Letter_PDEE_Energy_Ministers.pdf (348 KB)
Five key elements that will enable the Directive to raise energy efficiency, to generate growth and to create jobs across the European Union
Brussels, 18-11-2011
Dear Mrs. / Dear Mr.
Five key elements that will enable the Directive to raise energy efficiency, to generate growth and to create jobs across the European Union
On 22 June 2011, the European Commission adopted the Proposal for a Directive on energy efficiency (COM(2011) 370 final). For the moment, the Directive is being discussed at the European Parliament and at the Council of the European Union.
The European Building Automation and Controls Association (eu.bac) supports the Directive which, we believe, will not only lead to raised energy efficiency and a reduction in energy dependency across the European Union (EU), but also, more importantly – not least in the current times – represents a great opportunity for growth and jobs creation in all EU’s corners.
Buildings account today for 40% of the EU’s overall energy consumption and for 36% of the EU’s overall GHG emissions. We know that approximately 70% of the buildings that we will occupy in 2050 are already standing at present. Further, around 20% of the energy consumed by Europe’s buildings is wasted, mainly due to inefficient maintenance, a lack of basic energy efficiency measures and poor energy efficiency behaviour by occupants. This waste represents a cost of approximately €270 billion every year, a figure that is set to increase to 53% by 2030 if no action is taken to curb it.
Therefore, the renovation of both buildings owned by public bodies and buildings owned by private bodies is of great importance in order to ensure a sustainable future.
In this letter, eu.bac would like to raise five key elements that, according to us, will enable the Directive to ensure a sustainable future:
- A longer-term approach towards the renovation of public, non-residential and residential buildings
- A harmonised set of policies to make buildings smart-grid ready
- A clearer definition of Energy Performance Contracting (EPC)
- A cost-effective approach towards the renovation of public buildings
- A stronger recognition of the need to combine audits and energy management schemes
In conclusion, the Directive presents a great opportunity for Member States to achieve a workable and coherent framework of measures, aimed to realise concrete energy savings, to improve energy security and to boost the local economy through green investments and local jobs creation.
We would be delighted to provide you with more information and/or to engage in a discussion with you at local level alongside members active in your Member State.
We remain at your disposal.
Yours sincerely,
Jean-Yves Blanc (President eu.bac / VP Energy Management Services, Buildings Business, Schneider Electric)
Ernst Malcherek (Vice-President eu.bac / VP Strategic Marketing EMEA, Environmental and Combustion Controls, Honeywell)
About eu.bac
eu.bac is the European Building Automation and Controls Association. It represents some 95% of the European manufacturers of products for home and building automation. For a full and updated overview of our membership, please see www.eubac.org
More importantly, eu.bac members’ products and services manage over half of the energy demand in the European Union, reducing waste, reducing demand and increasing efficiency. By providing distributed intelligence, eu.bac members’ products and services ensure that the built environment is ready and able to respond to smart grid signals, demands and supplies.
eu.bac, has developed its own robust certification scheme, eu.bac CERT, which assures that technologies (products and systems) in the area of building automation and controls are in conformity with European Directives and with European Standards. The eu.bac CERT mark is the symbol that represents energy efficiency, quality and reliability.
For more information, please contact:
Frédéric Melchior (Director Governmental Relations)
Diamant Building, Boulevard A. Reyers, 80, 1030 Brussels, Belgium
e-mail: frederic.melchior@eubac.org
Phone: +32 2 706 82 02 / +32 474 91 59 11
Fax: +32 2 706 82 10
Annex
1. A longer-term approach towards the renovation of public, non-residential and residential buildings
It is important to reconcile the Directive’s goal, to raise energy efficiency with the European Union’s long term ambitions, especially in terms of GHG emissions reduction. In order to achieve this objective, eu.bac supports the creation of a Building Roadmap stretching until 2050.
Such a Building Roadmap should:
1. Give clear targets related to the energy consumption to be achieved depending on building type (public, non-residential and residential)
2. Address the existing diversity by setting up “tailor-made” targets and policies depending on building type
3. Provide “tailor-made” solutions in order to fully unlock the available funding and to ensure that the workforce is adequately skilled
4. Identify ways to enable buildings to become intelligent and to interact with their environment
In conclusion, a coherent long term strategy encompassing the four above mentioned objectives is the only real solution in order to ensure a sustainable future.
2. A harmonised set of policies to make buildings smart-grid ready
eu.bac supports the introduction of Demand Response (DR) in the Directive. DR will enable final customers to temporarily reduce their demand in response to supply conditions, for example in the case of electricity. It also allows a dialogue between suppliers and final customers. DR will facilitate the integration of distributed generation and the introduction of distributed intelligence in both new and existing buildings.
eu.bac also strongly urges that the wording of the Directive go beyond smart meters when it comes to cost effective technological innovations. Smart meters are not in themselves smart: they allow the final customer to visualise his/her energy use in real time, but without being able to influence it.
Clearly, such a measure will not drive energy efficiency on its own. What is needed is a clear reference to building automation and controls whenever smart meters are mentioned: they enable buildings to become intelligent and to communicate with their environment. Final customers will then not only observe but be able to act on their energy use.
Further, building automation and controls, in comparison with other technologies, are technologies that are already available on the market, that are cost efficient and that have short pay-back times.
Additionally, the potential reduction with the introduction of building automation and controls in thermal and electrical energy consumption in all sectors is substantial:
- 26% in educational institutions and hospitals
- 27% in residential buildings
- 41% in hotels and restaurants
- 49% in wholesale and retail buildings
- 52% in office and lecture halls
In conclusion, without enabling technologies, such as building automation and controls as well as Demand Response, achieving substantial energy efficiency improvements will only remain a dream.
3. A clearer definition of Energy Performance Contracting (EPC)
eu.bac believes that the energy service provider definition in the Directive should be removed and that the energy service company (ESCO) definition should be reinstated. The ESCO definition is a well-accepted nomenclature in the market and is being used by many different stakeholders, for example those offering services, customers and policy-makers. Further, by reinstating an ESCO definition, consistency within the Directive and with other EU pieces of legislations will be ensured for example Directive 2006/32/EC on energy end-use efficiency and energy services and repealing Council Directive 93/76/EEC and the Impact Assessment accompanying the Directive (SEC(2011) 779 Final, 22/06/2011) as well as its accompanying Annexes (SEC(2011) 780 final). The energy service provider definition, on the other hand, is vague and open to different interpretations.
eu.bac also believes that the Energy Performance Contracting (EPC) definition that is featured in the Directive does not accurately reflect reality. Energy Performance Contracts are marketed and sold on the basis of the guarantee that they offer – a guarantee that encompasses financial as well as kilowatt hours savings. This is not adequately highlighted in the Directive as it stands. We also believe that public authorities should also be called to consider the use of the Energy Performance Contracting (EPC) in order to lower the level of public investments.
In conclusion, without the appropriate tools as well as the appropriate screws, it is very difficult to construct an energy efficient house. Therefore, precise and adequate definitions are needed
4. A cost-effective approach toward the renovation of public buildings
eu.bac strongly supports the yearly 3% renovation rate for buildings owned by public bodies proposed by the Directive. Apart from the fact that it is important that public bodies set the good example, there are also significant savings in terms of kilowatt hours and money waiting to be realised. This would free up public resources for other uses. Therefore, we also strongly believe that the ‘loft’ of 250 m2 should be removed to allow the full potential to be realised.
Further, ESCOs carrying out EPC, such as the eu.ESCO member companies, can support public bodies in the renovation of their buildings at no additional costs. eu.ESCO member companies typically work closely together which local Small and Medium Enterprises (SMEs) in order to bring the guaranteed energy savings into life. Thus, the positive financial impact of the renovations extends beyond the buildings and the public bodies themselves into the local economy.
In conclusion, public bodies need to set the good example and ESCOs carrying out EPC, will enable them to do that at no additional costs. Further, ESCOs are “SME friendly”.
5. A stronger recognition of the need to combine audits and energy management schemes
eu.bac is of the opinion that the most important aspect is not to undergo an energy audit in itself but rather, what is realised with the identified measures that it will bring forward. In other words, the implementation of the identified measures is "the" key issue in this case.
In order to promote and to guarantee flexibility as well as to drive the implementation of energy management systems, large enterprises should not be subject to mandatory energy audits if they chose to introduce an energy management standard such as the ISO 50001 (International standard) or the EN 16001 (European standard) .
In conclusion, flexibility is key for large enterprises and by providing them with tools in order to raise their energy efficiency, such as an energy management standard, will ensure that they are on-board.
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