Energi-, Forsynings- og Klimaudvalget 2015-16
EFK Alm.del Bilag 155
Offentligt
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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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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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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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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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