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Fédération des services énergie environnement

FEDENE

FEDENE is a French federation representing 500 companies specialized in energy efficiency, building performance, and renewable heat.

Lobbying Activity

FEDENE Urges Simplified Taxonomy Rules for Green Heating Projects

5 Dec 2025
Topic — The European Commission is reviewing rules defining sustainable investments in energy and environmental sectors.
Message — FEDENE requests simplifying technical standards for district heating and geothermal energy. They want bioenergy rules aligned with existing EU directives. They also propose including waste-to-energy projects in the Taxonomy.123
Why — This would reduce administrative costs and planning bottlenecks for renewable heat projects.4
Impact — Environmental groups lose stricter biomass standards that currently exceed existing EU directives.5
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FEDENE Urges EU Funding for Energy Efficiency and Decarbonization

12 Nov 2025
Topic — This consultation addresses the post-2027 EU budget plans for supporting industrial competitiveness.
Message — FEDENE requests that the fund prioritize projects with guaranteed energy performance. They argue Waste-to-Energy plants should be eligible for industrial competitiveness grants.12
Why — These measures would reduce financial risks and simplify access to EU grants.3
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FEDENE urges heat recovery and data sobriety in AI roadmap

5 Nov 2025
Topic — The European Commission is developing a strategic roadmap for digitizing and using AI in energy.
Message — FEDENE calls for prioritising data quality over quantity to ensure energy sobriety and system interoperability. They demand that AI deployment include oversight by qualified human energy managers and mandate waste heat recovery from data centres.123
Why — These measures would create new revenue from heat recovery and lower members' data processing costs.45
Impact — Data center operators face stricter reporting and potential aid conditions tied to heat reuse.6
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FEDENE urges more EU funding for heating decarbonization

3 Nov 2025
Topic — Consultation on the EU's long-term budget and future regional funding programs.
Message — The federation requests increased financial support for heat decarbonization and the refurbishment of district heating networks. They propose that fund eligibility and aid intensity should not be restricted by company size. Furthermore, EU funds must supplement rather than replace existing national funding.123
Why — This ensures ongoing investment for energy service firms while expanding funding access to larger corporations.45
Impact — Fossil fuel importers lose market share as Europe transitions to local, renewable heating solutions.67
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French energy federation FEDENE calls for prioritized district heating

9 Oct 2025
Topic — Consultation on a new EU strategy for decarbonizing heating and cooling systems.
Message — The federation calls for a strategy prioritizing energy efficiency and local planning to ensure effective heat decarbonization. They advocate for a merit order favoring waste heat recovery and demand a dedicated focus on cooling solutions.123
Why — This would secure market dominance and increased public subsidies for district network operators.45
Impact — Providers of standalone heating systems lose subsidies when competing with district networks.6
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FEDENE Urges Updated Aid Formulas to Support Industrial Electrification

5 Sept 2025
Topic — The consultation examines technical updates to state aid guidelines for industrial electricity cost compensation.
Message — The federation requests a comprehensive review to align compensation with current electrification trends. They seek new formulas that account for increased electricity use during industrial decarbonization.12
Why — Revised formulas would provide economic stability and incentivize investments in industrial electrification projects.34
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Response to Review of the State aid rules on the Services of General Economic Interest (“SGEI”)

31 Jul 2025

FEDENE is the French representative federation for energy efficiency services and heat decarbonization, covering the entire value chain, a sector that brings together over 1,500 businesses and 50,000 employees in France. In 2022 households energy bills amounted in France to 9,5% of their total budget . Accounting for an increasing share of households' annual expenses, energy and the need for energy-efficient housing are now closely linked to affordable housing. On the other hand, energy-efficient renovations and solutions play a significant role in promoting a just transition to more affordable and sustainable housing. FEDENE welcomes the suggested definition of affordable housing as a housing that meets minimum energy performance levels at affordable conditions. This will require an ambitious renovation action plan. Considering the massive challenge posed by the existing building stock, this approach should ensure that priority is given to the worst performing buildings, adopting a staged renovation approach. In that respect, and in line with the recommendation of the Energy Performance Directive, such renovations should, especially in large condominiums, be carried out under an Energy Performance Contract (EnPC). These contractual arrangements ensure that that expected energy consumption reduction is reached and maintained over time. Indeed, affordability must also rely on stable energy consumption in the long run. Besides, energy affordability for housing is also conditioned by energy prices. Protecting vulnerable households against the volatility of imported fossil fuels should also be supported by the Decision concerning services of general economic interest (SGEI) . Energy renovations are a unique opportunity to include actions that substitute fossil energies with sources based on renewable and waste heat such as connections to efficient district heating and cooling (EDHC). Indeed, efficient district heating and cooling networks (DHC) protect consumers against fuel supply shortages and ensure better price stability by utilizing local renewable or recovered resources such as waste heat, solar thermal, geothermal energy, or sustainable biomass. SGEI should support this energy flexibility by ensuring that new buildings as well as refurbished ones are equipped with collective heating solutions. Considering the massive investment required to enhance energy efficiency and decarbonization of the housing stock, alignment of the related policies is of the utmost importance. In this regard, State Aids rules and policies should ensure that public support prioritize solutions with guaranteed performance. This could be achieved through a bonus in the intensity of public support. This would facilitate the mobilisation of private co-financing for such projects. Energy and CO performance can notably be effectively guaranteed through energy management solutions such as Energy Performance Contracts (EnPCs), under which an Energy Service Company (ESCO) contractually commits to a public or private asset owner to achieve guaranteed levels of energy performanceand increasingly, CO emissions reductionsover time. The upcoming revision of State Aid laws for Services of General Economic Interest (SGEI) in affordable housing presents an important opportunity to integrate energy efficiency into the heart of housing affordability. During the revision, FEDENE will particularly pay attention to how renovation investments are incorporated into the financing of social and affordable housing and draws the Commission's attention to the incorporation of EnPCs and DHC into these investments.
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FEDENE Urges Innovation Fund Expansion to Waste Heat and Biomass

8 Jul 2025
Topic — Evaluation of the Innovation Fund's role in supporting European industrial and energy decarbonisation.
Message — FEDENE requests simplified application procedures to reduce significant administrative barriers. They advocate expanding the fund's scope to waste heat and biomass. District heating and cooling should also become eligible for innovation funding.12
Why — This would lower entry barriers for companies seeking funding for heat recovery.3
Impact — Proponents of pure electrification lose out as biomass becomes a prioritized alternative.4
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French energy federation urges EU to prioritize heat decarbonization

26 Nov 2024
Topic — Evaluation of the European Union’s legislative framework for energy security architecture.
Message — FEDENE demands that heating and cooling solutions become central to energy security. They advocate for district heating networks and energy efficiency to reduce gas imports.12
Why — Proposed changes would increase demand for services provided by FEDENE's member companies.3
Impact — International fossil fuel suppliers lose market share as Europe prioritizes local heat production.4
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FEDENE Urges Flexible Waste Emission Monitoring and Biomass Rules

29 Jul 2024
Topic — This consultation updates EU Emissions Trading System rules for monitoring and reporting greenhouse gas emissions.
Message — FEDENE requests that small biomass installations be zero-rated directly to reduce the administrative burden. They argue for allowing Member States to follow their own approach for waste-to-energy installations. They also seek clarity on justifying zero emissions using Biomethane Guarantees of Origin.12
Why — This would lower compliance costs and avoid technical requirements that are currently unachievable.34
Impact — Environmental groups and regulators lose precise data if monitoring frequency and accuracy are reduced.5
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FEDENE calls for incineration ash inclusion in carbon storage rules

16 Jul 2024
Topic — Rules for determining when greenhouse gases are permanently chemically bound in products.
Message — FEDENE calls for including incineration bottom ash carbonation technology in the current Delegated Act. They request a rigorous methodology for monitoring and reporting CO2 absorption.12
Why — This would reduce reported emissions and allow the reuse of ash in construction.3
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Response to Guidance to Member States and market actors to unlock private investments in energy efficiency (EED recast)

26 Feb 2024

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENEs members employ 60.000 professionals dedicated to the implementation and development of sustainable services. Throughout the legislative process, FEDENE has always welcomed a revision of the Energy Efficiency Directive which accelerates the ecological transition towards climate neutrality. Today, FEDENE is committed to making the Fit-for-55 package a tangible and lasting success via concrete projects. FEDENE salutes the European Commissions (EC) initiative to publish guidelines to unlock private investment in energy efficiency. Reinforcing synergies between public and private funding. Public and private funding should complement one another to optimise their effects and strengthen the competitiveness of operations aimed at improving the energy efficiency of buildings and industrial processes. This is particularly true at a time when public aid is getting scarce, as it is currently the case in France, and the price of imported fossil fuels is falling. In France, "white certificates" a private scheme - can be combined with public aids such as ADEMEs Fonds Chaleur. Thanks to this combination, virtuous projects (creation of district heating, and installation of collective heating systems) are more attractive and can be launched faster without increasing public spending. The EC's guidelines should encourage the articulation of public subsidies with private funding, such as white certificates. ADEME, the French energy agency, identified waste heat untaped potential throughout the country which could, if recovered, save up to 15% of the energy used in domestic heating. The recovery of this waste energy by private actors should be encouraged via cost-effective tools. For instance, guarantee funds have proven very effective in developing geothermal energy in France. Following this precedent, FEDENE is studying the creation of a guarantee fund supported by initial public funding that will be complemented with projects contributions to cover the financial risks of recovering industrial waste heat. Expanding the scope of the EU Taxonomy. As the Taxonomy provides a compass for private investors, it should include all the activities needed to accelerate the energy transition. Member States are reindustrialising the EU. However, this policy has to comply with the framework defined to develop the green industry, which FEDENE supports. To maintain a coherent framework and ease the emergence of a sustainable EU industry, FEDENE proposes to establish in the Taxonomy a category recognising specialised services related to energy performance in this sector as it exists for buildings. In complement with the efficiency of modern sorting plants in achieving high recycling rates, waste-to-energy (WtE) serves as a valuable component in the overarching strategy to responsibly manage and generate value from residual waste. Thus, the Taxonomy should encompass the construction, upgrade, and operation of dedicated facilities focused on treating non-recyclable waste with energy recovery. Facilitating the use of third-party financing. To accelerate and massify energy refurbishment, an ESCOs client can resort to third-party financing when contracting an Energy Performance Contract (EnPC). By doing so, the client benefits from an entirely financed project that he starts reimbursing at the works delivery. In the Energy efficiency and Energy performance of building directives, the European Union encourages the use of EnPCs because they are one-stop shops to finance and save energy speedily. As such, EnPCs should be promoted in the ECs future guidelines.
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Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENEs members employ 60.000 professionals dedicated to the implementation and development of sustainable services. Throughout the legislative process, FEDENE has always welcomed a revision of the Energy Efficiency Directive which accelerates the ecological transition towards climate neutrality. Today, FEDENE is committed to making the Fit-for-55 package a tangible and lasting success via concrete projects. To launch economically viable projects, efficient public funding is paramount. FEDENE welcomes the European Commissions (EC) initiative to collect feedback about energy efficiency public funding. In France, FEDENE notes a great dispersion of public bodies and programs supporting energy efficiency, while, paradoxically, its financing remains insufficient to achieve the countrys 2030 objectives. FEDENE favors consolidating programs around one-stop shops and simplified processes to amplify the leverage effect of public aid. The following recommendations are in line with this approach: Enforcing the exemplary role of the public sector. In FEDENEs view, there are two categories of public funding: public spending and public aid. The revised EED includes obligations for public bodies at all levels; 1,7% energy savings per year for instance. Public bodies are encouraged to use solutions guaranteeing tangible and measured energy savings, such as Energy Performance Contracts (EnPCs). As the public sector should set an example for private actors to act quickly in favour of energy efficiency, the ECs assessment should promote the use of EnPCs by public bodies in its support and funding mechanisms. Boosting the EEDs success with EnPCs. Public support should ensure the economic viability of projects that guarantee tangible energy savings over time. In that sense, public support should prioritise projects using tools that provide such results as EnPCs; or a bonus should systematically be granted to those projects. Beyond the guarantee of effective energy savings, EnPCs could enable ESCOs to apply for and receive public aid on behalf of their customers, simplifying procedures and speeding up project completion. Optimising the use of one-stop shops. At a time when accelerating the deployment of energy efficiency projects is key, simple application and allocation procedures are paramount. The European Commission should encourage Member States to rationalise the number of public bodies and programs supporting energy efficiency. Mechanisms like ANAH have proven their efficiency in massifying thermal refurbishment in France. In that respect, ESCOs can, through contractual arrangements such as EnPC, act as agents and aggregate the supports available, fostering this one-stop-shop approach. If a dedicated mechanism were to be created at the EU level, it should preferably rely on, and channel its funding through already existing national public bodies and programs, as done with Next Generation EU. In that way, the EU program would greatly improve the effect of public subsidies without adding complexity for project managers. Supporting the recovery of waste heat. ADEME, the French energy agency, identified an untapped potential of waste heat throughout the country which could, if recovered, save up to 15% of the energy used in domestic heating. The recovery of this waste energy by private actors should be encouraged via cost-effective tools. For instance, guarantee funds have proven very effective in developing geothermal energy in France. Following this precedent, FEDENE is studying the creation of a guarantee fund initiated by public funding and complemented with projects contributions to cover the financial risks of recovering industrial waste heat.
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FEDENE Urges Proportional Penalties for ETS Energy Efficiency Compliance

2 Jan 2024
Topic — The consultation updates regulatory rules for free allocation of EU emission allowances.
Message — FEDENE proposes replacing the 20% flat-rate penalty with reductions proportional to missing emission savings. They suggest including inflation in cost assessments and using auditors for compliance proof.123
Why — Proportional penalties would protect companies from excessive financial losses despite partial compliance efforts.45
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Energy federation FEDENE urges EU waste-to-energy carbon capture support

31 Aug 2023
Topic — The European Union is consulting on measures to deploy carbon capture and storage infrastructure.
Message — FEDENE requests CO2 transport infrastructure and a dedicated market mechanism for negative emissions. They argue capturing carbon is insufficient without proper storage and accounting frameworks.12
Why — This would provide the legal certainty and financial incentives needed to invest in carbon capture technologies.3
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FEDENE urges flexible timelines and incentives for heat pumps

26 May 2023
Topic — A consultation on creating an EU action plan for heat pump deployment.
Message — FEDENE calls for targeted financial incentives for collective heat pump systems in apartment buildings. They request including hybrid systems in subsidy programs and establishing flexible refrigerant phase-out timelines.123
Why — These measures would lower compliance costs and create new revenue streams for energy service companies.45
Impact — Environmental advocates lose as fossil-fuel boilers persist in hybrid systems and refrigerants remain permitted longer.67
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FEDENE demands trade secret safeguards in EU Data Act

13 May 2022
Topic — The EU Data Act aims to ensure fair access and use of data across industries.
Message — FEDENE requests a clear distinction between raw data and proprietary processed knowledge. They argue trade secrets and algorithms must remain private. They also seek an extension to the proposed twelve-month implementation timeline.12
Why — Safeguarding proprietary knowledge maintains their competitive advantage while avoiding expensive data-sharing requirements.3
Impact — Public institutions and competitors lose access to valuable technical insights and processed analytical datasets.4
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

30 Mar 2022

FEDENE is a French professional association representing 500 energy and environmental service companies, 60.000 employees. From public and private district heating and cooling operators to energy service companies (ESCOs), FEDENE’s members implement and develop sustainable services. In reaction to this recast, we would like to emphasise 3 key guiding principles when revising the EPBD Fostering energy management solutions as a complement to renovations This revision introduces and reinforces several instruments improving buildings’ energy performance through renovation actions: National Building Renovation Action Plan, Minimum Energy Performance Standards, Building Renovation Passport and Energy Performance Certificates. These measures should systematically assess the feasibility of using an energy performance contract (EnPC) to guarantee real energy performance in the long-term as the vehicle of choice for building renovations. New standards such as “deep or staged deep renovation”, “zero-energy building” and “zero-emission building” should also promote a dynamic approach to building’s energy performance and require relevant projects to be carried under an EnPC or at least ensure management of energy performance. Indeed, a high-performance renovation is truly efficient when keeping energy performance over time through proactive energy management. Appropriate financial measures, linked to real and measured energy performance, should assist the new ambitions of this proposal, especially for most vulnerable households. Removing economic barriers, such as authorising third-party financing mechanisms in EnPC, including for the public sector, is also essential. Promoting equal treatment between on-site and nearby renewable energy sources (RES) and waste heat In respect of the Energy Efficiency First principle, implementing energy efficiency measures should be considered prior to any fuel switching. Fedene thus welcomes the calendar provided for the definition of deep renovation to transform first buildings into nearly zero-energy buildings, then into zero-emission buildings by 2030.In this process, it is essential to ensure a non-discriminatory treatment between on-site and nearby RES. The definition of zero-emission building heads in the right direction by specifying “where the very low amount of energy still required is fully covered by energy from renewable sources generated on-site, from a renewable energy community … or from a district heating and cooling system, in accordance with the requirements set out in Annex III” (art. 2). FEDENE proposes to adapt the definition so that a building with of the required energy consumption is considered as zero-emission as soon as it is supplied by an efficient DHC system (according to EED). In addition, the renovation of buildings should be inscribed in broader intervention plans addressing neighbourhoods and districts through local energy plannings, especially when it comes to heating and cooling, with due consultation of DHC operators. In this context, the feasibility of solutions such as waste heat recovery should be considered as a priority to support circular economy, energy performance and buildings’ and districts’ decarbonization. Whilst FEDENE fully supports transparency in energy related data for buildings, communication of data should be limited to those relevant to assess and manage the energy performance of the building, and not include processed data that result from commercial know-how. Besides, due consideration should be given to the consecutive digital carbon footprint generated. Air quality in the EU building stock Addressing air quality is essential both to reduce energy consumption and to improve sanitary conditions, especially after the COVID-19 pandemic. Thus, regular inspections of ventilation and air conditioning should not be limited to systems with an effective rated output of over 70 kW but extended also to smaller buildings including individual houses.
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Response to Methodology for calculating the quantity of renewable energy used for cooling and district cooling

25 Nov 2021

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals developing sustainable services. In near future, rising temperatures in cities will no longer concern the comfort of the population but its health! FEDENE supports a common sustainable cooling strategy to ensure these health challenges and rising cooling needs are properly addressed in the Fit-for-55 package. The European Commission (EC) currently proposes a draft Delegated Act (DA) setting the calculation method of RES rate in cooling and DC systems while recasting the definition of efficient district cooling in Article 24 of the Energy Efficiency Directive (EED). FEDENE welcomes the draft DA which the European Commission’s consideration for DC. However, the draft lacks providing a sufficient level playing field among stand-alone and DC systems. FEDENE fears it could obstruct the coming development of efficient district cooling. Ensuring a fair level playing field among all cooling solutions District cooling (DC) offers an efficient and sustainable response to the cooling needs densely populated areas. It has a unique ability to prevent against urban heat island effects and to use renewable sources (RES) located in urban centres (river or sea water, geothermal water, urban waste recovery). Its energy and environmental performances are superior to most of autonomous installations. The average CO2 content of a cooling network in France is 10g/kWh and DC’s refrigerant leakage rates are much lower than stand-alone installations (<1% compared to about 10%). The current draft DA favours autonomous solutions that do meter their production over measured solutions like DC. The formers benefit from standard theoretical SPF values that are double the actual SPF of autonomous solutions while a unique pair of SPF thresholds (SPF low and SPF high) has been established for the latter. The draft DA do not put metered and unmetered solutions on an equal footing which seems the opposite of spirit of the EC’s proposal for a revised EED which promotes measured systems. Hence, FEDENE recommends circumscribing the SPF calculations’ perimeter to chillers only and setting the SPF high to 5 for cooling systems measuring their performance. Promoting the use of waste energy In line with Renewable Energy Directive and the Energy Efficiency First Principle, the draft DA should promote the recovery of waste energy. Therefore, the use of waste heat and heat-driven solutions (absorption) should not be disqualified from the scope of the calculation. Absorption technologies can valorise low temperature heat with low performance factors. The DA should incentivise the use in summertime of low temperature renewable and recovery energy sources by setting a SPF min to 0.1 and a SPF max to 1.8.
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Response to Revision of the Energy Tax Directive

17 Nov 2021

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals dedicated to the implementation and development of sustainable services. By 2050, the European Union has committed itself to become the first continental area reaching carbon neutrality. Last July, the Commission presented the Fit for 55 package which gives a comprehensive and interconnected set of proposals to step-up the pace for the greenhouse gases (GHG) emissions reduction. The Energy Efficiency First principle should be promoted within the package, especially in the heating and cooling sector. The substitution of fossil fuels by renewable energies should be accelerated by sending a clear pricing signal. The Energy Taxation Directive (ETD) should play a significant role in that process. FEDENE welcomes the possibility to recast the ETD allowing Member States to achieve the Union’s 2030 environmental goals as defined in the Fit for 55 package. Above all, ETD should promote the use of sustainable renewable energies According to Article 23 (1) of the Commission’s proposal to recast the Renewable Energy Directive (RED), each Member state shall increase annually by 1,5% the share renewable energy and waste heat and cold, in its domestic heating and cooling sector. FEDENE supports this target as it provides a clear and stable roadmap to promote the use of renewable energies in the heating and cooling sector. For this purpose, energy taxation on fossil fuels based on their CO2 and energy content would support effective decarbonisation and foster a level playing field in the heating & cooling sector. Therefore, FEDENE welcomes the Commission’s proposal to revamp the energy taxation system especially in an environment with strong variations of fossil fuels market prices. This should be translated by favourable taxation levels for low-carbon fuel that will need to replace fossil fuels. Hence, FEDENE proposes to set at zero the minimum level of taxation of bioliquids, biogas, solid products using wooden biomass respecting RED’s sustainability and GHG criteria.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Nov 2021

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals developing sustainable services. In line with the fit-for-55’s overall objective, FEDENE supports the European Commission’s (EC) ambition to increase to at least 40% the share of renewable energy sources (RES) in the Union’s gross final energy consumption. Encouraging the recovery of waste heat and cold To decarbonise the heating and cooling sector, the recovery of waste heat by DHC should be encouraged. In that sense, Articles 23 and 24 include the reuse of waste heat. FEDENE supports this proposal which promotes the “Energy Efficiency First” principle set in Article 3 of the proposal to amend the Energy Efficiency Directive. Promoting the use waste heat in the building sector According to Article 15a, Member States shall define a target consistent with the EU’s indicative target of at least 49% RES in the building sector’s final energy consumption. The greening of this sector is paramount to reach the Fit-for-55’s targets in 2030. Pursuant to Articles 23 and 24, waste heat and cold recovered by DHC should be considered to fulfil this target. In that respect, the non-discrimination principle between on-site and nearby RES established in the current Energy Performance of Buildings Directive and recalled in Article 15a is crucial. Besides, energy performance contracts increasingly cover building decarbonisation actions as introduction of RES in the building’s energy mix and commitment on the carbon footprint. Such contracts, evolving towards “energy and carbon performance contracts” should be promoted in this directive. A fruitful third-part connection right to DHC Article 24 obliges operators of DHC systems above 25MWth to connect third-party suppliers of energy from RES, waste heat and cold. FEDENE sees third-party connection as a mean to further green and develop DHC systems without endangering the operators’ ability to ensure resilient management of the networks. To strike a balance between third party suppliers’ rights and the DHC operator’s obligations, a Member State may implement four exemptions. The current provisions listing these exemptions should maintained to ensure a harmonised and stable EU legislative framework on this issue. To reinforce the coordination framework set in article 24(6), potential third-party suppliers of waste heat should inform DHC operators on the reasons why they refuse to supply the system located nearby. Facilitating a sustainable use of bio energies The EC’s proposal strengthens the sustainability criteria for biomass and lowers threshold down to 5 MW. Whilst FEDENE supports the aim of ensuring a sustainable use of biomass, the threshold should be set at a level that strikes a balance between this objective and the resulting administrative burden and associated cost. Lowering the threshold down to 5MW would create a disproportionate administrative burden. A 10MW threshold would cover “85% of commercial woody biomass used in plants above 1MW, while affecting 25% of the wood chip plants” according to the EC’s Impact Assessment Report. The cascading principle on wooden biomass (Article 3) duplicates the waste hierarchy and places its energy valorisation at the penultimate position. The complementarity of uses suggested by the Joint Research Centre seems a more appropriate scheme regarding the EC’s objectives. Furthermore, on such complex matter FEDENE suggests deepening discussions with all stakeholders rather than resorting to a delegated act. Developing biomethane Biomethane is a key enabler for the EU decarbonisation roadmap. In that respect, Guarantees of Origins should be considered as an important flexibility tool for developing this resource.
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Response to Review of Directive 2012/27/EU on energy efficiency

17 Nov 2021

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employes 60.000 professionals developing sustainable services. FEDENE welcomes the proposal which accelerates the ecological transition towards carbon neutrality as the European Union is willing to step up the objectives of reduction of greenhouse gases emissions by 2030. Energy efficiency first FEDENE embraces the Commission’s proposal to make the ‘Energy Efficiency First’ Principle a cornerstone of planning and investment decisions, by giving it a legal basis under the Energy Efficiency Directive (EED). Its application all along the energy chain is essential to limit energy wastage and to reach the targets set in Article 4. To that extend, the implementation of energy efficiency measures should be considered prior to any fuel switching. A better uptake of Energy performance contract (EnPC) FEDENE welcomes the strengthened energy savings obligations. Therefore, EnPCs should be promoted as they are the key legal instrument which ensures that energy performance is improved, monitored, and maintained over time. Thus, the existing proposition for renovation of large non-residential public buildings, which need to assess feasibility of using an EnPC, is strongly appreciated. To make this measure effective, justifications should be required when an EnPC is not implemented following this assessment. FEDENE also supports that energy-intensive enterprises that have already concluded an EnPC are not required to conduct further energy management measures or energy audits as such contracts not only identifies improvement actions but also guarantees effective and sustained energy savings. The exemplary role of the public sector FEDENE welcomes that the revision of EED includes obligations for public bodies at all levels, with a specific objective of guaranteed and measured energy savings by at least 1,7% each year as it encourages the use of EnPC. Moreover, it is essential that third-party financing mechanisms could be used in EnPC in public sector in order to massify renovations and reach the 3% target of the total floor area of all public buildings Synergies between the EED and the European Emission Trading Scheme (EU-ETS) for buildings The revision of the EED must be made in synergy with the new EU-ETS for buildings. Both systems should support each other without creating any additional complexity or additional burden. However, the provisions of Annexe V (2) points e and h imposing separate allocations of energy savings could be detrimental to "white certificates" and other energy efficiency operations. Furthermore, it will create additional burden, as both measures contribute to the single objective of the Effort Sharing Regulation sector. Hence, FEDENE recommends putting away this requirement. DHC towards carbon neutrality The new definition of efficient DHC sets a clear pathway towards carbon neutrality by introducing a minimum share of renewable energy sources (RE). In that respect, this minimum share should include the part of waste heat recovered by DHC when it has been produced from RES. DHC operators should benefit from a reasonable period to comply with Article 24 (3). The European Commission is currently working on the calculation method to determine the RES cooling. FEDENE suggests revisiting the definition of efficient district cooling to support the development of such virtuous solutions, once the calculation method has been adopted. Final customers’ rights Article 20 (2) of the proposal requires the heating and cooling supplier to provide final consumers and final users with a comprehensible summary of the contract. While FEDENE supports transparency within a contractual relationship, it should be clarified that the relevant information is provided by each party to its respective client.
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Response to Updating the EU Emissions Trading System

8 Nov 2021

EU EMISSIONS SYSTEM TRADING DIRECTIVE FEDENE’s contribution to revision of the EU ETS directive November 2021 FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals dedicated to the implementation and development of sustainable services. FEDENE welcomes this initiative to revise the European Emissions Trading Scheme (EU-ETS) system, which enables a more ambitious pathway towards carbon neutrality, as the European Commission is willing to step up the objectives of GHG decrease in 2030 compared to 1990. 1. A carbon price supporting the decarbonisation of heating and cooling sector in buildings should be properly implemented FEDENE welcomes the introduction of a carbon price and the direction chosen by the EU Commission to implement a new ETS mechanism for buildings and transports as a way to ensure a fair “burden sharing” and a level playing field for building sector’s decarbonisation. This is needed for the new EU-ETS2 for buildings and road transports to be properly designed before start-up. It is fundamental that it remains a separated mechanism from the existing one and following an upstream approach. Moreover, the new EU-ETS should be:  introduced in a progressive manner so as to apprehend correctly all the particularities of the newly covered sectors, especially the heating and cooling sector;  designed in coherence with policies in force in order to minimise administrative burden ;  addressed with all the tools required to avoid price fluctuation. 2. A fair system guaranteed by essential measures The creation of the new EU-ETS for buildings and road transport will induce social, distributional and economic impacts that could jeopardize the ambition of this revision. In that respect, FEDENE supports the tools proposed by the Commission to mitigate those risks:  The Social Climate Fund should be given the sufficient financial resources to shield vulnerable households and finance a necessary switch to efficient low-carbon heating and cooling solutions. Consequently, the Social Climate Fund should support all decarbonisation measures including DHC systems and energy performance contracts.  Similarly, the Innovation Fund has to be properly designed and should finance innovative low-carbon solutions for heating and cooling if its resources are provided by a part of the new ETS mechanism for buildings and transports.  The rapid implementation of the Market Stability Reserve which is crucial to address the risks of excessive price fluctuation. Beside the cautionary measures mentioned above, the main priority must remain 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. 3. The introduction of a carbon price in the building sector should lead to a level-playing field of all solutions to accelerate its decarbonisation An adequate carbon price is needed to ensure a genuine level playing field within a given sector. It should ensure the economic competitiveness of renewable solutions to deliver the expected environmental and climate related benefits while preventing any market distortion. In particular, in the heating and cooling sector, there is a need for a uniform CO2 pricing signal to make sure solutions that provide numerous positive externalities such as DHC, can compete on equal footing with individual heating solutions. In any case, this revision should serve the purpose of achieving this result while optimizing regulatory and administrative burdens.
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Response to Detailed implementing rules for the voluntary schemes recognised by the European Commission

27 Jul 2021

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals dedicated to the implementation and development of sustainable services. FEDENE welcomes the opportunity to comment on the Draft Implementing Act on the rules to verify sustainability and greenhouse gas emissions savings criteria and low indirect land-use change-risk criteria. Please find our comments and proposed amendments included in the file attached.
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Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

FEDENE is a French professional association representing 500 energy and environmental service companies, 60.000 employees. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members implement and develop sustainable services. FEDENE supports the Commission’s ambition to reach carbon neutrality by 2050 which requires : - the establishment of a coherent and stable framework covering legal and non-legal tools, - the reinforcement of both private and public financial supports for virtuous solutions. 1. The publication of guidelines and best practices regarding the Delegated Act Article 8 of the Taxonomy Regulation establishes the obligation to publish non-financial information fairly assessing the sustainability of undertakings in the management or consolidated management reports contained in the company’s annual financial reports. Although the Delegated Act provides precisions regarding Article 8, its practical application would need further clarifications. For example, the qualification of district heating and cooling activities regarding Taxonomy’s nomenclature remains unclear. Guidelines and best practices should complement the Delegated Act to better understand and better enforce the Taxonomy. 2. Providing sufficient transparency without burdening energy transition actors FEDENE and its members support a greater transparency regarding non-financial statements. However, it should apply equally to all relevant undertakings, and it should not constitute an administrative burden for actors at the Green Deal’s forefront. The disclosed information should be limited to what is necessary for the private investors to evaluate the activity’s Taxonomy-eligibility and environmental sustainability. FEDENE fears that a full disclosure of all detailed calculations and all background data will create unnecessary complications for the undertakings without added value for private investors. Article 9 sets the obligation for financial and non-financial undertakings to provide KPIs covering the last five reporting periods. Although private investors need the relevant information on a sufficient time frame, disclosing this information on a five-year period seems unreasonable regarding the pursued objective. FEDENE proposes to lower this reporting period to two years. Although CAPEX and revenues can be disclosed at a relevant breakdown level, OPEX can carry commercially sensitive information. For this reason and because it is not indispensable to achieve the EU’s goal, publishing data and KPIs on OPEX could be encouraged but it should not be an obligation under the Taxonomy Regulation. The Delegated Act does not allow companies to account for a portion of turnover generated through and CapEx investments made in joint ventures. Companies should be able to declare the revenue and CapEx in material joint ventures pro rata their equity stake in the joint venture. 3. The Taxonomy should support energy services and sustainable heating and cooling. To ensure the necessary stability to encourage virtuous investments, the activities that are compliant with the technical screening criteria the time they are first reported should remain environmentally sustainable throughout the entire economic lifetime of their assets. Taxonomy should incentivise companies to green their portfolios and increase their share of Taxonomy-eligible activities. Activities that have been promoted by the EU and Member States should be able to be reported as ‘sustainable’ by undertakings. The recovery of waste heat is a crucial lever to speed up the decarbonisation of heating : Taxonomy should recognise it as a sustainable activity. In general, the Taxonomy regulation should consider an activity as sustainable when it meets RED II’s sustainability criteria. Finally, district cooling should be considered beyond chillers in the Delegated Act published in April.
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Response to Guidance on REDII forest biomass sustainability criteria

28 Apr 2021

La FEDENE, regroupe 500 entreprises de services centrés sur l’efficacité énergétique, la performance des bâtiments, la production et la valorisation de la chaleur et de froid renouvelables et de récupération ainsi que le facilities management et l’ingénierie de projets. Ces services, qui emploient plus de 60 000 salariés, répondent à deux enjeux majeurs de la transition énergétique : la réalisation d’économies d’énergies, le développement des énergies renouvelables thermiques. Ses adhérents, opérateurs publics et privés, gèrent des installations de production d’énergie notamment dans le secteur des réseaux des réseaux de chaleur alimentés majoritairement par la biomasse. Le bois énergie est un axe stratégique majeur pour délivrer les objectifs français et européens en termes de réduction des émissions de CO2 et répondre ainsi aux engagements concernant la transition énergétique et la lutte contre le changement climatique et atteindre la neutralité carbone en 2050. Substituant des énergies fossiles importées, il est principalement utilisé en France pour décarboner la production de chaleur, qui représente le plus important segment de consommation d’énergie finale (45%). La FEDENE accueille favorablement les recommandations proposées par la Commission visant à clarifier les orientations pour la durabilité de la biomasse. • Sur la capacité de l’installation : Les critères de durabilité de la biomasse forestière définis à l'article 29, paragraphes 6 et 7, de la directive (UE) 2018/2001 ne s'appliquent qu'à la biomasse ligneuse primaire, utilisée dans des installations de grande envergure produisant de l'électricité, du chauffage et du refroidissement ou des combustibles (« Les biocarburants, les bioliquides et les combustibles issus de la biomasse produits à partir de la biomasse forestière pris en compte aux fins visées au paragraphe 1, premier alinéa, points a), b) et c), remplissent les critères suivants en vue de réduire au minimum le risque d'utiliser de la biomasse forestière issue d'une production non durable »). Il nous parait indispensable de préciser ce point dans le projet de guide proposée par la Commission et de limiter l'application du seuil aux seules parties des installations considérées utilisant de la biomasse et que cela soit harmonisé au niveau européen. Les critères de durabilité et GES n'étant applicables qu'à la biomasse, il est logique que seule la partie de l'installation l'utilisant soit soumise aux exigences correspondantes de la directive. Pour illustrer par un exemple, il ne sera pas fait application des dispositions relatives à la durabilité dans le cas d'une installation de combustion de 30 MW composée d'une chaudière gaz de 25 MW et d'une chaudière biomasse de 5 MW. C'est dans cet esprit que sont prévues les dispositions relatives aux installations biogaz pour lesquelles la puissance à comparer au seuil d'applicabilité est mesurée en proportion de la part du biogaz dans la fourniture. Nous proposons de modifier le point 2 a) de l’article 1 du projet de guide comme suit : ajouter « biomass » après « total » : Primary biomass from forests, from wich solid biomass fuels have been produced that are used in installations producing electricity, heating and cooling or fuels with a total biomass rated thermal input below 20 MW • Opérateurs économiques : il est fait référence de nombreuses fois aux opérateurs économiques sans toutefois donner de définition précise de ces acteurs.. Pour lever toute ambiguïté, il conviendrait de le préciser dans le projet de guide • Article 3 (1) ( b) ( iv ): le projet de guide la commission propose des règles plus restrictives que celles imposées par la Directive. Aussi, nous proposons de remplacer “regulate” par « ensure » ce qui permet d'englober des pratiques dont le respect n'est pas forcément assuré par une législation nationale mais par d'autres dispositions réglementaires.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

FEDENE’S FEEDBACK ON EPBD REVIEW ROADMAP FEDENE is a French professional association representing public and private members implementing and developing sustainable services, district heating and cooling (DHC) operators, energy service companies (ESCOs). Considering the objectives and actions announced with the Renovation Wave and the renewed climate ambition for 2030, FEDENE welcomes a review of the Energy Performance of Buildings Directive which should focus on the effective reduction of the energy consumption of the European building stock. Moreover, as buildings are expected to play a critical role in the decarbonisation efforts which will be require in the years ahead, it is important to ensure that the EPBD is fully consistent with the legislative framework addressed by the “Fit for 55 Package” and contributes actively to the achievement of EU’s climate and energy objectives. Finally, a propre implementation of existing legislation remains key and should be further secured. ________________________________________ Promote the achievement of real energy performance objectives guaranteed over time A revision of the EPBD would represent an occasion to focus not only on improving buildings’ energy performance through renovation actions, but also on the role of solutions that allow to keep energy performance over time, through proactive energy management. These should systematically be considered as a complement to building renovations, depending on buildings’ specific circumstances and needs. Energy Performance Contracting (EnPCs), which additionally guarantees a level of real energy performance in the long-term, should be further promoted within the EPBD, especially in a strengthened framework for Energy Performance Certificates and potential Building Renovation Passports. A possible “deep renovation” standard should also promote a dynamic approach of building’s energy performance and require relevant projects to be carried under an EnPCs or at least monitoring of energy performance. Minimum Energy Performance Standards (MEPS) can raise awareness of the importance of improving energy performance for certain categories of buildings, but it is also essential to ensure that these are efficiently operated over time. Both digitalization and human expertise are key in this respect. ________________________________________ Link energy and environmental performance, possibly on a district scale Besides improving comfort levels and providing for additional benefits to users, increasing buildings’ energy efficiency is primarily key to reduce CO2 emissions. If energy efficiency must be the prerequisite for any other decarbonization 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, which rightly refers to primary energy as the main performance indicator, based on primary energy factors to be set at national, regional, or local level. Moreover, it allows to consider in the relevant calculations renewable energy supplied through the energy carrier as well as generated on-site, provided it applies on a non-discriminatory basis. Should minimum levels of RES be introduced for the building sector, or for some categories of buildings, it is essential to fully apply this principle and ensure a non-discriminatory treatment between on-site and nearby RES. The decarbonization of buildings should indeed be inscribed in broader decarbonization plans addressing entire neighborhoods and districts, necessarily linking renovations with decarbonization actions that are part of local energy planning, especially when it comes to heating and cooling. In this context, the availability and feasibility of solutions such waste heat recovery should be fully considered as one of the viable options to support building’s and districts’ decarbonization.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

The FEDENE welcomes the objective of the European Commission to establish a legislative framework to encourage sustainable investment. However, some issues in the present draft act and in the overall Taxonomy’s design would need to be clarified and possibly reviewed. Widen the recognition of energy performance services’ contribution In full coherence with the « energy efficiency first » principle, the draft act includes a category acknowledging the contribution of professional services to the energy performance of buildings (cat. 9.2). Beyond the building sector, improving the energy performance of the industrial sector as well as of the ICT sector, particularly for data centres is a major topic for energy transition, be it for the reduction of greenhouse gas emissions or for their economic competitiveness. Hence, we recommend the creation of an additional category « Professional services related to energy performance in the industry » in chapter 3, as well as an equivalent category for ICT in chapter 8. Restore consistency between renewable energies Article 10.1 of the Regulation (EU) 2020/852 states that an economic activity is considered as contributing substantially to climate change mitigation by «generating, transmitting, storing, distributing or using renewable energy in line with Directive (EU) 2018/2001» Hence, as for other renewable and recovery energies, such activities should not be classified as transitional activities when they meet the sustainability and greenhouse gas reduction criteria defined in Directive (EU) 2018/2001. Guarantee a stable framework for actors who invest in the energy and environmental transition. The aim for establishing a framework to facilitate sustainable investment is to « put in place incentives and methodologies that stimulate companies to measure the environmental costs of their business and profits derived from using environmental services. » To encourage businesses in engaging proactively in such activities and investments it is necessary to ensure stability of the framework used for assessing a given project over its lifespan, avoiding that virtuous investments become stranded assets. Parameters that define the eligibility for activities as environmentally sustainable will evolve along with technologies and environmental targets. It is therefore paramount to ensure that an investment implemented according to the taxonomy criteria will remain eligible at least for its economic life. Recognise the contribution of actors committed early in the transition The Regulation (EU) 2020/852 on the establishment of a framework to facilitate sustainable investment stipulates in art. 8 that undertakings subject to an obligation to publish non-financial information present « the proportion of their turnover » and « the proportion of their capital expenditure and the proportion of their operating expenditure» related to assets or processes associated with economic activities that qualify as environmentally sustainable. A number of actors have engaged themselves in the energy and environmental transition and have committed investment capacities in the field of energy efficiency or renewable and recovery energies in coherence with prescriptions of European regulations that prevailed at the time that actively promoted these actions. An adapted framework should therefore be defined for assessing investments committed before the entry into force of the taxonomy. This framework should classify as environmentally sustainable investments (and associated activities) that, whilst not fully meeting the criteria specified in the 2020 taxonomy, were implemented according to policies developed in the European Regulations or benefited from a support in the domain of energy efficiency or renewable and recovery energies. In coherence with above, this inclusion should apply for their remaining economic lifetime. Absence of such a framework would result in penalizing those who first acted on climate mitigation.
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Response to Updating the EU Emissions Trading System

25 Nov 2020

FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals dedicated to the implementation and development of sustainable services. FEDENE welcomes this initiative which is in agreement with a more ambitious pathway towards carbon neutrality, as the European Commission is willing to step up the objectives of GHG decrease in 2030 compared to 1990. 1. Overall coherence of the system aiming at reducing CO2 emissions The chosen mechanism in this revision should be as easy to implement as possible to grant visibility to stakeholders. As such: - It should be made in synergy with the other regulations and tools currently in force and in use, and for sectors newly included, made in coherence with the regulatory framework of the entire activity relevant to those sectors. More specifically, one has to be careful when it comes to sectors newly and possibly included into the system, for there is a strong risk of overlapping with existing and dedicated national policies : this could lead to a double taxation. - An adequate CO2 price is needed across the different sectors to ensure a genuine level playing field. In particular, in the heating and cooling sector, there is a need for a uniform CO2 pricing signal to make sure solutions that provide numerous positive externalities such as DH, can compete on equal footing with individual heating solutions. This would allow for a fair burden sharing, as well as to minimize the regulatory burdens and to drive the decarbonisation of heating and cooling sector by ensuring the economic competitiveness of renewable solutions. Decarbonisation will be achievable only through a global and coherent system regarding GHG regulation, with a revision of the whole mechanism (Market Stability Reserve, a progressive increase of the linear factor with the proposed reduction of allowances, one-off rebasement of the cap …) in order to ensure an incentivising CO2 price. 2. A revision process that should ensure fairness and solidarity - Sectors already covered by the scheme today should not bear the consequences of its extension. - If the system were to be extended, it should be built in a spirit of solidarity, and there should be mechanisms to mitigate social and distributive impacts (e.g.: by reinvesting and recycling part of the revenues of the system in building renovation). ETS revenue should also be re-invested to further help sectors included to achieve climate neutrality via accessible funding opportunities aimed at supporting energy efficiency actions and decarbonisation (e.g.: CCUS technologies and applications, modernisation of DHC networks). It should also be effective in staving off increase of energy poverty. 3. Extension of the scope - In case of the extension to the building sector: as building energy efficiency and fuel switch are an integral part of the decarbonisation effort, such an extension could contribute to creating a real level playing field, but would only work if designed upstream. Indeed, 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. - Maintaining the exemption of WtE plants: EU ETS would not be the most appropriate tool to decrease GHG emissions from WtE plants because it applies too far from the source of fossil waste (including plastic): as operators have no choice on the characteristics of the input, this taxation will not be effective for the reduction of fossil CO2. WtE being part of an integrated system waste management complying with the rules set by the Waste Framework Directive, priority should be given to upstream regulations of waste flows to minimize as much as possible the fossil content of residual waste.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

FEDENE’s feedback to EED Review Roadmap September 2020 FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals dedicated to the implementation and development of sustainable services. The EU steps 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 prioritized. 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 prioritize 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 towards renewables and energy efficiency, which instead, should be mutually reinforcing. That is why the EU energy efficiency target, and possibly national targets, should be made binding. ● Focus on the optimization of energy consumption through effective energy management Energy management solutions, such as those offered by energy efficiency services (EES), are an essential tool to optimize energy consumption, and thus reduce CO2 emissions, in both buildings and industrial facilities. The current EED already promotes EES, notably in Article 18. However, many provisions just call on Member States to encourage the development of the EES market, without requiring the enforcement of mandatory measures. Moreover, the role of energy management should be better and further promoted across different parts of the Directive, including: - 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. - Article 8 on energy audits, which should lead to implement actions, and prioritize 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. - 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 relevant pieces of legislation, to become key elements of any energy planning strategy at local level
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

IIA Roadmap - Renewable Energy Directive FEDENE’s contribution FEDENE is a French professional association representing 500 energy and environmental service companies. From public and private district heating and cooling (DHC) operators to energy service companies (ESCOs), FEDENE’s members employ 60.000 professionals dedicated to the implementation and development of sustainable services. 1. FEDENE supports the Commission’s new goals for the planet By 2050, the European Union wants to become the first continental area reaching carbon neutrality. FEDENE supports the Commission’s decision to step-up the pace for the GHG emissions reduction and to set a more ambitious target for 2030. However the wider transformation of the European economy also requires: - The establishment of a coherent and stable framework covering legal and non-legal tools, - The reinforcement of financial supports for virtuous solutions. 2. Provide a sufficient financial support for sustainable DHC The supply of heat and cold represents around 50% of the Union’s energy consumption. As stated in the Energy Sector Integration Strategy, DHC can answer local demand for decarbonised heat and cold by aggregating renewable and waste energy sources available nearby1. Besides, their thermal energy storage capacity can enhance the use of these green energies through a better balance between supply and demand. DHC have a major role to play in the decarbonisation of heating and cooling therefore a revised directive with an enhanced ambition requires an adapted financial framework to boost their greening and development. In addition to the introduction of a fair carbon pricing for fossil fuels, an increased flexibility in the public aids rules would enhance their competitiveness and help low income households. 3. Ensure a consistency between RED, EED and EPBD Energy efficiency first should remain the ground rule of the EU’s environmental and climate policy. The effective application of this merit order will increase the share of low carbon fuels by reorienting spared RES capacities to substitute other fossil fuel consumption. EED and RED revisions must be conducted jointly and their impact assessments should also consider the relevant consequences on each other and possibly on EPBD. This also means that energy performances should be reported in primary energy and final energy in order to get a holistic view on each heating and cooling solution. The metrics used in implementing these objectives should ensure a fair representation of the performance of all production means (individual or collective) and all RES and low carbon fuels (biomass, green gas, waste heat, energy from waste, renewable cooling...). 4. Biomass is an essential component of the energy transition Today in France, biomass is the most important RES2 and the second in DHC3. In the coming decades it will play a crucial role in the transition of the energy sector as it is widely available, sustainable and technologically mature. Maintaining this current dynamic requires a stable regulatory framework after the recent revision of REDII, setting the criteria for biofuels (Article 29-31). Such stability is a prerequisite for viable investment decisions to be taken by energy systems operators. 5. Encourage the reuse of industrial and commercial waste energy The decarbonisation of the heating and cooling sector must benefit from a higher reuse of waste heat from industrial plants, commercial buildings and waste-to-energy facilities by DHC, in addition to the promotion of RES. Promoting the valorisation of waste heat or waste energies as a by-product calls for a stable legal framework and a stronger financial support. Such support could include risk mitigation tools, like insurance fund schemes, that would unlock potential on projects where typical industrial horizon is not sufficient to cover for a proper return on the investment.
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Response to Revision of the EU Emission Trading System Monitoring and Reporting Regulation (MRR)

24 Jul 2020

A. Presentation : FEDENE, Federation of Energy and Environment Services, brings together, through seven specialized professional trade unions, 500 service companies focused on energy efficiency, building performance, district heating & cooling, renewable heat & cold production, waste heat & cold recovery, facilities management and project engineering. These services address two major challenges of the energy transition: the achievement of energy savings in buildings and industry as well as the development of renewable heat. With 60,000 employees and a turnover of 11 billion euros, FEDENE members offer tailor-made services at the heart of the territories, based on real performance commitments over the long term, both quantitative and qualitative. They are involved in renovation projects, from the design and realization of solutions, including where appropriate their financing, to the operation and relationship with the end customer. B. The use of biomethane by energy service operators : The EU Emission Trading System is the main tool to drive decarbonisation and tackle climate change. EHP welcomes the update of the monitoring, reporting and verification rules to better recognize the role of biofuels and guarantees of origin (GO) in the EU ETS, in line with the new Renewable Energy Directive. The energy service operators members of FEDENE are users of biomethane guarantees of origin (GO), as fuel, as part of the greening of the energy mix of the facilities they operate in three main areas. i. District heating and cooling (DHC) decarbonisation when under EU-ETS :  In marginal use, in addition to other EnR & R, to achieve a satisfactory rate when no other technical solution is viable and thus allow the development of networks in ultra-high density areas and in economically and socially acceptable conditions for end users. It happens that urban configurations in very dense agglomerations make both technically and economically complex the greening of the energy mix of DHC  In transitional use, in order to support the competitiveness of the DHC during the development and greening phase in an enhanced requirement framework to increase the enrolment rate (55% in 2025, then 60% in 2030) allowing to benefit from the reduced VAT rate on heat deliveries;  Flexibility during the transitional phases and especially during the DHC network’s ramp-up (subscription initiation, densification, extension, etc.) or in order to secure the achievement of the EnR & R rate in the face of climatic or technical hazards; ii. Industrial facilities under EU-ETS To achieve decarbonization, gas-consuming industries can resort to green gas consumption, which is sometimes - for technical reasons - the only solution. The use of biomethane under competitive economic conditions, contributes to the development of local green energy projects. C. Reflections on the EU-ETS and its link with the guarantees of origin : The implementing act opens two avenues for the choice of member states:  A "purchase record" mechanism which would be the equivalent of a green certificate or a guarantee of origin (method 1)  An average rate of incorporation of biomethane into the natural gas of each voluntary State making it possible to generate ETS in proportion to the consumption of natural gas (method 2) We suggest that the European Commission’s MRR takes into consideration the following general points: • Biomethane is a carbon-neutral renewable energy which has a key role to play in the energetic transition, in full complementarity with renewable electricity. As such, it is important to promote sustainable biomethane guarantees of origin consumption for gas-consuming industrial sites and DHC, by recognizing it in the ETS system. • Choosing not to recognize biomethane guarantee of origin, as a renewable carbon neutral energy, in the ETS should not be an option. It should also not be possible for Member States to refuse the recognition of biomethane used in ETS installati
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