EUU, Alm.del - 2015-16 - Bilag 298: Regeringens høringssvar vedr. EU-kommissionens høring om energieffektivitetsdirektivet

Europaudvalget 2015-16
EUU Alm.del Bilag 298
Offentligt

Denmark´s response to the European Commission´s public consultation

with regard to the review of the energy efficiency directive (EED)

Date

27 January 2016

J nr.

2015-3320

This paper sets out Denmark's provisional stance on the revision of the energy

efficiency directive (EED). The final Danish position will be determined on the basis

of the Commission's impact assessment and the proposal for a revised directive.

This response replaces the approach of filling out the European Commission's

electronic questionnaire.

1. General remarks

The Danish government welcomes the Commission’s consultation on the

Energy Efficiency Directive.

Denmark has as its long term goal to become independent of fossil fuels by

2050, producing sufficient renewable energy to cover the total Danish energy

consumption. Increased energy efficiency is a key element in achieving this

goal.

As a general remark, the Danish Government finds it important to ensure a

cost-effective transition of the European energy system towards a future low

carbon society.

As part of a cost-effective transition, it is important to ensure

fulfilment of the indicative target at the EU level of at least 27 pct. improved

energy efficiency in 2030 (having in mind the possibility of an EU level of 30

pct.) set by the European Council in October 2014. The 27 pct. target sets out

the overall level of ambition for the upcoming revision of the EED and will

require amendments of the current directive.

The Danish Government acknowledges the EED as a strong policy instrument

to ensure broad energy efficiency progress at Member State level as well as

enabling that the EU as a whole reaches the target on energy efficiency.

EU policies and measures are needed as a cost-effective way to tap into the

large potential for increased, profitable energy efficiency. Increased energy

efficiency drives a number of benefits to society, including a reduction of the

EU’s energy dependency, lower energy costs for businesses and consumers,

an increase in productivity, and improved competiveness.

Danish Ministry of Energy,

Utilities and Climate

Stormgade 2-6

DK-1470 Copenhagen K

P: +45 3392 2800

E: [email protected]

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EUU, Alm.del - 2015-16 - Bilag 298: Regeringens høringssvar vedr. EU-kommissionens høring om energieffektivitetsdirektivet

In an upcoming revision, the Danish Government finds it essential that the

EED continuously allows the Member States sufficient flexibility and room

for manoeuvre, in view of their very different national energy systems. By

introducing flexibility, the EED will enable deployment of the most cost-

effective solutions.

A revised directive must be based on a

thorough analysis of the possible

consequences of the upcoming proposal making sure that the most cost -

effective instruments with the highest impacts will be prioritised.

Thus, the

Danish Government looks forward to the Commission’s impact assessment on

the revision of the EED, which includes the articles covered in the public

consultation. The impact assessment should also assess the cost-effectiveness

of other articles, such as article 5 on public buildings and article 8 on energy

audits.

2. Specific remarks

Article 3: Energy efficiency target

In the current EED, the 2020 target is defined as a specified amount of energy.

This definition should be extended for 2030 as this is an essential instrument

for both Member States and the Commission to ensure target fulfilment.

Furthermore, the Member States should be obliged to report their expected

energy consumption for 2030, based on national projections. A continued

effort until 2030 in the EED is essential if the EU is to reach the agreed 2030

target on energy efficiency.

Article 7:

Energy efficiency obligation schemes

Article 7 provides approximately two thirds of the total energy savings in the EED,

and will as such be an important instrument for fulfilment of the 2030 target. The

Danish Government thus supports an extension of the energy savings requirements

of article 7 beyond 2020.

However, the specific level of ambition in article 7 should depend on the

Commission’s impact assessment on the revision of the EED, which can provide

thorough insight with regard to the cost-effectiveness of the energy savings

obligation.

The flexibility mechanisms in the current article 7 should be extended beyond

2020. The flexibility, defined as the Member States’ opportunity to use exemptions

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and alternative measures to reach the annual energy savings, makes the obligation

suitable for today’s diversified energy systems. In that way, Member States will

continuously be able to employ the most cost-effective solutions towards reaching

an annual energy savings target.

Denmark has implemented its article 7 obligations solely through the energy

efficiency obligation scheme for the energy utility companies. This approach has

led to additional and cost efficient energy savings. However, the marginal costs of

energy savings are gradually increasing as the amount of “quick win” (i.e.

comparatively low-cost) energy savings projects is declining.

Article 10-11: Billing information

The Danish Government regards the requirements on metering and billing in the

EED as important in helping consumers make conscious choices about their energy

consumption and thus contributing to energy savings. Nevertheless, it has seemed

difficult to interpret the notion of “economic justification” with regard to the

requirement of frequent billing information. Preliminary Danish assessments seem

to indicate that frequent billing has a positive impact on energy savings, but is at

the same time associated with considerable costs to energy companies and building

owners.

The Danish Government agrees with the need to maintain a cost-effectiveness

criterion in order to account for sectoral differences and differences among Member

States. However, Denmark would welcome more clarity regarding the

implementation of the criterion of “economic justification” where the costs for

providing frequent billing information should be compared to the potential for

energy savings. The Danish Government welcomes the Commission’s work on a

guidance document which will cover this and other issues related to economic

efficiency and technical feasibility conditions in Articles 10-11 of the EED. If it is

possible it should be considered in the context of the revision of the directive to

introduce a clearer framework for determining cost justification in the EED itself.

Article 20: Financing of energy efficiency

The Danish Government welcomes the Commission’s focus on providing financing

for energy efficiency in this consultation as well as in the communication on “The

State of the Energy Union”. The Danish Government acknowledges the fact that the

energy efficiency investment market is still relatively small in scale compared to its

potential and in view of the investments needed to meet the 2030 target. That

remains a substantial challenge along with a lack of expertise and awareness about

good business cases for investments in energy efficiency.

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EUU, Alm.del - 2015-16 - Bilag 298: Regeringens høringssvar vedr. EU-kommissionens høring om energieffektivitetsdirektivet

The Danish Government encourages the Commission to focus more on available

energy efficiency financing funds and in this context to take cost efficient

allocation of funding into consideration. Generally, EU financing could to a larger

extend be directed towards energy efficiency both when it comes to the structural

funds and the European Investment Bank in addition to the specific funds such as

the European Energy Efficiency Fund.

The European Energy Efficiency Fund has high requirements for the applicants,

which mostly enables the bigger actors to participate. The Danish Government

encourages the Commission to provide an easily accessible overview of funds

available for energy efficiency projects as well as better guidance for the Member

States and private actors in order to open up the EU financing for energy efficiency

for a wider range of actors.

Article 24: Review and monitoring of implementation

The Energy Union Strategy foresees an integrated governance framework for EU

energy and climate policies to ensure that agreed climate and energy targets are

reached and to enable Member States to better coordinate their policies at a regional

level.

The Danish Government is of the opinion that the current EED sets a good

framework for governance on energy efficiency progress and policies at the

Member State level. The reporting and notification obligations in the EED enable

the Commission to follow up on all Member States’ actions regarding their

obligations in the different articles of the EED. The Danish Government

emphasises the importance of reporting obligations to remain binding, but is open

minded as to whether this reporting should be included in the governance

framework for the Energy Union or remain as a part of the EED.

Article 5: Exemplary role of public bodies’ buildings

The Danish Government notes that article 5 is not part of the Commission

hearing and fully understands the ambition to limit the scope of the revision in

view of the relative recent agreement on the current directive. Nevertheless,

we would like to signal that the ongoing implementation of article 5 regarding

the exemplary role of public bodies’ buildings poses a number of challenges.

Specifically, there is a need to clarify the scope of the article when applying

the alternative method and a need for clearer guidance on the implementation

methods for target setting and monitoring. Furthermore, clearer guidance is

requested on how to interpret the article regarding the scope of buildings

included, and how to correctly calculate the energy savings. There is a risk

that the aforementioned challenges can lead to suboptimal energy efficiency

investments. In order to remedy these difficulties, the Danish Government

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EUU, Alm.del - 2015-16 - Bilag 298: Regeringens høringssvar vedr. EU-kommissionens høring om energieffektivitetsdirektivet

would encourage the Commission to initiate a process with the aim of

clarifying implementation issues through guidance papers and follow-ups on

progress.

Furthermore, the Danish Government urges the Commission to perform an

impact assessment of article 5 as part of the general impact assessment ahead

of the proposal on a revised EED. The assessment should in particular explore

whether the energy savings requirements in article 5 are delivered in a cost-

effective manner and whether the requirements are sufficiently focused. In

this context it should be borne in mind that there are significant variations

between Member States with regard to energy savings potential in state owned

and occupied buildings and that the share of state owned and occupied

buildings of the total building mass and the nature of these buildings also vary

from one member state to another.

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