Dear Deputy Permanent Representative,
Ahead of the conclusion of the final trilogues of the revision of the Energy Efficiency Directive (EED), CAN Europe is calling on rapidly stepping up energy savings through an ambitious revision of the EED.
In this context, we are very concerned about the Presidency’s non paper on the Energy Efficiency Directive with regards to several issues. A higher number for the energy efficiency target or the energy savings obligation does not automatically bring more ambition, when essential elements that underpin these higher numbers are being substantially weakened and in some parts going even below what Member States agreed upon in the first place.
The record-high winter temperatures across Europe are yet another reminder of the current climate crisis. An increased and EU-binding energy efficiency target of minimum 14.5% for 2030 in both final and primary energy terms will help against the worsening impacts of climate change, lower our dependency on fossil fuels as well as enhance member states’ energy security and shield homes, communities and businesses from skyrocketing energy bills.
Increasing the EU energy efficiency target for 2030 however cannot come at the expense of a weak governance – both are equally important. Raising the target level to 11 or 12% without good governance risks weak results on the ground and a weak delivery of the target. A robust governance including a binding primary energy consumption target for the EU and binding national contributions is of utmost importance. A fixed fair formula and the ambition gap mechanism proposed by the Council should be preserved and extended to primary energy as well, which ensures that all Member States deliver on their commitments.
Similarly, it needs to be ensured that an increased annual energy savings rate of the energy savings obligation truly raises ambition. Counting any climate policy measures as energy savings should not be permitted, as it puts the integrity of the article’s architecture at risk and would reduce the level of end-use energy savings substantially. Adding these provisions to the Council`s position substantially lowers the ambition level compared to the EED General Approach from June 2022.
Finally, a robust exclusion of fossil fuels for the energy savings obligation is pivotal to move the EU away from fossil fuel subsidies. The Council’s General Approach with exceptions for energy intensive enterprises in industry only and under strict conditions should not be weakened with elements of the weaker Parliament’s position.
Thank you very much for your consideration.