“Energy efficiency first approach” is needed in the Energy Strategy for Europe 2011–2020

(02 Jul 10)

eceee welcomes the flagship initiative to promote a “Resource-efficient Europe” outlined in consultation document for en energy strategy for Europe. However, real innovation for a sustainable energy policy must be built on an energy efficiency first foundation. Without this, achieving a future low-carbon energy demand is likely to prove costly with negative effects for poor households and EU competitiveness alike.

eceee’s response submitted to the European Commission points out several shortcomings in the consultation document, and in particular find that it lacks a comprehensive understanding for the role energy efficiency can play, even if the need for reductions in primary energy consumption is underlined.

Among other things, eceee points out that:

• eceee welcomes the statement: “The EU has to realize all the 20 % potential for cuts in primary energy consumption by 2020.” Such verbs give eceee hopes that the Commission will be proposing mandatory targets if the potential “has” to be realized. And it has to.
• On making progress towards a low-carbon energy system, eceee agrees it will require the use of various instruments but it also requires a different mindset. The paper mentions innovation many times but eceee does not see this strategy as being innovative. The emphasis is still too focussed on energy supply (including renewables). 
•  Real innovation would reflect that a sustainable energy policy is built on an energy efficiency first foundation without which meeting future CO2 free energy demand is likely to prove costly with significant impacts for the most vulnerable EU households and severe implications for our international competitiveness. While the strategy implies that, it is not reflected in the programmes or the resources made available. eceee wants Europe to provide leadership in technological innovation but we do not see a well-rounded and balanced approach to innovation. Europe could be a world leader if it tackled energy demand more effectively.
• The document refers to the success of appliance labelling but says nothing about Eco-design. eceee hopes that the Commission will re-affirm its commitment to this important programme and that it will provide adequate resources to ensure effective implementation.
• The document discusses the results from the 2007 Energy Action Plan and we must note that the SET-Plan has no reference to energy efficiency at all. If energy efficiency is to play such a key role, this is not encouraging.
• The same must be said for the Economic Recovery Plan and we can only note that anything there is on energy efficiency is largely due to the efforts of decided Members of the European Parliament.
• In discussing the remaining gaps and shortcomings, eceee agrees that a number of the National Energy Efficiency Action Plans were disappointing but we fail to see in this document how the Commission intends to address that.
• eceee agrees that implementation of energy legislation has largely been poor and eceee particularly worries about the Energy Performance of Buildings Directive. 
• eceee welcomes the emphasis on ICT technologies, particularly smart meters. eceee believes they can have an important impact, but also wants to caution against a belief that this technology will bring about increased energy efficiency without an integrated approach where synergies are created with other energy efficiency measures.
• Concerning transport, eceee would like to see more emphasis on better fleet management, even through ICT, and more emphasis on modal shifts towards less energy-intensive transport systems.
• eceee would like more information on how the Commission will monitor and ensure effective implementation of EU legislation. Implementation also has to be stressed in the issues for consideration in the short-term.
• eceee welcomes that the Commission is committed to work with Member States to ensure maximum compliance but eceee would like the emphasis on maximum impact. 

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