responseResponse to Revision of the Energy and Environmental Aid Guidelines (EEAG)
10 Dec 2020
EFIEES’ feedback to the Public Consultation on State Aids
EFIEES represents energy service companies (ESCOs) and their national associations in 12 Member States. They represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling (DHC) networks.
Generally speaking, we deem the current scope of EEAG to be adequate with regard to activities covered by our members.
But the existing rules should be improved, in order to deliver on the EU Green Deal enhanced ambition. State Aids improve the economic viability of projects, as an absolute necessity for viable, profitable “green” projects to emerge, aligning State Aids rules with other climate related policies and regulations.
Revising State Aid principles should fully take into consideration:
- The “Energy efficiency First” principle. Energy efficiency (EE) actions are often, if not always, a crucial prerequisite for actions to switch from fossil fuels to renewable energy, by reducing the energy demand and thus optimising the size of the investments allowing a greener energy mix.
- The role of energy services, of performance-based contracts, needs to be better recognised in the State Aid rules, to help making energy supply and demand more efficient.
- There should be a stronger support to projects based on Energy Performance Contracts (EnPCs), with contractually guaranteed results, actual and verified energy savings/performance, energy management over time, to maintain energy performance and savings.
o A bonus should be foreseen in the State Aid rules for the EE projects based on an energy guaranteed performance, such as the one provided by EnPCs. That would be also consistent with other EU regulatory provisions recognising the benefits of such contractual guarantee.
o This bonus could consist in an increased aid intensity, fully in line with the Energy Efficiency First principle. The criterion to define this green bonus should be the certainty of the savings/performance, measured and verified, over time.
A second main request from EFIEES is to make sure that there will still be:
- A strong support for the decarbonisation of heating and cooling, as heating and cooling needs account for half of the energy consumption across EU, while fossil fuels low prices, and (still) low CO2 price signal hamper the competitiveness of energy efficiency/RES-based projects.
- District Heating and Cooling networks (DHC) are key for decarbonising the H& C sector. They allow to mobilise energy and carbon efficient solutions, in particular with regard to the recovery of waste heat, and locally available renewable energies. They are the first renewable energy vector for H & C in urban areas. They also contribute to “energy sector integration” and can play a role in flexible energy solutions (e.g. thermal storage).
- The creation, the extension of DHC networks, the increase of density, the modernisation and greening of their energy mix must remain priority actions under State aids.
- State Aid rules should continue support projects aiming DHC networks to become efficient, (EED definition), provided that there is a clear 5-year trajectory to implement the project’s commitment and foreseen final result.
- Maximum intensity threshold should be given consideration, to ensure projects will emerge even if fossil fuel suddenly decrease or fluctuate. Member States would have the flexibility to grant the required level of public support, whilst avoiding market distortions.
Actions that contribute to the GHG reduction, whether through energy consumption reduction, or through the development of renewable energies, should benefit from the appropriate support. Member States design NECPs that reflect their strategies for reaching their climate objectives. These NECPs are a good basis for assessing the energy and environmental benefit of
Read full response26 Nov 2020
EFIEES, the EU Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they also ensure the efficient operation of district heating & cooling networks.
We welcome this initiative, as it is closely linked with the upcoming review of the EU ETS, with which the ESR will necessarily need to be addressed in a coordinated and coherent manner, if we want both instruments to effectively contribute to the new 2030 climate target and to the ultimate goal of climate neutrality. Hence, we would like to reiterate here some of our main messages about the EU ETS extension and on how an effective carbon pricing, accompanied by the right regulatory tools, can deliver on these goals. In particular, we would like to highlight the following:
- An increased and uniform carbon price is needed
The key element currently missing, and which is absolutely critical to ensure all sectors effectively and fairly contribute to the much needed decarbonisation efforts, is a robust, uniform and predictable carbon price, covering also those sectors that are, at present, not subject to the EU ETS, notably buildings. Establishing a uniform carbon price in the building sector would allow for a fair “burden sharing” and a real level playing field with respect to the additional efforts that will be required towards climate neutrality. It will help trigger real and widespread decarbonisation actions, in terms of both energy efficiency and fuel switch.
- Coherence between the available tools must be ensured
To establish a well-functioning carbon pricing mechanism, the synergies between the relevant available policy instruments, notably the ETS, the ESR, but also the ETD and the future CBAM (concerning the external dimension), will need to be fully exploited. Consistency between the different tools will also need to be ensured. The different pieces of legislation will indeed need to be part of a broad and coherent picture, in which carbon price acts as an effective trigger for decarbonisation, along with other instruments.
- High impact policies must accompany carbon pricing
Developing a wider carbon pricing mechanism, for instance, through a much-needed extension of the ETS to buildings, does not imply that other regulatory measures will become useless. On the contrary, strong legislative tools will be essential to ensure that carbon price will work properly and further incentivise the needed investments and measures towards climate neutrality.
That’s why the entire EU climate and energy legislation, especially the EED, EPBD and RED, will need to be strengthened to push for more energy efficiency in the long run, better energy management, energy recovery and greater focus on H&C decarbonisation, amongst the key priorities.
If we consider the building sector, carbon price will need to be in line with all the other tools identified by the Renovation Wave as necessary to increase the energy efficiency of the building stock (and vice versa).
- Put in place a “just” carbon pricing design
The overall carbon pricing mechanism and accompanying legislative tools will have to ensure that the greater decarbonisation efforts will not have a negative impact on most vulnerable consumers and poor households, so as to avoid that the higher energy prices result in increased energy poverty. Hence, it is crucial to address the social and distributive impacts of a possible ETS extension, especially to buildings, in a spirit of solidarity and support for a just transition. Tackling these aspects will require a rethinking of existing instruments and the possible introduction of new tools for ETS revenues’ recycling, to be used to support the categories mostly in need.
Read full responseResponse to Updating the EU Emissions Trading System
26 Nov 2020
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they also ensure the efficient operation of district heating & cooling networks.
We welcome the objective of this initiative, which aims to revise and possibly extend the EU ETS, in order to meet the renewed climate ambition for 2030 and the long-term goal of climate neutrality by 2050, while taking into account the need for a just transition and ensuring that all sectors contribute to the EU climate efforts in a fair way.
In particular, we fully support the introduction of a carbon price in those sectors that are currently not covered by emissions trading, notably the building sector, provided that such a scheme is properly designed and implemented.
In light of this, we would like to stress the following elements, which need to be duly considered when planning the upcoming review of the EU ETS:
- The main priority of this and related initiatives should be that of establishing a uniform carbon price across different sectors, to allow for a fair “burden sharing” and a real level playing field when it comes to require increased efforts on the trajectory towards climate neutrality. To achieve this, the synergies between available policy instruments (the ETS, the ESR, the ETD and the CBAM, for the external dimension) should be fully exploited, and coherence between the different tools should be imperatively ensured. The future mechanism should, as much as possible, lead to a stable, predictable and progressive carbon price.
- Moreover, a carbon price mechanism and an overall ETS review should be fair:
o On the one hand, this means that market distortions should be avoided and that sectors already covered by the scheme today should not bear the consequences of its extension. The higher the ambition, the larger the scope needs to be.
o On the other hand, this implies that the social and distributive impacts of a possible ETS extension to other sectors, especially buildings, should be addressed in the spirit of solidarity, support for a just transition and protection of the most vulnerable households. Tackling these aspects requires a rethinking of existing instruments and a possible introduction of new mechanisms for ETS revenues’ recycling, to be used to support poor households and vulnerable consumers.
- As the ultimate goal of carbon pricing is to lead towards increasing emission reductions, decarbonisation actions, such as fuel-switching and energy efficiency improvements, should be strongly incentivised, also through revenues’ recycling and new supporting instruments.
- An extended ETS covering the building sector could only work if built “upstream ”: as it would be difficult to actively involve individual consumers and building owners in the trading scheme and its dynamics, such a system should ideally be based on the active engagement of energy distributors.
- Finally, the proposed reduction to the allowances’ cap must go hand in hand with the progressive increase of the linear reduction factor, which both need to be addressed in a consistent way. A possible review of the MSR will necessarily depend on the interactions between the former and the overall functioning of the system.
Read full responseResponse to Revision of the Renewable Energy Directive (EU) 2018/2001
21 Sept 2020
EFIEES represents energy service companies (ESCOs) and their national associations in 12 Member States. They represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling networks.
Paving the way for a robust green recovery, while ensuring that the EU policy framework is adequate to meet the challenge of climate neutrality, not only requires a clear enforcement and, where relevant, a review of existing legislation, but also greater consistency between the different pieces of legislation. This is particularly true for the RED and other Directives, such as the EED and ETD.
Should the higher climate ambition lead to an effective review of RED in 2021, we would like to make the two following recommendations:
- Renewable Energy must be Efficient Energy too -
If we are to deliver on an increased ambition for 2030, we must ensure that the development of energy efficiency (EE) and renewable energies (RES) goes hand in hand and that it is consistently promoted and supported, at the EU and Member States’ level.
In fact, EE improvements should be prioritised, even in the field of RES, in line with the Energy Efficiency First principle, as set out in the Governance Regulation. This overarching principle requires indeed to take into utmost consideration, in energy planning as well as in policy and investment decisions, cost-efficient measures that make both energy demand and supply more efficient. This should be fully applied to the generation, distribution and consumption of all types of RES as well.
In particular, the optimisation of energy demand and of the energy performance of buildings and facilities through effective energy management should be actively promoted also with respect to RES installations.
Solutions that are clearly based on an energy performance criterion, or that even guarantee a certain level of renewable energy supplied or a maximum CO2 level, should be explicitly supported within the Directive. This would also ensure greater consistency with the EED and make EE and RES mutually enforcing.
- Decarbonising Heating & Cooling must be a priority -
While renewable electricity has been steadily developing over the past years, thanks also to considerable public support, renewable heating and cooling (H&C) is lagging behind. Considering that H&C accounts for about 50% of the EU energy consumption, more efforts in this area are urgently required.
Even if the REDII finally included a dedicated section on H&C, there is still a need for a greater focus on the decarbonisation of the sector.
Should the ambition on renewable energy be increased, it should notably be achieved through a higher annual target for renewable heat. This would allow for a greater deployment of renewable and recovered energies, such as waste heat and cold, and of virtuous supply solutions at local level, such as efficient district heating & cooling (DHC). A higher role of renewable gases (biomethane, green hydrogen) in heating and cooling should also be emphasized.
In particular, the existing articles should be complemented by new provisions to ensure that:
a) the necessary economic support for the required investments is available;
b) the envisaged financial support framework is clear and predictable;
c) a favourable regulatory framework is created at different government levels to maximise the use of renewable and recovered energy sources;
d) no discrimination between “on-site” and “off-site” solutions is made, in line with the current EPBD;
e) the benefits of connecting to efficient DHC systems are fully recognised, where relevant.
Read full responseResponse to Review of Directive 2012/27/EU on energy efficiency
21 Sept 2020
EFIEES represents energy service companies (ESCOs) and their national associations in 12 Member States. They represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling networks. 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, we would like to preliminarily recommend 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 MS 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 Art. 18. However, many provisions just call on MS to encourage the development of the EES market, without requiring the enforcement of mandatory measures.
Moreover, the role of energy management should be better and further promoted across different parts of the Directive, including:
a) Article 5 on public buildings, where the 3% annual renovation obligation should be expanded and complemented by the requirement to follow and effectively manage energy consumption. This would ensure that buildings are not only refurbished, but that their energy is used properly over time.
b) Article 8 on energy audits, which should lead to implement actions, and prioritise solutions that not only encompass the equivalent effect of an audit, but are also based on an energy performance criterion and comprise concrete actions to improve energy consumption.
c) Potential new provisions to address tertiary buildings, including for example specific performance targets or energy management requirements for large non-residential buildings, should also be implemented to ensure they fulfil an exemplary role and actively contribute to emissions reduction as well.
- 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. The latter should indeed reflect the outcome of the comprehensive assessment of national heating and cooling potentials, to be conducted by MS according to a revised Annex VIII.
Read full responseResponse to Strategy for smart sector integration
8 Jun 2020
EFIEES represents energy service companies (ESCOs) and their national associations in 12 Member States. They represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling networks. EFIEES welcomes the roadmap for the upcoming Strategy on energy sector integration, which aims at creating a smarter, more integrated and optimised energy system, in which all sectors can fully contribute to decarbonisation and help achieve the long-term objectives of the EU Green Deal.
We are convinced that an effective energy sector integration should rely on the following elements:
1. As a necessary precondition, a truly integrated energy system should ensure the proper application of the Energy Efficiency First principle, as defined by the Governance Regulation. This requires the prioritisation of energy efficiency actions along the whole energy chain, from supply to demand, to ensure that energy is produced, distributed and then consumed in an efficient and intelligent way across the different systems.
2. A really integrated energy system should go beyond the binary concept of ‘sector coupling’ (referring exclusively to the integration of the electricity and gas sectors) and fully comprise the heating & cooling sector. This can indeed play a major role in facilitating the decarbonisation of our energy systems by supporting overall system flexibility and security. Existing thermal solutions, based on hot water systems, offer storage and backup options at building and district level, together with the use of decarbonised sources. By providing for efficient and increasingly green energy supply, efficient district heating & cooling (DHC) networks also allow for energy recovery at local level. Finally, cogeneration is intrinsically an energy integration example, especially when highly-efficient and combined with DHC, providing for additional support to energy system stability and balancing.
3. A smart and integrated energy system is facilitated by the process of digitalisation, where efficient ICT technologies enable communication between various parts of systems, sectors and infrastructures, and help manage synergies, creating opportunities for energy savings and reduced emissions. To fully exploit the benefits deriving from increasing digitalisation, it is in any case essential to recognise the enhanced value of the combination of ICT technologies and proactive energy management, provided by energy efficiency services (EES).
4. EES play a key role and have a huge cost-effectiveness potential across different sectors, including the building sector, which will be central in the dynamic of future energy system integration. The optimisation of buildings’ energy consumption, thanks to renovations and effective energy management, can indeed support the further uptake of renewable and recovered energies both at building and district levels. The same can be said for the optimisation of energy consumption in industrial sites and platforms, where EES can enable energy efficiency gains and enhance circularity.
5. As stated in the Roadmap, improve the circularity of our energy systems is an essential factor for a successful and efficient energy sector integration. In particular, this implies making the best use of the energy which is available in our systems - especially at local level - and allowing for the identification and effective reuse of energies which would otherwise be wasted, such as waste heat and cold. Waste heat and, in general, ‘waste energy’ potential should indeed be better considered, assessed and integrated into local energy planning. This should be addressed through a district approach, which is essential to ensure that all systems’ synergies and local opportunities are duly assessed and fully exploited, in a way to effectively contribute to a successful, resilient and integrated energy system.
Read full responseResponse to Commission Communication – "Renovation wave" initiative for the building sector
8 Jun 2020
EFIEES represents energy service companies (ESCOs) and their national associations in 12 Member States. They represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling networks.
EFIEES welcomes the roadmap for the forthcoming Renovation Wave initiative, which is expected to play a critical role within the Green Deal and in the economic recovery post-Covid19. For this to happen in an effective way, we strongly recommend to take into account the following considerations:
1. At a time when public budgets face several constrains and are deprived of a large amount of resources, attention to cost-effectiveness is of utmost importance. As highlighted by the European Court of Auditors in its Special Report 11/2020, on the use of cohesion policy funds for energy efficiency upgrades in buildings, more cost-effectiveness is needed both in the selection and financing of energy efficiency projects. This implies prioritising solutions based on criteria such as the cost per unit of energy saved, as well as ensuring that measures are chosen based on buildings’ specific conditions and needs.
2. The Renovation Wave is also the occasion to reinforce current legislation – or create new policy, where needed - to ensure that energy savings are real (i.e. measurable and verifiable) and that improved energy performance is maintained over time, thanks to proactive energy management. Solutions delivering these benefits already exist and are offered by energy efficiency services (EES).
3. EES typically provided by ESCOs, such as energy performance contracts (EPCs) and other forms of energy management schemes - i.e. solutions encompassing a set of planned actions, defined roles and responsibilities - should thus be further promoted. In particular, as they represent a necessary complement to renovations to ensure that actual energy performance is kept, and even contractually guaranteed, in the case of EPCs. Hence, they should be fully integrated in potential Building Renovation Passports or similar long-term strategies, also at district level.
Moreover, when (deep) renovation is unfeasible or unnecessary, they constitute the most cost-effective alternative to renovation actions. The latest TEG's Taxonomy report, including recommendations to the Commission on the adoption of the first delegated act on Sustainable Finance, already recognises such solutions as sustainable and thus eligible under the Taxonomy. This should be confirmed in the final delegated act, as well as in other key pieces of legislation (such as the EED), which should ideally make energy management a mandatory requirement for some categories of buildings.
4. The energy and carbon performance of the building stock is not only the result of renovations, but it also depends on the progressive and continuous decarbonisation of the heating & cooling (H&C) sector, accounting for about 50% of the EU energy consumption. In this respect, the role of existing thermal solutions making H&C generation and distribution more efficient should not be neglected, along with the necessary increase in the deployment of renewable and recovered energies.
5. A smart and all-embracing Renovation Wave should not only aim to improve single buildings’ performance, but to achieve energy efficient and decarbonised districts, in which the synergies between buildings, their environment and the locally available energy sources are clearly identified and fully exploited. For this to be realised, local and integrated energy planning should be fostered and become an essential element of national strategies designed to contribute to the achievement of energy efficiency and decarbonisation objectives. A proper energy planning should in any case be implemented following the Energy Efficiency First principle, prioritising energy efficiency options along the whole energy chain.
Read full responseResponse to Climate change mitigation and adaptation taxonomy
27 Apr 2020
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they operate district heating & cooling networks. We welcome the Regulation on Sustainable Finance as agreed in December 2019 and the latest TEG Report of March 2020, proposing updated technical screening criteria for climate change mitigation and adaptation.
The process conducted by the TEG over the past two years, in which EFIEES has been actively engaging, has resulted in a report that will constitute the basis of the first delegated act supplementing the Regulation. To guarantee its success and effectiveness, we feel that a number of key issues still need to be better addressed and further clarified. We would hence put forward the following remarks and recommendations, notably with respect to activities substantially contributing to climate change mitigation:
1. We understand that activities that are compliant with the thresholds required by the Taxonomy at time when they are evaluated as eligible, can be considered as environmentally sustainable throughout their life-time. This point should be explained and stated in a clearer way, as a key element to provide companies and investors with the necessary stability and certainty they need.
2. The Taxonomy was initially conceived just as a tool for financial market participants. The extension of the Taxonomy obligations to companies, notably in terms of non-financial reporting (NFR), risks to penalise early movers that put in place activities which were considered as environmentally sustainable before the Taxonomy was established (e.g. by national support schemes or programmes), but which currently fail to meet the thresholds.
In order to avoid penalising companies that started early actions, with assets to be reported for long years in NFR, it is crucial to consider and explore the possibilities to set up an ad-hoc ‘inclusion’ regime for sustainable activities implemented a few years before the entry into force of the Taxonomy, which however fail to meet the relevant Taxonomy-thresholds, while still considerably contributing to climate change mitigation.
3. The Heating & Cooling (H&C) sector, representing about half of the EU energy consumption and where decarbonisation efforts are particularly challenging, is now addressed in the final TEG report in a way that reflects that thermal solutions can effectively lead to decarbonising this sector and hence fully support a carbon neutral economy. Nevertheless, some adjustments still need to be done in the Taxonomy, by making eligible a number of energy efficiency solutions, both for H&C production and distribution, and allowing for full eligibility of waste heat recovery from any origin and for any user.
4. More generally, the impact of metrics and thresholds recently revised by the TEG, based on feedback from 2019, should be evaluated and adapted so that the Taxonomy could fulfil its role as an incentive for mobilising green investments, even in the post-Covid-19 economic context. For the Taxonomy to mobilise investments in a far less favourable situation, the EU legislator must carefully assess the level of ambition and adapt the first necessary steps to the new economic situation.
5. We welcome the inclusion of energy efficiency services, such as energy management and energy performance contracts, among the eligible professional services in buildings and we strongly recommend their further inclusion, which should also cover industry, in the upcoming delegated act.
6. In setting criteria for climate change mitigation, we finally recommend the application of "Energy Efficiency First” as the guiding principle for emissions reduction.
Read full responseResponse to EU rules on industrial emissions - revision
21 Apr 2020
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and in industrial facilities. In some countries, they also ensure the efficient operation of district heating & cooling networks.
1. A reminder of EFIEES’ response to the public consultation of 13 September 2019:
- EFIEES, as most industrial stakeholders, agreed on the environmental benefits resulting from the whole EU regulatory process since the IPPC Directive. We acknowledged the progress in the process leading to setting up the BAT conclusions, which cover the most significant environmental impacts. However, we expressed a more nuanced opinion on the fact that the combination of best available techniques do not necessarily lead to the best solution.
- EFIEES also mentioned that, according to its members’ experience, MS have put in place an IED-based permitting system.
- EFIEES also expressed some nuanced views on whether or not the BREFs process properly took into consideration the compliance and operational costs.
- EFIEES did not express an opinion on whether IED “should remain relevant to rapidly adapt to a zero-carbon economy by 2050”, due to the way the question was asked. To us, the IED should not be THE instrument to reduce CO2 emissions through permitting. It is not fit for such a purpose. Existing energy efficiency requirements in many BATs are better adapted for reaching such objective.
2. Why revising the IED?
The public evaluation of the Directive was based on general considerations. No conclusions were reached on a precise sector, pollutant or process, It is difficult to agree or disagree with the general statements of the inception impact assessment saying “ there are not to be expected large economic impacts unless radically different approaches to those in the current legislation “, “costs of compliance with the requirements of IED and BAT conclusions are relatively small” , and “where it has been possible to assess, the societal benefits from the IED have substantially outweighed its economic costs”.
EFIEES understands the envisaged revision of the IED to possibly target three objectives: improving the BREF elaboration process, exploit the untapped potential for the IED to further contribute to the circular economy objectives, and interact with the decarbonisation of the industry. We do not fully understand which pollutants would be put under review, since the general evaluation of the Directive shows quite positive conclusions.
If a revision of the IED was to be decided, EFIEES’ two main requests to the EU legislator, at this stage, are:
• To pay great attention to the issue of costs for the industry, in the context of the post-Covid-19 crisis. We also ask for a permitting process for industrial energy installations using innovative or experimental technologies (not yet “proven”) to be made possible, in order to allow to assess the results of new processes for energy transition/emissions reduction in an industrial environment.
• To take into account whether or not industries covered by the Directive are also subject to the ETS. The idea that “IED permitting could support GHG abatement measures” (“for energy intensive industries”), as mentioned in the inception impact assessment, would result in imposing a double regulatory burden on district heating and cooling installations subject to ETS.
Any other future public consultation on IED should address the pollutants, the processes, and measures the revision would tackle. Until now, the evaluation seems too vague and general to build a robust answer on the needs and scope for a revision.
Read full responseResponse to 2030 Climate Target Plan
15 Apr 2020
EFIEES, the European Federation of Intelligent Energy Efficiency Services, represents energy service companies (ESCOs) and their national associations in 12 Member States. They represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in buildings and industry. In some countries, they also operate district heating & cooling networks.
Following the launch of the Green Deal in 2019 and the Climate Law proposal in March 2020, we welcome the Commission’s Roadmap on the 2030 Climate Target Plan. The challenge of increasing the pace of the energy transition to secure the 2050 objective will be even greater, at a time when national authorities are struggling to address the critical economic consequences of Covid-19.
It is hence of utmost importance to set a solid and ambitious target for 2030, accompanied by the most appropriate measures and instruments, in line with the principles of competitiveness and affordability, also at the heart of our green growth strategy, the Green Deal. As this approach will be even more relevant in today’s context, we would like to make the following recommendations:
- The 2030 Climate Target Plan should ensure the Green Deal is a real engine for growth. Support schemes should focus on measures that contribute to developing green and economically sustainable activities, generate local employment and are the most efficient in terms of public funds allocation, to be leveraged through additional private investment. Hence, criteria like invested euro/ton of avoided CO2 and amount of energy savings are especially relevant.
- Energy Efficiency First must remain the guiding principle to reach the new 2030 target. It should thus be precisely defined, modeled and streamlined in all EU policies contributing to CO2 abatement.
- Energy efficiency services (EES) offer a sound answer to climate change. Solutions like Energy Performance Contracts (EPCs) secure the energy savings on which investments are decided through a contractual performance commitment, backed by proactive energy management. They offer the possibility to mobilise financing covered by the generated savings and their typical return on investment allows to strongly reduce the need for public subsidies.
In light of their environmental and economic profitability, EES and EPCs should be prioritised (in both industry and buildings) and renovation strategies should consider a staged process, where the generated long term savings serves as support for further investments. Moreover, EES create solid value chains and highly qualified local jobs. A positive regulatory environment should thus be created and secured, also via a proper energy taxation that recognises the hidden cost of carbon content in energy products and fuels, to make energy efficiency projects more attractive.
Full consideration of circular economy solutions should also be ensured, specifically by making the best use of the untapped potential of waste heat. In this regard, district energy networks are already an ideal vector for both aggregating energy demand and reducing emissions, using local sources, such as bioenergy and waste heat. Future policies should make the best use of this infrastructure and support its transition to a carbon neutral local solution.
- The planned EED and RED revision will be key to achieve the new 2030 target. By the same token, the new MFF, the Taxonomy and green finance initiative will be essential in channeling available funding towards necessary investments in the field of energy efficiency – with a caveat on some needed improvements on EES, to take into full account any action resulting in concrete and demonstrable energy savings.
- In order to find a successful way forward in a dramatically altered economic situation, the EU legislative calendar and current consultation initiatives should make room for enabling all stakeholders to voice their concerns and attempt to find broad consensus.
Read full responseResponse to Revision of the Energy Tax Directive
1 Apr 2020
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 Member States. Our members represent over 130.000 professionals engaged in energy-efficiency solutions in buildings and industry. They also operate district heating & cooling networks. We welcome the Commission’s Roadmap for the revision of the Energy Taxation Directive (ETD), with the following remarks:
1.The EU climate and energy objectives for 2030 and 2050 require effective taxation based on CO2 and energy content of energy products.
Taxation is key for transitioning to a carbon neutral economy. The current ETD sets minimum levels of taxation on motor fuels, heating fuels and electricity. However, these are not proportionally based on the CO2 or energy content of the products consumed and have not been updated since 2003. Hence, it is largely outdated and not designed for more ambitious climate goals.
The new ETD should enable a consistent treatment of all energy sources to provide a level playing field for energy consumers and steer their choices towards decarbonised fuel options and energy efficiency. This could be achieved by setting a minimum taxation rate based on energy content and CO2 emissions, with an equal taxation for competing products. This rate, especially the carbon component, should be sufficient to reflect the GHG externalities of fossil primary energies. This would ensure fairer prices against renewable energies and thus support their development.
2.Energy taxation on fossil fuels for heat production based on CO2 and energy content would allow for effective decarbonisation and a level playing field in the whole heating and cooling (H&C) sector.
H&C represents around 50% of energy consumption and its decarbonisation is one of the main challenges of the energy transition and requires the creation of a real level playing field across the entire H&C market.
District heating and cooling (DHC) networks currently suffer from a competition distortion, when subject to the EU ETS, while individual boilers and heating installations under 20 MW are not. Consequently, only the CO2 impact of the fossil energy used by DHC is taken into account, while that of the largest part of the market is not. This prevents any significant decarbonisation of the sector. A revised ETD should hence be a tool for MS to establish a pricing mechanism for CO2 emissions in installations not under the ETS today, with rates regularly reviewed to remain consistent with the ETS carbon prices. Installations already under ETS should not be taxed (to avoid double taxation) as well as renewable energy sources, including biomass and biogas.
3. The new ETD should aim at fully reflecting the carbon impact of fuels used in individual installations, for which low excise rates and too many exemptions are still allowed by Article 14.1.
All heating solutions, thermal or electric, should be under the same levels of taxation as far as fossil primary energy is concerned.
Hence, households should not benefit from tax exemptions nor reduced rates. Other national mechanisms should set up, when necessary, accompanying measures mitigating the economic impact of a heavier taxation on specific categories. These could include support to energy efficiency actions that reduce energy bills on the long term.
4.The revised ETD should stimulate energy efficiency actions
The new ETD should stimulate energy efficiency actions in industry and buildings by making energy efficiency measures and projects more attractive. Likewise the ETS, increasing the cost of use of CO2 intensive fuels will indeed provide incentives to energy consumers to invest in energy efficiency measures, in line with the “Energy Efficiency First” principle.
This could also be facilitated by providing energy intensive industries with reduced rates, conditioned by the achievement of environmental objectives and increased energy efficiency.
Read full responseResponse to Commission Implementing Regulation on the Modernisation Fund
16 Mar 2020
EFIEES’ Feedback to the Modernisation Fund Proposal
Brussels, 16th March 2020
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In several countries, they also ensure the efficient operation of district heating & cooling networks.
The latter are the key instrument for decarbonising the heating and cooling sector, combining energy efficient heating production and distribution and the possibility for a massive integration of renewable and low carbon energy sources. Efficient and modern DHC networks, enabling a “district approach” to energy planning, allow for the flexibility, stability of the grids, and security of supply, and sector integration, in case of thermal storage or simoultanenous production of heat and electricity. Achieving climate neutrality by 2050, and reaching the goals set out in the Paris Agreement, call for a rapid and radical transformation of the energy systems, including the heating sector.
The Modernisation Fund can be an essential tool for upgrading existing district heating infrastructures together with their further development. Large scale investments are needed, and the Modernisation Fund will be pivotal for mobilising them, in particular in the five Member States which choose to transfer CO2 allowances to the Modernisation Fund, allowing it to double. Its support should be based on swift and agile procedures.
EFIEES wishes to raise some concerns about the draft proposal. DHN investment projects often require several years of preparation. The distribution of the fund’s resources to Member states should be made in a quick and efficient manner, to avoid delays. Hence, we propose the following:
- The approval of the projects and the disbursement of funds should be separate processes, the former being limited to the material admissibility of the project.
- A beneficiary Member State should be allowed to request the disbursement of funds at its discretion. At this stage and before issuing the disbursement decision, the Commission should check if the other criteria are met: the basis of the criterion 70/30, if sufficient funds are available, and if state aid has been authorised. On the basis of the decision, the EIB transfers then the corresponding funds to the beneficiary Member State.
- The verification process should be made only when approving the payment of funds, not when approving the project.
Read full responseResponse to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"
12 Mar 2020
EFIEES, the European Federation of Intelligent Energy Efficiency Services, is the voice of energy service companies (ESCOs) and their national associations in 12 EU Member States. Our members represent over 130.000 professionals engaged in the design and implementation of energy-efficiency solutions in public and private buildings as well as industrial facilities. In some countries, they also ensure the efficient operation of district heating and cooling networks.
Following the publication of the EU Green Deal in December, we welcome the Commission’s proposal for the establishment of a Just Transition Fund (JTF) and the broader introduction of a Just Transition Mechanism (JTM) to enable a socially fair and sustainable transition.
Our comments and recommendations on the JTF proposal can be summarised as follows:
1. In defining the programming and functioning of the JTF, we strongly recommend to ensure the Energy Efficiency First principle will be the guiding rule. This principle is crucial in order to design affordable energy transition policies and to secure their social acceptance. In particular, it allows to strike the right balance between energy efficiency measures at both the supply and demand side and the need for additional renewable energy generation capacities, facilitating their deployment. The application of this principle is also particularly relevant for the heating & cooling sector, which currently faces the challenge of a deep and relatively rapid decarbonisation.
The implementation of this principle, thus requiring energy efficiency measures to be prioritised along the whole energy chain, should ideally be reflected in the Territorial Just Transition Plans, which in turn should also be coherent with the National Energy and Climate Plans. The latter, indeed, shall also incorporate the Energy Efficiency First Principle under the provisions laid down in the Governance Regulation.
2. Energy Efficiency professions are known to generate significant net employment, also in regions where economic and energy transition will result in a necessary and massive retraining of workers. All actors of the energy efficiency chain, especially private companies able to create new jobs, train workers, improve skills, and spur innovation with projects contributing to the JTF objectives, should be enabled to support the just transition process.
Those companies should hence be allowed to benefit from the JTF irrespective of their size, and for any type of investment falling within the scope of the Fund. Among those stakeholders, energy service companies (ESCOs) can play a key role as they allow for the creation of a number of sustainable jobs at local level, covering different types of skills and expertise.
3. Finally, the JTF should provide support for solutions, which enable the decarbonisation of the heating and cooling sector, today still accounting for about half of the EU energy consumption. In particular, solutions such as efficient district heating and cooling should be eligible for support through all three pillars of the Just Transition Mechanism (the JTF, InvestEU and the EIB facility) as they facilitate the transition of the heating & cooling sector towards low carbon energy sources in a cost-effective and socially affordable way.
In addition to high efficient district networks, those which have formally committed to a short-term roadmap to become efficient, according to the definition provided by the Energy Efficiency Directive, should also benefit from support both for the generation (exchange of heating sources) and distribution of heat (modernisation and expansion of the network).
Read full responseResponse to Climate Law
6 Feb 2020
Achieving the climate neutrality objective by 2050, which will be enshrined in legislation by the Climate Law, will require a full commitment from all sectors of the economy and the society as a whole. It will also require clear and ambitious targets to steer our actions towards the required optimum.
As regards the possible inclusion of intermediate emissions’ reduction targets in the Climate Law, we welcome and support this proposal. Intermediary milestones would design a clear trajectory which is needed for effective emissions reduction, especially if accompanied with a robust and transparent monitoring and reporting framework.
The energy efficiency sector plays a pivotal role in this transition by putting in place measures and projects aimed at reducing energy consumption - and thus CO2 emissions - along the whole energy chain. It should therefore be given a prominent position, in line with the Energy Efficiency First principle.
The reduction of primary and final energy demand, responsible for the majority of CO2 emissions in the EU, should indeed have precedence on the pathway towards climate neutrality and, on this account, be prioritised in any relevant strategy and legislative initiative which will accompany the Climate Law and follow in the next future.
In light of the above, we would strongly recommend to ensure the Energy Efficiency First principle is explicitly stated and validated in the Climate Law, so as to ensure the right market signals are sent to all stakeholders.
However, there is no single way to “make energy efficiency happen”: better use of energy is the result of a combination of complementary and sometimes alternative actions, which should be selected and prioritised according to any specific situation and their respective cost-effectiveness.
Solutions such as energy efficiency services, providing the design and implementation of the appropriate energy efficiency measures (including operation, monitoring and maintenance) and more specifically efficient energy management, should always be considered as reliable allies for emissions’ reduction, both in buildings and industry.
Moreover, as they commit on a guarantee of a specific level of energy performance/savings over time (as it is the case for Energy Performance Contracting, EPC), they systematically result in real, long-term and verifiable energy efficiency and emissions’ reductions; one of the main advantages of these solutions.
Energy efficiency services have also a key role to play in any ambitious renovation strategy: they can be an enabler for renovation, as the money previously saved on the energy bills through an EPC can fund future renovation works. In addition, energy efficiency services can ensure energy and emissions savings in a scenario when thermal insulation is not feasible or when a building has not yet reached a renovation stage. Furthermore, they are always a useful complement to it, as energy management permits to maintain a certain level of energy performance or a specific energy class - previously achieved through renovation - over time.
Besides energy efficiency, our transition towards carbon neutrality in 2050 will also require a careful examination of how a sector responsible for circa 50% of the energy consumption in the EU today can be decarbonised. The heating sector will play a vital role, and electrification alone will not ensure that heating and cooling demand is entirely met with renewables in the next future.
Efficient thermal heating solutions should be considered and supported, including district-level solutions such as district heating and cooling networks, especially when they are designed as highly efficient ones, as they are a privileged vector for renewable energies.
Hence, we highly recommend to take the above factors into consideration in the preparation of the future Climate Law and all related initiatives, particularly under the Green Deal.
Read full responseMeeting with Maria Cristina Lobillo Borrero (Cabinet of Vice-President Miguel Arias Cañete), Yvon Slingenberg (Cabinet of Vice-President Miguel Arias Cañete)
18 Mar 2015 · Energy efficiency in the context of the Energy Union and a strategy on heating and cooling
Meeting with Peter Van Kemseke (Cabinet of Vice-President Maroš Šefčovič)
18 Mar 2015 · Energy Union follow-up: energy efficiency