In view of the 2030 Climate Target Plan and the goal of climate neutrality to be reached by 2050, the 2030 energy efficiency target of 32.5% is obsolete. EPEE calls for binding 2030 EU Energy Efficiency target of at least 40% to reach the cost-effective energy efficiency potential and maximise the environmental, social and economic benefits of the energy transition.
Given the importance of decarbonising the H&C sector to achieve the objectives of the EU Green Deal, EPEE believes that a sectoral target should be established, in order to shift from a siloed approach on heating only towards an integrated, system-based and more holistic approach, and increase the political attention devoted to H&C.
More specifically, in relation to the exemplary role of public buildings and as disciplined under Articles 5-7, EPEE calls for more consistency and better alignment between the EED and the EPBD, in light of the Energy System Integration Strategy and the Renovation Wave. Indeed, a revised scope to cover all public buildings should aim at incentivising the uptake of highly efficient H&C solutions in public buildings, while promoting indoor air quality solutions for the health and productivity of occupants. With respect to IEQ standards, EPEE believes that harmonised European standards should be established and promoted in the context of the EPBD revision.
The energy savings obligation is not calibrated to a higher 2030 energy efficiency target and the current annual energy savings requirement for the period up to 2030 should be at least doubled to align with higher 2030 and 2050 climate targets. Further, improvements in fossil fuel technology efficiency should be made ineligible to count towards the target.
The scope of Article 14 of the EED on waste heat should be extended to include the “recovery of non-residential waste heat and cold” and “commercial waste heat and cold” as opposed to the current, more limited “industrial waste heat”. This would allow the EED to promote waste heat in tertiary sector facilities with a great deal of potential in this regard (e.g. data centres and chains of supermarkets).
EPEE furthermore calls for an extension of the scope of the Comprehensive Assessments (CAs), by considering a reduction of the 20 MW thermal input requirement to 5 MW, to also capture single spot facilities and smaller installations (e.g. supermarket chains).
Lastly, EPEE promotes the synergies between the EED and the existing legislation, such as between the Comprehensive Assessments (CAs) under Article 14 of the EED and renewables assessments under Article 15 of the Renewable Energy Directive (RED). In this respect, the methodology to define ‘renewable cooling’ should prioritize decarbonization as ultimate end and the revision of the Primary Energy Factor (PEF) should aim to incentivize technologies that contribute to both energy efficiency and renewable energy targets.
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