EU Committee of the Federal Council, 13 September 2011
Committee Communication
concerning
COM (2011) 109 Communication from the Commission to the European Parliament, the Council, the
European Economic and Social Committee and the Committee of the Regions: Energy Efficiency Plan
2011
and
COM (2011) 370 Proposal for a DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL on
energy efficiency and repealing Directives 2004/8/EC and 2006/32/EC
Energy efficiency constitutes an important element of the efforts made to achieve the European
climate control targets. Austria has committed herself to increase energy efficiency by 9% by 2016.
This represents a significant contribution towards reaching the agreed energy and climate control
targets as well as the targets set within the framework of the EU Strategy 2020. Against the
background of increased imports of fossil sources of energy into the European Union at rising prices,
energy generation from renewable sources of energy as well as measures to increase energy
efficiency play an important role in the medium and long term. The proposal submitted by the
European Commission refers to various measures intended to reduce the consumption of primary
energy in the European Union by 2020 by 20% against current forecasts. After an evaluation of these
measures by the Commission, this European target is to be achieved through the establishment of
binding national targets. For the time being, however, it is impossible to foresee if and at what level
such binding national targets will be established from 2014 onward. This implies a high degree of
planning uncertainty for the Member States and their regional or provincial entities. In the
Committee’s opinion, it would therefore be counterproductive to set binding national efficiency
targets for all EU Member States at a uniform level without considering their relative position to each
other, as the initial situation differs greatly from country to country and the targets have to be
adjusted accordingly.
For the citizens, a higher degree of energy efficiency will result in lower energy costs – for both
private individuals and economic operators. The scope of the new directive proposed by the
Commission overlaps with existing directives (Cogeneration Directive 2004/8/EC and Energy Services
Directive 2006/32/EC). Therefore, it is essential to avoid unnecessary duplication.
As a matter of principle, a clear definition of energy efficiency and energy conservation would be
needed. The former can be achieved through improvements in the technological standard of the
equipment in use, while the latter demands a conscious energy saving effort on the part of
consumers. It appears that the two notions are being mixed up in the proposal in the context of
“smart meters”, as these produce a change in consumer behaviour and, thus, result in energy
savings.
Post‐crisis economic growth should by not be jeopardised through Community‐wide and possibly
exaggerated measures. Therefore, any modification of existing provisions will also have to be
assessed on the basis of a macro‐economic cost‐benefit analysis. This applies, for instance, to the
introduction of the aforementioned “smart meters”.
In particular, the obligation imposed upon energy utilities to achieve annual energy savings equal to
1.5% of their energy sales in the previous year through energy efficiency measures appears to be
questionable. Generally speaking, the energy efficiency schemes of the individual Member States
vary greatly. Imposing far‐reaching obligations would interfere with the energy efficiency schemes in