EUU, Alm.del - 2020-21 - Bilag 434: Regeringens positionspapir vedr. revision af direktivet om energieffektivitet

Europaudvalget 2020-21
EUU Alm.del Bilag 434
Offentligt

Danish Government’s position on a revised EU Energy Efficiency Directive

Date

8 April 2021

Key Danish priorities for the revision of the Energy Efficiency Directive:



Overall support for the

Commission’s approach

regarding energy efficiency that must

contribute cost-efficiently to achieve the EU emissions reduction target of at least 55

percent by 2030 and the objective of achieving climate neutrality by 2050.

Encourages the Commission to raise the present energy efficiency target at EU level to

40 percent of EU’s final energy consumption by 2030

(article 3), while maintaining the

current level and scope of the Energy Efficiency Obligation (article 7).

Encourages the Commission to maintain the possibility to use the alternative reporting

method

related to the public bodies’ energy efficiency obligation

and to focus on de-

veloping a framework that provides a more consistent and equal savings obligation

across member states (article 5).

Encourages the Commission to modernize the policy framework for energy efficiency,

taking into account the national circumstances of the various member states in order

to incentivize least-cost paths for emission reductions.

Encourages the Commission to strengthen existing and introduce new measures at

EU-level to strengthen energy efficiency policies, e.g. sector specific regulation for

data centres, expanding the scope for regulation of energy consuming products

(Ecodesign) as well as extending the EU Emissions Trading System (ETS) to heating

in buildings. Regarding the building sector, focus should be on increased use of data

and digitalization, as well as smarter utilization of building spaces and elimination of

fossil fuels for heating and cooling of individual units.

Encourages the Commission to ensure comprehensive alignment with the

“Fit for 55

package”,

especially regarding the ETS and sectoral legislation in the Energy Perfor-

mance of Buildings Directive and sustainable product policies (Ecodesign and label-

ling). The Commission is also encouraged to come forward with guidance on the prin-

ciple of »energy efficiency first« to encompass costs and the wider benefits of energy

efficiency measures.



General comments

Despite the recent revision of the Energy Efficiency Directive (EED), the Danish

Government finds it timely to consider revising the directive again as part of the Eu-

ropean Commission’s “Fit for 55 package”

in order to achieve at least 55 percent

emission reductions by 2030 and a climate-neutral Europe by 2050 at the latest.

The Commission should ensure full alignment between the revised EED and other

relevant legislation highlighted

in the Commission’s 2021 Work Programme.

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EUU, Alm.del - 2020-21 - Bilag 434: Regeringens positionspapir vedr. revision af direktivet om energieffektivitet

Putting energy efficiency first must be a key objective in the package, as energy

savings can both save money for consumers and reduce greenhouse gas emis-

sions in the EU as a whole. In addition, energy efficiency reduces investment needs

in energy generation and infrastructure, and brings multiple benefits

for EU’s citi-

zens such as cleaner air, reduced pollution and better indoor climate. Energy effi-

ciency also provides huge employment opportunities in green sectors and indus-

tries, which is a high priority for a green recovery and the Next-Generation EU

package. The revised EED should take these wider benefits into account, as well

as the broader objectives of the European Green Deal to transform the EU to an

even more sustainable and prosperous society.

The 2030 Impact Assessment for Climate Target Plan and the Renovation Wave

initiative rightly points out there is a particular challenge related to the poor energy

performance of the EU building stock. The revised EED and the upcoming revision

of the Energy Performance of Buildings Directive (EPBD) should support enhanced

and expanded measures to deliver higher savings in a cost-effective manner, while

taking into account the different starting points, specific national circumstances and

emission reduction potential, as well as efforts already attained by member states.

In accordance with the above, the Danish government fully supports the Commis-

sion’s

overall approach regarding energy efficiency with the following detailed re-

marks for the revision of the EED.

Article 3: EU energy efficiency target

The Danish government encourages the Commission to raise the present energy

efficiency target at EU level to 40 percent

of EU’s final energy consumption by

2030

in order to encourage higher policy ambition throughout EU and the member states.

The conditions for the EU’s energy efficiency target

must remain unaltered.

The Danish government also encourages the Commission to strengthen existing

and introduce new measures at EU-level in order to reach a more ambitious EE-tar-

get, including the following.

A strengthened EU Emissions Trading System - include the building sector

It is clear that CO

reductions also need to come from the building sector where

there is still a large untapped potential across sectors and member states. The

Commission is therefore encouraged to strengthen and extend the use of the EU

Emission Trading System (ETS) to include emissions from buildings. Extending the

scope of the ETS will support a cost-efficient approach by setting a price on carbon

emissions that will incentivize investments in renovation of both public and private

buildings in combination with strong sectoral legislation. The Commission should

ensure full alignment between the revision of the EED, the EPBD and the ETS.

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EUU, Alm.del - 2020-21 - Bilag 434: Regeringens positionspapir vedr. revision af direktivet om energieffektivitet

Common EU regulation of data centers

Data centers will in the near future be a source for growing electricity consump-

tion, which poses a challenge for the objective of an overall reduction of the Euro-

pean energy consumption by 2030. The Danish government supports the com-

mitment laid out in the EU Digital Strategy to make data centers climate-neutral

by 2030 and encourages the Commission through sector policies in the EED,

EPBD or other legislation to take actions to put comprehensive regulation in place

as soon as possible. Guided by the principle of energy efficiency first, this should

address efficient use of electricity, incentives promoting the utilization of waste

heat, etc. which can support a cost-efficient path towards climate neutrality in

2050.

Phasing out fossil fuels in individual heating and cooling

It is necessary to consider all available options to phase out the fossil fuels for in-

dividual heating and cooling of buildings through for example strong restrictions

or a ban on the use of fossil fuels. The Commission is encouraged to work with

the member states to find solutions and available options, which at a national

level shall leave the members states the opportunity to phase out fossil fuels in

individual heating in compliance with EU regulation

A strengthened and widened scope of product regulation

EU’s comprehensive regulation of energy-related

products has delivered substan-

tial savings towards the energy efficiency targets. The Commission is encouraged

to strengthen product regulation, specifically the Ecodesign and Energy Labelling

as cost-efficient measures to achieve additional energy savings. The Commission

should ensure full alignment with the Sustainable Product Initiative (part of the Cir-

cular Economy Strategy), including the revision of the Ecodesign Directive. The

Commission must ensure to allocate sufficient resources to manage the tasks laid

out in the ongoing Work Plan for the Ecodesign Directive and to avoid further de-

lays and make sure it delivers on its current objectives, in parallel with the work on

the Sustainable Product Initiative.

Article 5:

Exemplary role of public bodies’ buildings

Regarding the current provisions on energy efficiency in public bodies, the Danish

government proposes that the current scope of the application regarding govern-

mental buildings is supplemented by a voluntary energy savings target for govern-

ment buildings at the national level not currently under the scope of the article, with

due regard to the competences of the member states.

Regarding the administration of the article, there are substantial differences in the

level of energy saving targets notified by various member states, in part due to ab-

sence of a clear definition of

“central

government”. The Commission is encouraged

to look into the definition and clarify the scope of the application.

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EUU, Alm.del - 2020-21 - Bilag 434: Regeringens positionspapir vedr. revision af direktivet om energieffektivitet

Further, the Danish Government finds that a potential proposal on increasing the

rate of renovation would not be appropriate under the current provisions, as the

current energy saving scheme has diverse effects on the different member states.

Instead, focus should be on developing a framework that provides a more con-

sistent and equal saving obligations across member states.

It is important to maintain the discretion for member states to choose the alternative

reporting method, as it gives way for a broader selection of policy instruments for

the realization of energy savings, e.g. behavioral changes, intensified use of build-

ings, data and digitization etc. It is therefore more flexible and cost-efficient than the

standard approach. The Commission is encouraged to consider defining and clari-

fying the conditions for the application of both approaches, including the calculation

method.

Article 6: Purchasing by public bodies

The Danish government

supports the Commission’s intentions to continue an ambi-

tious approach at EU-level to public procurement and to review Article 6 in this re-

gard. The Commission is encouraged to consider revising the scope, as the current

provisions for

green

and

energy efficient

purchases by public bodies only applies to

large budget purchases. However, it is important that a revised threshold for budget

purchases applicable to the provisions of the article are consistent with cost-effec-

tiveness, economical feasibility, wider sustainability, technical suitability, as well as

sufficient competition.

Article 7: Energy efficiency obligation schemes

The Danish Government is committed to fulfil the current energy efficiency for the

period 2021-2030 and finds that the current level of obligation should be maintained

Member states should be committed to adhere to European-level measures and fo-

cusing on economic or other measures, which could lead to more frequent, actual

implementation of cost-efficient energy savings. A clarification of the current provi-

sions and methods for the calculation and determining of energy savings could be

considered during a future revision.

Article 8: Energy audits and energy management systems

The Commission is encouraged to alter the criteria for energy audits from turnover,

balance sheet total or number of employees to primarily the energy consumption.

Moreover, the main rule should be that the audit focusses on the parent company

rather than subsidiaries. The current frequency of audits every fourth year is ade-

quate.

Article 14: Promotion of efficiency in heating and cooling

It is the preliminary assessment of the Danish government that the current compre-

hensive assessment (CA) does not properly take into account local differences and

a more country-specific approach would be useful. The Commission is encouraged

to propose an exemption from the requirement to prepare a CA if member states

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EUU, Alm.del - 2020-21 - Bilag 434: Regeringens positionspapir vedr. revision af direktivet om energieffektivitet

already have national schemes, which promotes efficiency in the heating and cool-

ing sector more extensively than the requirement in the article.

Furthermore, the Commission is encouraged to broaden the interpretation of the

definitions of effective district heating and district cooling, as it does not currently

not reflect energy efficiency in a comprehensive way.

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