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The Coalition for Energy Savings

The Coalition for Energy Savings advocates for energy efficiency as the cornerstone of EU energy policy to achieve security, sustainability and competitiveness.

Lobbying Activity

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen)

18 Nov 2025 · energy efficiency

Meeting with Niels Fuglsang (Member of the European Parliament) and ROCKWOOL A/S

6 Nov 2025 · Energy

Coalition for Energy Savings urges efficiency to lower electrification costs

8 Oct 2025
Topic — The EU Electrification Action Plan aims to transition energy demand from fossil fuels to electricity.
Message — The Coalition recommends integrating demand-side resources into energy system planning and investment decisions. They propose a 10-20% reduction in industrial electricity demand through efficiency actions. The plan should prioritize efficiency to optimize grid capacity.123
Why — This ensures that energy efficiency services are prioritized equally with supply-side energy options.4
Impact — Infrastructure developers lose profits as efficiency measures moderate the need for new electricity grids.5
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Meeting with Pierre Schellekens (Director Energy)

3 Oct 2025 · Exchange on the Commission’s upcoming revision of the Governance Regulation and simplification agenda

Meeting with Rosalinde Van Der Vlies (Director Energy) and

16 Sept 2025 · Exchange of views on priorities for energy efficiency policy

Meeting with Margareta Djordjevic (Head of Unit Energy)

12 Sept 2025 · Exchange of views on new priorities for energy efficiency policy

Meeting with Niels Fuglsang (Member of the European Parliament)

24 Apr 2025 · Meeting on energy

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

22 Apr 2025 · Energy efficiency

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

15 Apr 2025 · Simplification

Meeting with Bruno Tobback (Member of the European Parliament)

8 Apr 2025 · Breakfast - Looking ahead: What role for Energy Efficiency after the Clean Industrial Deal?

Meeting with Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

31 Mar 2025 · Potential Omnibus package and Clean Industrial Deal (CID).

Meeting with Thomas Auger (Cabinet of Executive Vice-President Teresa Ribera Rodríguez)

28 Mar 2025 · Energy efficiency.

Meeting with Anna Stürgkh (Member of the European Parliament, Rapporteur)

13 Mar 2025 · INI Report on Grids

Meeting with Jutta Paulus (Member of the European Parliament, Shadow rapporteur) and EPIA SolarPower Europe and

7 Mar 2025 · Security of Energy Supply

Meeting with Annalisa Corrado (Member of the European Parliament)

28 Feb 2025 · Clean Industrial Deal, Affordable Energy and Energy Efficiency

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen), Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen)

20 Jan 2025 · The role of energy efficiency in the Clean Industrial Deal

Meeting with Andrea Wechsler (Member of the European Parliament) and Stichting European Federation of Energy Traders (We operate under the name Energy Traders Europe)

12 Dec 2024 · EU Energy and industry policy

Coalition for Energy Savings urges demand-focused security architecture

26 Nov 2024
Topic — Evaluation of the performance and legislative gaps in EU energy security.
Message — The Coalition calls for shifting focus from supply diversification to permanent energy demand reduction. They demand structural measures that align energy security with the EU's long-term climate goals.123
Why — Prioritizing efficiency justifies the group’s mission and lowers system-wide infrastructure maintenance costs.45
Impact — Fossil fuel exporters and energy importers lose market share as consumption drops.67
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Meeting with Benedetta Scuderi (Member of the European Parliament)

14 Nov 2024 · Energy

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

22 Oct 2024 · Discussion on energy efficiency

Meeting with Niels Fuglsang (Member of the European Parliament)

12 Sept 2024 · Meeting on energy

Meeting with Elena Sancho Murillo (Member of the European Parliament)

12 Sept 2024 · Relevant issues to the ITRE Committee

Meeting with Marina Mesure (Member of the European Parliament)

11 Sept 2024 · Politique énergétique européenne - efficacité énergétique des bâtiments

Meeting with Bruno Gonçalves (Member of the European Parliament) and EUROPEAN TRADE UNION CONFEDERATION and

5 Sept 2024 · ITRE policies

Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

The Coalition for Energy Savings would like to thank the European Commission for the opportunity to provide its views on the upcoming report assessing the level of EU & national funding for energy efficiency. We believe that an analysis of the total public funding available for energy efficiency improvements and whether there is a gap to the financing needs is an important step to ensure a sufficient and strategically allocated flow of capital for energy efficiency to deliver long-lasting energy savings. The new Energy Efficiency Directive (EED) increased the EU energy efficiency target for 2030 to an 11.7% reduction compared to the PRIMES 2020 scenario, which will require additional and better use of public funding to be met. In addition, a recent European Court of Auditors report underlines that there is no information that sufficient financing will be made available to reach the 2030 targets. In that context, a Commission report on this aspect is very much welcomed and needed. The Commissions report should not only assess the level of existing EU and national funds available for energy efficiency, but whether the existing funds are used effectively and the potential impact of not prolonging the current level of funding in the next Multiannual Financial Framework (MFF). To facilitate access to funds, we strongly support the setting up of a Union-wide mechanism for energy efficiency, enabled by the earmarking of a certain percentage of the next MFF, in which the distribution of funds is simplified and more result-oriented (notably linked to the energy performance achieved and maintained). Such a long-lasting mechanism would offer predictability and stability for all actors. It should also address the coordination needs throughout the various funds and how this is being managed at national level. Importantly, any public funding must also be targeted to those who need it the most. The Commissions report should therefore review how current efficiency funding streams support households in energy poverty and provide recommendations, based on national examples, of how this could be improved, namely to help the preparation of the Social Climate Plans due by next year. Finally, it is crucial that public funding is used to leverage private investments, in order to maximise their impact and lead to a better use of the public resources available. As energy efficiency projects are often of a small financial size, technical assistance is needed to aggregate them and make them more attractive to private investors. Best practices, as examples stemming from the ELENA facility, could be showcased in the Commissions report to Parliament and Council.
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Meeting with Niels Fuglsang (Member of the European Parliament)

7 Nov 2023 · Energieffektivisering

Response to Review report on the Governance Regulation of the Energy Union and Climate Action

31 Jul 2023

The Coalition for Energy Savings would like to thank the European Commission for the opportunity to provide its views on the functioning and effectiveness of the Governance Regulation. The adoption of the Governance Regulation was a major milestone in the EUs energy and climate legislative framework as it streamlined the different climate and energy planning and reporting requirements, in particular through the introduction of the National Energy and Climate Plans (NECPs) and the regular progress reports. It also facilitated an integrated approach to the EUs and national energy and climate policies based on the five dimensions of the Energy Union (decarbonisation, energy efficiency, energy security, internal energy market, and research, innovation and competitiveness). Notwithstanding these positive developments, on the energy efficiency dimension, there are some instances where the Governance Regulation did not fully deliver on its objectives. The new Regulation did not manage to put in place the necessary mechanisms to address the insufficient national ambition to achieve the EU 2030 energy efficiency target. Indeed, according to the Commissions EU-wide assessment of the integrated NECPs, Member States' energy efficiency pledges did not add up to the 2030 EU energy efficiency target of 32.5% (PRIMES 2007 scenario), with a gap of 2.8% for primary energy consumption and 3.1% for final energy. The Governance Regulation introduced for the first time in EU law a definition of the Energy Efficiency First (EE1st) principle, which was useful to raise awareness about the importance of prioritising demand-side resources. However, this inclusion did not lead to a systematic application of the principle in national policies and the consideration of energy demand reduction measures on an equal footing with supply-side resources. Indeed, the Commissions assessment found that most final NECPs only set out limited details on the application of this principle. The integrated NECPs (due end 2019) were out of sync with the Energy Performance of Buildings Directives (EPBD) Long-term renovation strategies (due March 2020) which limited the positive synergies for national planning of building renovations. A similar situation is likely to occur as the EPBD is still currently under revision and the final text might only be adopted close to the deadline for submitting the final NECP updates. The new 2023 Energy Efficiency Directive (EED), just agreed by co-legislators, introduces new requirements and tools to address the first and the second points, going beyond the Governance Regulation. For instance, an Ambition Gap Mechanism is introduced for final energy contributions to solve the gap by design between Member States' declared contributions and the 2030 EU energy efficiency target. The new EED also introduces a specific article on the EE1st principle, providing a clear legal basis for its streamlining in energy-related decisions and investments, and requiring the consideration of the broader societal benefits of energy savings in cost-benefit analyses. These positive additions are however currently not yet reflected in the Governance Regulation, which is now out of sync with many of the changes introduced by the Fit for 55 package, including the EED. In that context, the Coalition for Energy Savings welcomes a timely revision of the Governance Regulation in order to both align it with the new EED, as well as to address the remaining missing elements needed to set up a strong legislative framework, such as the binding character of national energy efficiency contributions or the extension of the Ambition Gap Mechanism to primary energy contributions. The revision of the Governance Regulation can also contribute to setting a pathway for energy efficiency progress well beyond 3030, with, for example, intermediate milestones and targets for 2035 and 2040, in coherence with the upcoming EU 2040 climate target.
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Coalition for Energy Savings urges efficiency-first 2040 climate target

23 Jun 2023
Topic — The Commission is establishing a greenhouse gas emissions target for 2040.
Message — The coalition wants energy efficiency to be the foundation for 2040. They request specific 2035 objectives and continued use of triple targets.12
Why — Prioritizing savings ensures the long-term deployment of their members' efficiency technologies.3
Impact — Traditional energy providers lose income as permanent efficiency measures reduce demand.4
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Meeting with Maria da Graça Carvalho (Member of the European Parliament, Shadow rapporteur)

22 Jun 2023 · Electricity market design, main priorities from the coalition of energy savings, importance of digitalisation and smart energy

Meeting with Niels Fuglsang (Member of the European Parliament, Rapporteur)

7 Mar 2023 · Energy Efficiency

Meeting with Niels Fuglsang (Member of the European Parliament)

11 Jan 2023 · Energy

Meeting with Sirpa Pietikäinen (Member of the European Parliament)

12 Sept 2022 · Energy Efficiency Directive

Meeting with Ditte Juul-Joergensen (Director-General Energy) and Google and

25 Apr 2022 · US-EU Task Force Convening: Clean Energy Technologies. Carrier, Tado and the European Council for an Energy Efficient Economy (ECEEE) also participated.

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

29 Mar 2022

The Coalition for Energy Savings welcomes the EPBD recast proposal. It strengthens some existing provisions but fails to fully leverage the Energy Efficiency First Principle. The proposal does not accelerate actions at the pace needed to achieve the EU’s 2030 energy and climate targets and improve its energy security. The below summarises our initial reaction to the proposal: Minimum Energy Performance Standards (MEPS): We support the provision to set up MEPS, but this article should be further strengthened. As energy renovations require long-term planning and predictability for market actors and citizens, the limited scope and timeframe of the proposed MEPS risk missing out on the multiple benefits of ambitious energy renovations and creating lock-in effects. To ensure the achievement of the 2030 and 2040 milestones for the EU building stock and the transformation of all existing buildings into Zero-Emission Buildings (ZEBs) by 2050, MEPS should not be limited to G and F buildings only. An effective MEPS scheme shall be designed to ensure that all buildings are renovated to achieve higher levels of performance over time, with more modern technical building systems and new, efficient and renewable-based heating and cooling technologies. This will ensure deep renovations (whether in one go or staged) are accelerated and deliver their multiple benefits, including greenhouse gas emission cuts and mitigation of energy poverty. ZEBs: We welcome the new ZEB definition. However, as it only addresses operational carbon emissions, its name should better reflect this aspect. We believe that using only primary energy consumption (PEC) indicators to define ZEBs might deprioritize end-use energy savings measures in buildings. To promote quality design of ZEB buildings that respects the Energy Efficiency First Principle, we believe that the EPBD Annex III should establish thresholds for both final and primary energy use. The PEC thresholds used for new constructions should also be lowered. For new buildings, given the need to urgently stop climate change and improve the EU energy security, the 2030 date should be advanced. Specific attention should also be put on maintaining high operational energy performance over time in new buildings. Deep renovation: We welcome the introduction of a legally binding definition for staged-deep and deep energy renovation but regret that it is not being used in the Directive as the underlying guiding principle for the ambition of all energy renovations or financing programmes. All national renovation programmes should provide proportionately greater financial incentives for deep renovations (which should consider all solutions available in the market). Building Renovation Plans (BRPs): We support that BRPs are proposed to become more operational roadmaps than Long-term Renovation Strategies. BRPs are important planning (and reporting) tools for Member States, thus they shall provide precise trajectories for the reduction of energy use and full decarbonisation of all building segments. MEPS should be instrumental in achieving the latter. Also, BRPs should be better linked with other EU planning tools to grasp the positive synergies with other Directives (for instance EED Art.23) and local heat planning. When drafting BRPs, cooperation with stakeholders, including energy communities, is crucial to ensure that renovation efforts are tailored to citizens’ needs. Energy Performance Certificates (EPCs): Considering the many provisions in the proposal that rely on the soundness of the EPC framework, EPCs coverage should be further boosted by, for instance, introducing an obligation for all buildings to have an EPC in place well before 2030. Without a comprehensive coverage, all the positive changes suggested (ensuring more harmonisation, comparability, and reliability of EPCs) might end up having little to no impact on boosting renovations and improving information on the energy performance of buildings.
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Meeting 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

19 Nov 2021

The Coalition for Energy Savings is thankful for the opportunity to provide feedback on the Energy Efficiency Directive (EED) recast proposal. We believe that the EED recast is a core element of the Fit for 55 package as energy savings are the prerequisite to reach Europe’s 2030 energy and climate targets in an affordable way. The Commission’s proposal is a solid basis to strengthen the energy efficiency framework and accelerate the delivery of energy savings in Europe, but more is still possible and achievable. The increase of the energy efficiency target for 2030 to 36% for final energy consumption and 39% for primary energy consumption remains in the lower end of what is achievable through measures that make economic sense. The Coalition recommends to step-up ambition of the energy efficiency target to at least 40% (PRIMES 2007) and to 17% (PRIMES 2020) which is supported by a recent assessment of the cost-effective energy savings potential in Europe. We welcome the introduction of a binding EU energy efficiency target for 2030; however, to fully ensure that Member State deliver their share and the EU target is achieved, national binding contributions are necessary. This will provide certainty for all actors, including businesses and investors. We also support the introduction of a formula for Member States to calculate their national contributions to the EU target. We note however that only the use of the formula is binding, not its result, which leaves the possibility for Member States to adjust their contributions to national circumstances. This level of discretion undermines the effectiveness of the formula and the achievement of the 2030 EU target. The Coalition also supports the introduction of a gap filler mechanism which requires Member States diverging from their trajectory to get back on track within one year of the Commission’s assessment. To improve enforceability, binding milestones should be introduced as this will reinforce the role of the trajectories and the gap filler mechanism. The Energy Savings Obligation remains a core article of the EED. In that sense, we recommend increasing the annual rate to at least 2% to support the achievement of a higher energy efficiency target. In addition, we support that a minimum share of savings is achieved among people affected by energy poverty, vulnerable customers and people living in social housing, while noting that the scope of this ringfencing should be enlarged to low-income households and be properly monitored and implemented. We also support the extension of the obligation to renovate 3% of floor area per year to all public buildings owned by public bodies. However, to ensure that public bodies also rent the most performing buildings, the public procurement rules should be strengthened by requiring that contracting authorities only make new rental agreements for buildings that are nearly-zero energy buildings (NZEB). Finally, we support the deletion of the alternative approach to renovation and the increase of the requirement’s depth to require that all renovations achieve NZEB standards. To broaden energy efficiency actions of the public sector beyond the renovation of their buildings, we are also pleased to see the introduction of a new target for all public bodies to reduce their total final energy consumption by at least 1.7% per year. The Coalition warmly welcomes the introduction of a new article providing a legal basis for the Energy Efficiency First principle, which requires that energy efficiency solutions are considered in planning, policy and investment decisions in energy and non-energy sectors. However, the article should be reinforced by deleting the reference to “major” investment decisions, include a stronger obligation to develop cost-benefit methodologies to take into account the wider benefits of energy efficiency, and define clear compliance criteria to assess its implementation.
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Meeting with Kyriacos Charalambous (Cabinet of Commissioner Johannes Hahn)

28 Jun 2021 · Discussion on the revision of the Energy Efficiency Directive and general discussion on Fit for 55

Meeting with Filip Alexandru Negreanu Arboreanu (Cabinet of Commissioner Adina Vălean)

24 Jun 2021 · Meeting to discuss energy saving.

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

3 Jun 2021 · Fit for 55 Package and the revision of the EED Directive

Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

22 Mar 2021

The Coalition for Energy Savings welcomes the possibility to provide feedback and recommends that the following three considerations guide the upcoming EPBD revision: First, the EPBD revision must truly boost energy savings in the building sector to contribute to the achievement of a higher 2030 energy efficiency target; a stronger EPBD is also a prerequisite to meet a higher 2030 GHG emissions reduction target, the EU climate neutrality objective, and more broadly the aims of the European Green Deal. The revision of the EPBD should be forward-looking, holistic and trigger a fair and socially just transition providing the basis for EU climate endeavours, but also decent-quality homes for all citizens and economic recovery from the COVID-19 pandemic. Second, together with the EPBD, the strengthening of the whole energy efficiency framework is crucial to deliver more and deeper energy renovations across the EU. In particular, the upcoming EED and EPBD revisions should be well coordinated, build on each other and designed to maximise synergies and positive interactions. For example, the strengthening of the EED Art.5 on the exemplary role of public buildings should open the way for stronger measures in all building segments in the EPBD and EED Art.7 should be revised to ensure the energy savings obligations is a driver for building renovations. Finally, the Energy Efficiency First principle (EE1st) should be properly included and reflected in the revision of the EPBD, to ensure that maximum effort is placed on reducing overall energy demand of buildings so as to enable renewable penetration and facilitate the achievement of a highly energy-efficient and decarbonized building stock by 2050. A correct application of the EE1st principle also means that the multiple benefits of energy renovations are properly factored in, including through good modelling in the EPBD Impact Assessment. More specifically, and to maximise energy savings in the building sector and ensure the achievement of a highly-energy efficient and decarbonised building stock by 2050, the EPBD revision should: -Drive an increase of building renovations: the doubling of the current renovation rate is not enough; tripling the rate is necessary and a much stronger focus on the depth of the renovations is equally needed. -Ensure proper energy management in buildings: keeping in check energy consumption during the buildings’ operational phase is also crucial to reduce overall energy use and emissions of buildings. -Encourage a faster replacement of heating and cooling (H&C) equipment: the replacement of old and inefficient H&C systems with technologies in line with EU 2030 and 2050 targets should be promoted. -Support renovations at a district or neighborhood level: aggregation of renovations at local level can help achieving economy of scales, facilitate integrated energy planning and encourage participation of citizens and communities, hence maximizing energy efficiency, system integration and overall opportunities for decarbonizing H&C at a larger scale, in line with the EE1st principle. -Activate buildings’ participation in the energy system: in addition to reducing energy demand, buildings can manage, store, and generate energy; they should therefore be recognized as crucial infrastructure for Europe. -Empower citizens to take action on renovations: Engagement of citizens and communities is necessary to make renovations happen; their involvement is determinant to both understand their needs and create support for the renovation agenda. Our full contribution can be found in the attached document, which details crucial measures for the EPBD revision; in particular, the Coalition welcomes the introduction of Minimum Energy Performance Standards as a key tool to drive renovations in line with the EU climate neutrality goal and to improve living conditions, especially of the more vulnerable citizens.
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Meeting with Kadri Simson (Commissioner) and

1 Mar 2021 · Energy aspects of Fit for 55, renewables and energy efficiency, with special focus on biomass.

Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

25 Nov 2020

The Coalition for Energy Savings would like to thank the Commission for the opportunity to provide feedback to the roadmap on amending the Effort Sharing Regulation (ESR). The ESR and energy efficiency policies are strongly interconnected. National energy efficiency policy measures put in place to implement the Energy Efficiency Directive (EED) are often the main instruments of Member States to meet their ESR targets. In particular, the EED’s energy savings obligations under Article 7 require actions at the energy end use level, usually targeting the main ESR sectors, buildings and transport. With its more robust enforcement mechanism, the ESR has played so far an important role in some Member States as a driver for energy efficiency actions, while at the same time incentivising other Member States to create a surplus of allocations by undertaking serious energy efficiency actions as well. The revision of the ESR is an opportunity to further strengthen those synergies. The EU has to ensure that Member States put in place policies to overcome the non-price related market barriers to energy efficiency investments and to help vulnerable and hard to reach energy users. Only then, can the energy transition be fast, fair and attractive to people and businesses. However, a phasing out of the ESR or reducing its scope linked to a possible extension of the EU-ETS would be unacceptable. In addition, the interaction of an extension of the EU ETS with existing policies should be carefully assessed.
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Response to Updating the EU Emissions Trading System

25 Nov 2020

The Coalition for Energy Savings would like to thank the Commission for the opportunity to provide feedback to the roadmap on amending the Emission Trading System. Carbon pricing is an instrument that can complement energy efficiency support schemes and regulatory actions to deliver energy savings. It can make investments in energy efficiency improvements more attractive. However, pricing signals alone are not an appropriate tool to overcome market barriers, mainly because the price elasticity of energy is very low and most barriers are non-economic barriers. Therefore, the Coalition for Energy Savings would like to underline that specific support schemes and regulatory measures remain key in order to create demand for energy efficiency investments and to develop the energy services market.
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Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

27 Oct 2020 · Business and investor support for higher ambition and the just transition

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

21 Sept 2020

The Coalition for Energy Savings thanks the Commission for the opportunity to react to the roadmap on the Energy Efficiency Directive (EED). The Coalition has been advocating for a strong energy efficiency legislative framework for over a decade. Our diversity in membership is a key asset in that effort. The Coalition welcomes the strong energy efficiency narrative in the roadmap, as well as its proposal to revise the current EED. Applying the Energy Efficiency First principle, the core focus of the energy policy in the EU, needs a robust legislative and regulatory framework and enforceable targets. The EED has secured the continuation of policies and the introduction of new instruments at national level. However, it did not lead to the investments required to tap the savings potentials across sectors. In many countries, the energy savings delivered fall short of the minimum required and are often insufficient to achieve the national indicative targets. Enforcement has not been effective, and some rules not stringent and ambitious enough. Either way, the review has to lead to a comprehensive revision of the EED, a strengthening of the legal requirements and effective enforcement. Already for the EED I and the EED II and now for the upcoming revision, the European Parliament has asked to make the national energy efficiency targets binding. It is arguably the most effective way to secure the delivery of the given objectives. Nevertheless, the co-legislators agreed on indicative targets (Article 3) with binding measures (Article 7). This has not worked sufficiently. The EED revision has to raise the level of ambition of the current policy framework. The existing target for energy efficiency of 32.5% by 2030 needs to be increased higher than the proposed 36 % in the Commission’s 2030 Impact Assessment to at least 40% to tap the cost-effective energy efficiency potential. Above all, to ensure delivery, the EU-level target, as well as national contributions, should be made binding. A stronger and binding target is a key enabler to ensure the success of other Commission’s initiatives (Renovation Wave, Energy System Integration, Industrial Strategy, Circular Economy Action Plan). All the provisions related to measures detailed in the roadmap are important and need to be updated. In particular, Article 5 does not currently deliver. It needs to become a leading requirement to create a renovation wave for the public sector and deliver on its exemplary role, such as with renovation of schools or hospitals. To strengthen its impact, Article 5 needs to be broadened by including all public buildings, while avoiding regulatory loopholes. Last but not least, the EED revision needs to consider adjustments to the legal architecture set by Article 7. Solutions have to be provided to mitigate the current issues of eligibility and additionality of Article 7 measures, as new EU policies will be introduced to meet the revised GHG emission objectives (carbon pricing, vehicle standards…). The interaction of those provisions with the Article 7 energy savings obligation needs to be assessed. It should lead to an increase of the energy savings obligation and a simplification of its implementation to guarantee its enforcement, together with a reinforced monitoring system. Such ambition for the revision of the EED is in line with the European Green Deal. Reducing the overall energy consumption is the bedrock for achieving climate targets. Achieving carbon neutrality will be too slow and expensive without a significant reduction of energy demand. Energy savings are fast, fair and attractive. On the ground, increasing energy efficiency means delivering stable, quality local jobs, a healthier environment, increased energy security while spending less on energy bills and imports. In short, strengthening the EED is a way to ensure a deep economic transformation that is supporting a circular, resilient and equitable post-COVID recovery.
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Response to Strategy for smart sector integration

8 Jun 2020

Smart sector integration is seen as a contribution to increase the flexibility of the energy system and thus to facilitate the energy transition. It addresses the interlinkages between different sectors, namely gas, electricity and heat. This includes also the possibilities to recover unavoidable excess heat that can be used in district heating and cooling systems. In order to ensure a sustainable sector integration development, it is essential to apply the Energy Efficiency First principle. This means that energy efficiency considerations over the entire supply chain and in conversion technologies need to be considered in developing an EU Smart Sector Integration Strategy and in all the EU’s infrastructure planning. Reducing energy demand before extending capacities is key to avoid the creation of an oversized energy system and to keep energy prices affordable to citizens and businesses. It is also a prerequisite for the uptake of renewable energy needed for the decarbonisation of the system. As part of its smart sector integration and gas decarbonisation proposals, the Coalition for Energy Savings calls the Commission to assess the energy efficiency of different conversion and supply chain technologies. This can enable comparisons and benchmarking with the aim of achieving a highly efficient, sustainable and renewable energy system. Furthermore, the Coalition calls the Commission to proposes a revised text of the Trans-European Network for Energy (TEN-E) Regulation to fully integrate and implement the Energy Efficiency First principle into every future infrastructure planning decision.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

The Coalition for Energy Savings welcomes the Renovation Wave as an initiative to scale up current renovation rates of roughly 1% per year. The renovation rate and depth is clearly too low to achieve the EU’s climate and energy targets and to tap the multiple benefits of building renovations. Renovated building stock by 2050 Achieving the objective of a highly energy efficient and decarbonised building stock by 2050 requires a long-term vision and ambition. To say that the “very low energy renovation rates [...] will need to at least double” is a weak formulation. The goal should clearly be fixed at yearly 3% deep or staged deep renovations. A dedicated financing tool The roadmap identifies investment needs of around €325 billion annually. Existing funding schemes can be mobilised for energy renovations: European Investment Bank loans, the European Regional Development and Cohesion Funds and the LIFE programme. Those will be complemented by the Just Transition Mechanism, the InvestEU Sustainable Infrastructure Window and the newly proposed Recovery and Resilience Facility. But in practice it does not happen easily. None of these solutions deal with the specific situation of residential buildings, of small scale, dispersed and difficult to reach. The Coalition for Energy Savings calls for a dedicated renovation fund and strengthened regulatory requirements that create a market that can use a significant part of the EU’s budget for the renovation of buildings. An effective tool to overcome market barriers is Energy Performance Contracting (EPC) which should be strongly promoted by the European Commission and Member States, as it is not yet systematically used. Adequate regulation Access to financing is a prerequisite for energy renovations, yet it is insufficient on its own. The Coalition for Energy Savings suggests a combination of adequate regulation, such as a well transposed Energy Performance of Buildings Directive (EPBD) and a strong implementation of the Energy Efficiency Directive (EED) and the Renewables Directive. Our assessment of the NECPs shows a substantial gap in meeting the 2030 energy efficiency target. Filling this gap will require legislative measures, including a revision of the EED. This would, among others, allow strengthening requirement for the renovation rates of all public buildings and thus to lead by example. Rental market The Renovation Wave initiative should include a new EU policy to support the specific case of energy renovation of rented property. The rental market (including both residential and non-residential buildings) is a large sector and hard to get to. One of the most effective ways to improve energy performance of rented buildings is to put in place minimum standards. This means that buildings below a certain level of performance would not be considered suitable for rental any longer. Those standards have to be announced in advance, gradually phased in or linked to trigger points (e.g. start of a new rental term), accompanied by a comprehensive package of financial and technical support and tailored advice to ensure it is a fair deal for tenants, landlords and public investors. Citizens as central actor In order to create demand in the housing sector, citizens must become the central actor in any public policy effort to ramp up renovations. This requires specific measures to meet the needs of citizens and communities. Several stakeholders have proposed EU financial and technical support schemes to create demand for citizen-led energy renovations. Stakeholder engagement at all levels should be ensured, notably through the creation of open collaborative platforms. Furthermore, the Renovation Wave initiative should facilitate the creation of one-stop shops that can provide a large range of services and are designed to tackle the observed barriers.
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Response to Revision of the Energy Tax Directive

31 Mar 2020

National energy taxes are an instrument that can complement energy efficiency support schemes and regulatory actions. It can make investments in energy efficiency improvements more attractive and steer energy use behaviour in the right direction, as long as energy users are enabled to act. However, pricing signals alone are not an appropriate tool to overcome market barriers, mainly because the price elasticity of energy is very low and most barriers are non-economic barriers. Specific support schemes and regulatory measures remain key in order to create demand for energy efficiency investments and to develop the energy services market. One way to increase the impact of energy taxation on moderating energy demand is for authorities to reinvest the taxation revenues in energy efficiency programmes. This has been shown to produce 7 to 9 times more carbon savings than the impact of the price rise alone The Energy Taxation Directive (ETD) is out of step with the current EU energy and climate ambition. Several Member States are using the weakness of the ETD, namely the low level of minimum taxes, in an accounting practice that undermines the goals of the Energy Efficiency Directive (EED). For the purpose of achieving their annual energy saving obligation under EED Article 7, they are reporting energy taxes even though their effectiveness and eligibility to save energy is not demonstrated. Member States simply calculate the difference between the minimum EU tax level (which is considered to be set too low) and the national tax and credit this difference as “additional” savings (cf: Stefan Scheuer/RAP: Closing the Loopholes, October 2019). The Coalition for Energy Savings welcomes the revision of the ETD. The Energy Taxation Directive should ensure that taxation effectively contributes to delivering energy efficiency. Therefore, the Coalition for Energy Savings calls the Commission to assess the actual impact of energy taxation on energy demand and to consider the outcome of this assessment when developing policy options for the ETD review.
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Response to Climate Law

6 Feb 2020

Consultation answer to the roadmap for a European climate law by The Coalition for Energy Savings The Coalition for Energy Savings fully supports the initiative to ensure an ambitious and just EU climate policy and namely the objective of enshrining climate neutrality by 2050 at the latest in legislation. The Coalition for Energy Savings sees major opportunities in the energy transition, provided it is driven by the “Energy Efficiency First” principle. It will make the energy transition fair, fast and attractive. Energy efficiency measures come with multiple benefits such as reduced energy bills, new local jobs, better health and increased well-being, energy independence while tackling energy poverty and reducing greenhouse gas emissions. The new climate law should not only enshrine the objective of climate neutrality in law, but should also establish the pathway to deliver on the target. The new climate law therefore has to make full use of the Energy Efficiency First principle and build upon the established climate and energy trio target architecture (greenhouse gas emissions reduction, share of renewable energies and energy efficiency targets). By making each target binding, it can strengthen the current policy framework. Realising cost-effective energy savings potentials would lead to halving energy demand by 2050 compared to business as usual (see Fraunhofer ISI, January 2019) and lead to 40% energy efficiency by 2030, well above the 32.5% EU target. The 2020 energy efficiency target is expected to be missed and the pledges of Members States for national contributions to the 2030 target fall short of what is needed. However, not delivering the minimum energy efficiency target is not an option. On the contrary, the 2030 target will need to be revised to get on a path to net-zero emissions by 2050 at the latest and to tap the cost-effective energy efficiency potential of at least 40% by 2030. The Coalition for Energy Savings therefore calls on the Commission to strongly support full implementation and enforcement of existing legislation and, in parallel, to put in place new measures to increase ambition and secure its fulfilment. The building sector plays an important role in tapping the energy savings potential. Therefore, the Coalition for Energy Savings calls the Commission to include in the Climate Law a long-term vision for the buildings sector, applying the Energy Efficiency First principle and re-affirming the objective of a highly energy-efficient and decarbonised building stock by 2050 (building envelope, technical building systems and proper energy management). Realising the energy savings potentials in transport will play an important role to achieve the EU’s energy efficiency target. Therefore, the Coalition for Energy Savings calls the Commission to include in the Climate Law a long-term vision for the transport sector applying the Energy Efficiency First principle. This means taking account of energy efficiency considerations over the whole value chain of fuel and power supplies with the objective of a highly-energy efficient and decarbonised transport system by 2050. For more details, see the attached position paper “The Energy Efficiency Package as an enabler to deliver the European Green Deal”.
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