15.1.2008   

EN

Official Journal of the European Union

C 10/22

1.1

The European Economic and Social Committee welcomes and supports the measures proposed by the Commission. Energy efficiency is the primary, most important area for action if the goals set out in the Energy Policy for Europe (EPE) are to be achieved, reducing greenhouse gas emissions, which will also combat global warming, reducing dependence on countries outside the EU and safeguarding the competitiveness of the European system, while maintaining affordable energy supply.

1.2

In the light, inter alia, of the recent IPCC (Intergovernmental Panel on Climate Change) report, the EESC considers this target to be realistic, although it does feel that all possible endeavours should be made to reduce energy consumption and make technically achievable savings of more than 20 %. The target must go hand in hand with national action plans, reflecting the different basic financial and technological conditions, so as to ensure fair distribution of targets between Member States commensurate with each Member State's potential. Intermediate goals will need to be set, to be achieved by 2012 and 2016 for instance, so that measures can be stepped up if progress proves too slow.

1.3

The EESC suggests to the Commission that a specific debate be opened on lifestyles and ‘quality of life’. The EESC asks the Commission whether it believes that it really will be possible to preserve the same lifestyle for future generations, with both consumption and emissions increasing. Assuming that this is not possible, the challenge can only be met with resolute, bold, timely action. The problem is also taking on board the need to stave off the rebound effect whereby energy savings, which bring about an immediate increase in the public's purchasing power, are used to finance further consumption.

1.4

The EESC suggests that a further priority action should be added, to introduce district heating and cooling networks, which would avoid 33 % of primary energy being lost in the transformation stage.

1.5

The EESC recommends that priority initiatives be undertaken, such as the creation and development of new types of jobs related to the energy efficiency sector, dissemination of new, integrated energy services, harnessing of R&D, development of solid urban-waste recycling and disposal, which have many possible applications, and promotion of CSR initiatives. It is of primary importance that incentives be provided for energetics to be studied in higher and further education.

1.6

More Commission staff will be required to implement the 75 measures laid down in the Action Plan, monitoring and assessing the effectiveness of the raft of instruments proposed. They will have to monitor the development of these activities. The EESC recommends that a thorough analysis of needs be carried out and that sufficient human and financial resources be assigned.

1.7

The EESC believes that the EU's ability to present a united front on energy efficiency in international relations needs to be strengthened. To this end, it recommends that the Commission assess whether the Treaties need to be amended to allow stronger joint external representation, while still leaving Member States free to decide on the energy mix best suited to their requirements.

1.8

As regards tax policies supporting investment to achieve the objectives of the Action Plan, the EESC recommends that these policies take into account the most vulnerable social groups, the unemployed, pensioners and workers. Any ‘energy taxes’ or tax incentives must protect these groups.

1.9

The EESC condemns the failure to coordinate transport and energy policies adequately; together with environment and industrial policies, these address technical and industrial needs and concerns which are of necessity complementary. It is justifiably concerned that, thanks to this lack of coordination, the Commission document will be not nearly as effective as it could have been.

1.10

Residential buildings are the main priority area. The potential for savings is very high provided that a number of key points are clearly addressed, such as the need for a sharp cut in tax burdens arising from measures to improve energy efficiency, removal of red tape (licences, permits), and public funding for skills development and better training for operators. Residential buildings awarded an energy-savings certificate should benefit from tax relief or, where the owner has no taxable income, an energy bonus to be used for electricity supply. Preferential charges should be provided when annual consumption is below a certain level. The construction industry and all who work in it need training on what can be done to achieve much higher energy efficiency levels in building and new incentives to deliver these.

1.11

The ESSC believes that financing of the necessary investments should be split between the public and private sectors. In the light of the success of a number of schemes already in place in some Member States, special funds could be introduced more widely, using a small part of the profits made by the businesses operating in the sector, whilst avoiding this leading to price increases for end consumers or a fall in the huge investment necessary in the area of production.

1.12

The EESC feels that it is essential to involve civil society and employers', trade-union and environmental organisations in this major challenge. Only if there is a change in collective behaviour at grass-roots level, with a widespread increase in knowledge and awareness, will it be possible to achieve perceptible results, given that the end users are actually the primary consumers of energy. Energy use in residential buildings, private transport and work activities depends directly on individuals. Education in ‘responsible energy use’ is essential, from kindergarten onwards. The whole of society must commit to this endeavour, which is and must become a universal symbol of new civilisation. Every European must feel that they are doing their bit in this savings race, so that future generations, too, can enjoy natural heritage which is now under severe threat from pollution and related climate change.

1.13

The EESC stresses the successes achieved by the household appliances industry with labelling. Savings of up to 70 % in respect of fridges and 60 % in respect of washing machines show how effective this method is. The EESC calls for the practice of eco-design to be extended to the public buildings, residential housing and public and private transport sectors too, i.e. those sectors with very high energy use (over 70 % of total energy use).

1.14

Losses in the generation, transmission and distribution phases warrant great attention. Over a third of energy — 480 Mtoe — is lost. With high-voltage continuous-current transmission, losses are reduced from over 10 % to 3 % of power every 1 000 km. Moreover, continuous-current transmission also has advantages in terms of people's exposure to electric and magnetic fields and eliminates the ELF electromagnetic wave emissions associated with alternating-current transmission.

1.15

Given the excellent results being achieved in the area of solar thermal power, the EESC alls on the Commission and the Council to encourage and support the dissemination of this technology.

1.16

The EESC endorses the Commission's goal of increasing development of CHP plant, although it feels that the adoption of standard regulations for measuring the efficiency of these plant needs to be speeded up. The EESC believes it would be useful to invest in programmes disseminating trigeneration, which could be fuelled by biomass. Microgeneration units (Directive 2004/8/EC — units with an installed capacity below 50 kW) should be encouraged: they should be included in programmes providing incentives for saving energy and reducing impact on the environment, and integrated more easily into national grids as part of distributed generation development. However, support should be provided for businesses to cover the additional costs of changing current transmission grids entailed by the system.

1.17

The gas and electricity markets have not been fully liberalised. Businesses which manage technical monopolies must be separated legally from those operating in a system of free competition.

1.18

The EESC feels that the introduction of electronic meters could be beneficial, providing a system of remote energy distribution management and optimising management of grid load. These meters are recognised as suitable instruments which comply with the energy efficiency requirements laid down by European directives.

1.19

The transport sector has striven hard to reduce energy use and pollutant emissions. However, the constant rise in CO2 emissions from wider use of private transport in particular, but also from all other forms of transport, calls for a further effort (CO2 emissions from road transport rose by 26 % between 1990 and 2004). The Commission is carefully studying the impact assessment as regards adopting legislation on procedures for achieving the 120 g CO2 target. The EESC recommends that all measures necessary to achieve the target be adopted, while ensuring, in particular, however, that they are sensible and feasible in both technical and production terms.

1.20

The EESC points out that large-scale substitution of fossil fuels for biofuels would entail the risk of placing fuel production in competition with food production as regards allocation of fertile land for different uses. The price of food could then rise to meet the price of energy production, in turn aligned with the price of fossil fuels, effectively placing motorists from the north in competition (1) with the starving poor in the south.

1.21

The EESC fully supports the incentives and financing and tax strategies proposed by the Commission, in particular involving the EIB and the EBRD. It also supports moves to raise the European banking sector's awareness of the need to provide financial support for the implementation of national energy plans. The EESC calls for a dedicated conference to be held on financing energy efficiency, to raise awareness among stakeholders and encourage the European banking sector to participate in a major project to modernise the European economy.

1.22

The EESC supports the creation of the ‘Covenant of Mayors’ but feels that the goal of bringing together Europe's 20 most important cities is not ambitious enough. The target should be much higher and local expertise more effectively harnessed. One excellent way of connecting local administrators who are responsible for urban transport policy with those responsible for neighbourhood activities which have a direct impact on the public, would be to set up a portal or other means of communication for the exchange of expertise between the EU's towns and cities, where over 80 % of the EU's population live.

1.23

The EESC regrets that the Action Plan overlooks the major role that the social partners and social dialogue have to play at all levels in assessing, promoting and developing energy-savings policies. The EESC calls on the Commission to take steps to encourage the incorporation of environmental sustainability issues into the various levels of existing social dialogue structures, particularly in sectoral dialogue and in European Works Councils. Trade union organisations have a key role to play in improving knowledge and awareness at both European and national levels, helping to disseminate best practices.

1.24

It is important that the issue of energy savings goes hand in hand with good corporate social responsibility practices, particularly in multinationals; more intensive social dialogue is needed to address all energy efficiency-related issues.

1.25

The international dimension of the issue of increasing energy intensity is firmly stressed by the Commission. The EESC endorses the partnership proposals and the drawing-up of an International Framework Agreement. As regards the planned international conference on energy efficiency, the EESC warns against underestimating the need to involve countries from the ACP, Euromed and ENP programmes. International cooperation is essential if we are to successfully achieve sustainable development, and greater diplomatic endeavours must be made to achieve a new, post-Kyoto, international protocol by 2009 with the conference which is to open this year in Bali.

2.1

The Commission issued the Communication entitled Action Plan for Energy Efficiency: Realising the Potential on instructions from the Spring 2006 European Council, which endorsed the recommendations made in the Green Paper on A European Strategy for Sustainable, Competitive and Secure Energy.

2.2

The aim of the proposals summarised in the Communication is to achieve energy savings of over 20 % by 2020 in respect of expected use, assuming a given GDP growth rate and with no further interventions. If implemented, the plan would bring energy savings of up to 390 Mtoe per year and CO2 emissions would be reduced by 780 Mt per year. The proposed measures should ensure a drop in total use of 1 % per year, assuming a GDP growth rate of 2,3 %, which, on the other hand, if there are no new interventions, would entail an increase in use of 0,5 % per year. The investment expenditure should be offset by the annual fuel savings of approximately EUR 100 billion.

2.3

The debate triggered by the Green Paper on Energy Efficiency or Doing More with Less led to proposals for a complex, coherent raft of 75 measures spanning all areas of energy-saving potential. The sectors for priority action are the building sector and the transport sector, which consumes the bulk of oil products, although just as much attention should be given to the savings which can be made in energy production, transmission and transformation and in industry.

2.4

The Commission's plan lays down immediate-term actions and other, longer-term actions to be taken over a span of six years. A further action plan will be necessary to achieve the goal of savings of 20 % by 2020.

2.5

Looking at savings potential, beneficial savings are possible in end-use sectors, including 25 % in the manufacturing industry, where peripheral equipment such as motors, fans and lighting offer the greatest savings potential; 26 % for transport, reinforcing co-modality and a shift to other modes of transport identified in the White Paper on Transport; and 27 % in the residential sector, thanks to wall and roof insulation, improved lighting and more efficient household appliances; while for commercial buildings an overall improvement in energy management systems could bring savings of up to 30 %.

2.6

Improvements in energy intensity of 1,8 % or 470 Mtoe per year are expected due to structural changes, the effects of previous policies and the introduction of new technologies. This means that the overall reduction in energy intensity, including the 20 % expected from the new measures proposed (1,5 %, i.e. 390 Mtoe, per year for the period 2005-2020) should be 3,3 % per year. Offset against an estimated GDP growth rate of 2,3 % per year, the total energy savings would therefore be 1 % per year.

2.7

The Action Plan will provide benefits in terms of environmental protection, reduced imports of fossil fuel meaning less dependence on third countries, and a more profitable, competitive EU industry thanks, not least, to technological innovation boosted by the processes set in motion, with positive employment effects.

2.8

The plan is structured around 10 urgent, priority actions, and the Commission calls upon Member States, local and regional authorities and all stakeholders to implement further measures to achieve an even better result. Both sectoral and horizontal measures are laid down.

2.9

Measures focus on the need to set dynamic energy performance requirements; to improve the efficiency of new and existing generating capacity and reduce transmission and distribution losses in the energy transformation sector; and to adopt a holistic approach for the transport sector.

2.10

The Strategic Energy Technology Plan, due to be adopted in 2007, will spur further efficiency gains.

2.11

Price signals warrant a great deal of attention, as they help to increase awareness. Moreover, it is essential for proper financing tools to be put in place at all levels, together with tax and other incentive policies for producers and consumers.

2.12

Energy efficiency issues need to be addressed at global level and so international agreements and partnerships are essential.

2.13

Rigorous implementation of existing directives and regulations such as the recent Directive on Energy End-Use Efficiency and Energy Services, the Labelling Directive and its eight implementing Directives, the Energy Performance of Buildings Directive, the Eco-Design Directive and the Energy Star Regulation will help to achieve the expected goals.

2.14.1

Appliance and equipment labelling and minimum energy performance standards. Updating of Framework Directive 92/75/EC to include new, dynamic standards for appliances. Special attention will be devoted to standby loss. Fourteen priority product groups will be targeted initially. The aim is to ensure that by 2010 the majority of products which consume a significant part of total energy consumption are covered by the minimum standards laid down by the Eco-Design Directive or performance rating/labelling.

2.14.2

Building performance requirements and very low energy buildings (‘passive houses’). Extending the scope of the Energy Performance of Buildings Directive (currently applicable to areas over 1000 m2) and proposal in 2009 of a new directive laying down EU minimum performance requirements for new and renovated buildings (kWh/m2). Targeted strategies will be developed with the building sector for very low energy buildings.

2.14.3

Making power generation and distribution more efficient. The energy transformation sector uses around one-third of all primary energy, with transformation efficiency of about 40 %. New generation capacity should make it possible to achieve 60 %. Losses in the transmission and distribution of electricity — often as high as 10 % — can also be substantially reduced. Minimum performance requirements will be set for new electricity, heating and cooling capacity lower than 20 MW. The implementation of the Directive on the Promotion of Cogeneration (CHP) (2004/8/EC) is expected to bring further progress. Lastly, minimum performance requirements and regulations for district heating will be introduced.

2.14.4

Achieving fuel efficiency of cars. To reduce CO2 emissions, in 2007 the Commission will, if necessary, propose legislation to ensure that the 120 g CO2/km target is achieved by 2012. The option of using tax instruments in connection with CO2 emissions is being evaluated. The tyre sector can also make a contribution to energy efficiency (of up to 5 %) with rolling resistance standards and correct tyre pressure. The Commission is going to issue a Green Paper on urban transport to encourage the use of public transport, and introduce other, tougher measures to address the matter, particularly in congested areas.

2.14.5

Facilitating appropriate financing of energy efficiency investments for small and medium enterprises and Energy Service Companies. The Commission will call on the banking sector to offer finance packages aimed at energy savings. Community financing such as Green Investment Funds and the Competitiveness and Innovation Framework Programme will have to support SMEs in particular.

2.14.6

Spurring energy efficiency in the new Member States. The Commission will call for more cohesion policy funds to be deployed to implement major energy efficiency projects.

2.14.7

A coherent use of taxation. The forthcoming Green Paper on indirect taxation and related review of the Energy Tax Directive will provide for the integration of energy efficiency considerations and environmental aspects. The benefits of using tax credits as incentives for both enterprises and consumers of appliances and equipment will be assessed.

2.14.8

Raising energy efficiency awareness. The development of skills, training and information for energy managers in industry and utilities will be fostered. Schools will be provided with teaching materials.

2.14.9

Energy efficiency in built-up areas. A ‘Covenant of Mayors’ will be created by the Commission in 2007, bringing together the mayors of 20 of Europe's largest and most pioneering cities to exchange best practices.

2.14.10

Foster energy efficiency worldwide. The aim is to conclude a framework agreement with key trading partner countries and international organisations, on improving energy efficiency in end-use sectors and in energy transformation.

3.1

The Commission's Action Plan takes a comprehensive approach to the framework of initiatives necessary to achieve the ambitious target, set in the proposal, of achieving energy savings of 20 % and thus reducing CO2 emissions by 780 Mt per year by 2020. In the light, inter alia, of the recent IPCC (Intergovernmental Panel on Climate Change) report, the EESC considers this target to be realistic, although it does feel that all possible endeavours should be made to reduce energy consumption and make technically achievable savings of more than 20 %. The target must go hand in hand with national action plans, which, together, should make it possible to achieve the desired result, reflecting the different basic financial and technological conditions so as to ensure a fair distribution of targets between Member States commensurate with their potential.

3.2

Intermediate goals will need to be set, to be achieved by 2012 and 2016, so that measures can be stepped up if progress proves too slow. The 2009 review seems too soon to be able to make a considered judgment. The EESC also recommends that a long-term target option (2040/2050) be provided to ensure ongoing pursuit of energy-saving goals. Within a few years investments in fossil fuel-based energy production, amounting to billions of euro, will be obsolete. This capacity needs to be replaced as quickly and efficiently as possible. It will be a historic challenge, going against the current trends of 120-storey glass skyscrapers lit up day and night and the use of land for transport infrastructure. The authorities must take on board without delay the huge-scale problem of how to replace energy sources.

3.3

The Commission's plan should both reduce energy consumption and preserve the same quality of life. On the basis of this objective, it is planned to reduce energy intensity by 3,3 % by 2020, i.e., taking into account constant GDP growth of 2,3 %, achieving a real reduction in energy use of 1 % per year, which is equivalent to a total drop in use of 14 % between 2005 and 2020. The EESC suggests to the Commission that a specific debate be opened on lifestyles and ‘quality of life’. There are expectations of improved quality of life, which many gauge by the number of household appliances, mobile phones or cars per person, while others measure it in terms of CO2 emissions, particulate matter and fine dust, traffic jams and travel time and the quality of public services. Clearly, purely as regards energy efficiency and savings, a very modest change, in the most environmentally-friendly sense of the term ‘lifestyles’, will speed up achievement of the goals. The EESC asks the Commission whether it believes that it really will be possible to preserve the same lifestyle for future generations, with both consumption and emissions increasing. The problem is taking on board the need to stop the rebound effect resulting in energy savings being used to finance further consumption. Reorganisation of the economic system therefore needs to be planned in good time, encouraging the creation of appropriate infrastructure and proposing to new generations an appropriate set of principles such as (2):

3.3.1

Responsibility for energy efficiency needs to be disseminated at all levels, and regional and local action plans set up alongside national plans. Regional authorities must be involved in this major challenge. The scale and importance of the Action Plan are indeed a real challenge. Some aspects of the lifestyle associated with progress in the twentieth century will have to be discarded, and the very concept of good taste will have to include an ethical element of acceptability with regard to energy efficiency, as is already the case for rare animal skins and ivory products; thus, a skyscraper with glass sides or an SUV will have to be seen as unacceptable. This far-reaching change in the prevalent value system calls for cooperation from the private sector too, which should anticipate the necessary shift to promoting energy efficiency so as to have the edge on international markets, using these new principles in advertising as well rather than sending out conflicting messages that extol weight and unnecessary power as status symbols, as happens all too often.

3.4

The Action Plan identifies ten priority actions, in four priority areas: energy conversion, transmission and distribution; buildings for residential, commercial and professional use; transport; and industrial and agricultural uses. These areas account for over 90 % of energy use. Other measures will be taken in the field of international agreements, to form partnerships on drawing up standards; and in the field of information, training and communication, regarding the need to develop synergies and ownership among all stakeholders to the greatest possible degree.

3.5

The EESC suggests that a further priority action should be added, to introduce measures to reduce fossil fuels for heating and cooling, and notes that the proposal does not analyse the possibility of introducing district heating and cooling networks, which would avoid 33 % of primary energy being lost in the transformation stage. This potential could be as much as doubled if associated with the use of renewable energies or waste disposal, leading to savings of up to 50,7 Mtoe per year. The EESC suggests that, alongside the priority actions, new, tangible priority initiatives should be undertaken, facilitating creation and development of new types of jobs related to the energy efficiency sector, dissemination of new, integrated energy services, promotion of new, energy-saving products which cause less pollution, fostering of R&D at both national and European levels, with a substantial increase in the budgets allocated, and harnessing of all technological resources already available. Further areas for action could be development of solid urban-waste recycling and disposal, which have many possible applications, and promotion of CSR initiatives and voluntary agreements in businesses, actively involving workers and using EMAS procedures.

3.6

The Commission proposal announces many legislative measures, such as new directives and regulations, and the revision of existing instruments, to make standards more stringent (announcement of 7 February 2007 on the CO2 emissions ceiling in the automotive industry). The EESC notes the Commission's proposals and the decisions of the Spring Council last March, but points out that, following the waves of enlargement in May 2004 and January 2007, a huge number of used vehicles have been brought into the countries concerned. The influx is ongoing and has even intensified. The EESC feels that it will be many years before full turnover of the vehicle fleet is achieved in these Member States, and that it is inconceivable that this should be brought about by a binding standard relating to the existing fleet.

3.7

The document does not consider the need to strengthen Community responsibilities and powers in order to ensure that the targets are achieved and to present a unified front to international partners. The EESC endorses the provisions of the European Council's document and the adoption of the EPE (Energy Policy for Europe), which sees energy policy as one of the priorities for the EU's future and strengthens EU foreign policy and cooperation. The legal constraints of the Treaties in force, which reserve decision-making on energy policy for Member States, are to some extent offset by genuine strengthening powers of representation in respect of third countries, although Article 174(4) provides for shared competence and a specific role in cooperation with international organisations. Clearly, the better the coordination of policies, the greater the EU's negotiating capacity. The EESC calls for the European Parliament, the Council and the Commission to consider, where necessary, the possibility of amending the Treaties to give the Community more powers in respect of external partners, providing unified representation.

3.8

The Energy End-Use Efficiency and Energy Services Directive (2006/32/EC) mentions a strategy based on wider application of white certificates, and national action plans which will have to be evaluated by the Commission. The Action Plan itself will involve a considerable increase in workload for the Commission, in terms of both legislative and regulatory initiatives and monitoring. The EESC believes that the experience has been encouraging thus far, although there have been a number of hitches in getting the white certificates market off the ground, due, inter alia, to disparities between Member States' regulations. For activities related to the achievement of the directive's goals and, more generally, to enable the Commission to work on the issue effectively, more Commission staff need to be assigned to these tasks. The Commission estimates a need for 20 staff. The EESC recommends making a thorough estimate of the resources needed and hopes that they will be provided.

3.9

The implementation of the proposed measures will bring savings leading to a drop in VAT revenue which could affect the Community budget, partly offset by the rise in new activities related to energy efficiency policy. The EESC calls on the Commission to analyse this scenario as it is not taken into account in the Impact Assessment Report. The EESC believes that the EU's current resources are wholly insufficient to cover all the Community programmes, which are constantly subject to cuts in funding for extremely beneficial projects, including those aimed at saving energy. If an ‘energy tax’ is introduced, it must be part of a taxation policy which takes into account vulnerable social groups and has no negative impact on current levels of social security and public services.

3.10

The Action Plan is affected by difficulties in achieving the goals set in the White Paper on transport. In its Mid-term review, the Commission notes that the obstacles and resistance encountered thus far have hampered the reinforcement of rail and sea transport, which would bring considerable energy savings. This reinforcement must be treated as an absolute priority, considering the time needed both to build infrastructure and to change people's habits. There needs to be more focus on improving transport for workers, who are currently heavily penalised by a policy geared more to the need for immediate financial gain than to meeting public transport needs, e.g. prioritising investment in high-speed links. Facilitating people's journeys to work will not only reduce energy use but considerably improve their quality of life as well. The public investment necessary to reinforce public transport systems inevitably came up, inter alia, against a difficult five-year economic crisis which affected the public finances of many Member States. The failure to put in place essential infrastructure, the cut in Community funding for strategic plans such as TEN corridors (down from EUR 20 billion to EUR 7,5 billion), and the strategies of the substantial European automotive industry, helped to render the plan obsolete. The EESC is about to adopt a major opinion on transport in urban areas, which highlights a steady decline in the use of public transport networks and suggests solutions to reduce the number of private vehicles on the road (3). The EESC condemns the failure to coordinate transport and energy policies adequately; together with environment and industrial policies, these address technical and industrial needs and concerns which are of necessity complementary. It is justifiably concerned that, thanks to this lack of coordination, the Commission document will be not nearly as effective as it could have been

3.11

These problems affect the Commission's legislative activity, communications and recommendations. The same difficulties are encountered in Brussels as at national level, and the situation is exacerbated by the fact that national policies should be coordinated at EU level (rather than the other way round).

3.12

A European energy policy must be sustainable by all social groups, so that all are treated equally as regards access to the services provided by energy suppliers, when purchasing more efficient household appliances and when renting flats. It should have a positive impact on employment, and this is certainly possible in the immediate term in the housing sector. For all types of measures designed to increase energy efficiency, concessions should aim to highlight the benefits for the user, so that the time necessary to offset costs is reasonably short and easy to calculate.

3.13

Funding must not come solely from public finances: a fund could be created using a small proportion of the huge profits reaped by the energy and electricity sectors, as, moreover, has already been piloted in a number of Member States. However, this must not lead to higher charges for end users and less strategic investment from businesses. The huge investments that will be needed in the production industry to cope with growing demand and increasingly heavy costs will, of course, have to be taken into account, while for other fossil resources prices are linked to oil price trends but research costs are much lower, as they are for the distribution industries. Therefore, contributions to the fund should take account of the significant differences in research costs that have to be borne. Differentiation between Member States could be provided for according to the different legislation in force in terms of requirements for energy industries to invest in research on energy efficiency and price control. This solution could enable small property-owners without financial resources to increase the energy efficiency of their homes, setting in motion a virtuous circle which would create jobs.

3.14

Any tax relief, to be used with extreme caution, should be implemented with due regard for the lowest income-groups, who, as they do not pay tax, would be excluded from measures intended to facilitate an energy efficiency policy. Efficiency bonuses could be provided for those who are not subject to direct taxation because their incomes are too low.

3.15

The EESC feels that it is essential for awareness-raising campaigns to be developed at European, national, local and regional level, with one theme agreed on at a time (e.g. during one month in Europe there could be focus on light bulbs, another month on public transport development, another month on environmentally-friendly, efficient heating/cooling etc.). Campaigns could be launched to disseminate ideas and suggestions, constantly making more of the public aware of this vital need. Only by mass awareness-raising will it be possible to achieve tangible results. The democratic debate, involvement of all the representatives of the various stakeholders and the role of governments will be essential for effective management of the actions planned. Member States with more technical consultants in the area of energy efficiency should oversee training for consultants in the other EU Member States, to ensure uniform dissemination of the knowledge necessary for the success of the Action Plan. In the Member States, the study of energetics in higher and further education should be encouraged, promoting interregional cooperation. The Commission could play an effective coordination role.

3.16

Great care must be taken to strike the essential balance between the need to provide for all possible improvements and the economic and production systems' ability to deal with very sudden change. There is a real danger that if energy-intensive industries are faced with costs that are too high, they will relocate to areas with fewer ‘constraints’. The pace of change must be strictly linked to potential to adapt and absorb the costs. Measures should be developed to enable long-term contracts to be signed guaranteeing long-term, stable energy prices in exchange for commitments to invest in innovation, technology or infrastructure in the fields of production, transport and distribution. The investments should be assessed from the point of view of energy efficiency. The use of voluntary agreements should be seen as positive, but requires a genuine, rapid monitoring capacity on the part of regional bodies and the intention to replace them with binding undertakings if they prove ineffective.

3.17

The measures identified must always take into account the state of the market, which is becoming increasingly globalised. The potential increase in energy prices could cause huge problems for high energy-use sectors such as the aluminium or cement industries. The Lisbon goals must always be borne in mind and the competitiveness of the European system consistently guaranteed; it must be able to rely on energy prices which are in line with the global economic system. Moreover, Europe must not tolerate the constant threats of relocation which some sectors and businesses continue to issue. Businesses which relocate purely to increase their share of profits should be penalised as, in addition to the — sometimes extreme — social problems which they inevitably cause, which also impact on the community, they distort competition in the internal market by placing goods on the market which have been produced in other, more tolerant countries which do not impose the same constraints.

4.1

The EESC will not discuss each individual action proposed (about 75), for obvious reasons, but it feels it should comment on the most important measures and proposals in the document and the Annexes. A hearing has been held at the EESC and further, useful recommendations made by the participants, which have enhanced the EESC's knowledge of the matter and contributed substantially to its work.

4.2

Firstly, the measures adopted thus far on dynamic energy performance requirements for energy-using products, buildings and energy services have yielded successful results. Producers and consumers have shown great interest in expanding supply of and demand for new, increasingly efficient products and have proved very willing to do so. The immediate confirmation of the achievable savings and increasingly widespread education and awareness-raising on environmental issues suggest that these policies are practicable in the immediate term and can achieve the hoped-for results. Eco-design has been well received by the public, which is paying increasing attention to the features of the products on offer. The tendency which some producers are already showing to emphasise energy efficiency and give consumers detailed instructions on energy-efficient use of their products must be fostered. The US model also deserves attention, as it has allocated specific incentives for businesses which use eco-design with very encouraging results. The EESC believes that supporting the network of businesses by awarding tax credits to businesses which develop and produce products which are very energy-efficient will have successful results, provided that this system goes hand in hand with effective, substantive market and product surveillance similar to that carried out in the machinery sector. This surveillance activity must be seen as a guarantee that the investments of manufacturers that act ethically will not come to nothing and it must be commended to the regional authorities responsible for its implementation.

4.2.1

Labelling is a good practice, which should be encouraged and adopted for as many products as possible and extended to the automotive and construction sectors without delay. The EESC supports the proposal and urges the Commission to make the 14 products mentioned subject to minimum energy performance standards, paying particular attention to the specific market segments, to avoid a new regulatory system distorting competition. Other end-use products which should be made subject to minimum standards must also be identified. The priority given to reducing energy-use in ‘stand-by’ and ‘sleep’ modes is endorsed by the EESC, which sees this action as very important as it could help to reduce consumption in these modes up to 70 % by phasing out appliances in use. The EESC feels that the Energy Star agreement should make registration mandatory in the EU (as it is in the US) for open tenders for the purchase of office equipment and ‘expects the Commission itself to set an example’ (4). An agreement of this kind should also be negotiated with other major producers from East Asia, which now account for a considerable chunk of the electronic appliances market.

4.2.2

In the field of household appliances, because of the lack of rapid procedures for verifying the accuracy of labels and punishing abuse, there is a danger that well-intentioned enterprises which invest in energy efficiency will be penalised and non-compliant products will be allowed to enter the market. The replacement of older household appliances (an estimated 200 million appliances over 10 years old are in use in Europe) should be encouraged, bringing greater savings; non-energy efficient, obsolete appliances must be prevented from entering the second-hand market in developing countries as well. It should also be ensured that initiatives funding the purchase of household appliances be reserved for energy-efficient products.

4.2.2.1

It should be stressed in this connection that, while refusing to comply with the voluntary self-regulation code, the electrical appliances industry is declaring the need for binding measures to regulate the market. The lack of penalties for unscrupulous producers and importers who classify products as class A which do not comply with the energy savings measures laid down has, in practice, facilitated circulation on the market of ‘bogus’ low-consumption appliances. The shortcomings condemned by European businesses, which are calling for ‘rules’, are still, however, cause for thought regarding the effectiveness of voluntary agreements.

4.2.3

Considerable savings are achievable in the building sector, and even today alternative materials, construction methods and forms of heating are available, such as condensing boilers which achieve fuel savings of between 6 % and 11 % by reusing the latent heat which would normally be dispersed. Energy use on air conditioning could be reduced by fitting sun-blocks on the outside of buildings, as interior sun-blocks provide a shield against light but preserve much of the heat energy. Passive houses, for instance, are houses which use no more than 15 kWh/m2 per year (winter-summer) for basic consumption: cooling, heating. The total consumption (sufficiency) and the basic consumption limit should also be indicated, calculated as a whole (lighting, appliances — efficiency + sufficiency), including drying washing (drying one kg of washing can use three to four times the energy needed for one wash). Given that energy consumption could successfully be reduced from an average of 180 kWh/m2 per year to around 15 kWh/m2 per year, savings of up to 90 % could be made (22 houses, passive house village Wiesbaden 1997, average consumption 13,4 kWh/m2 per year; 32 passive houses, Kronsberg 1998, average consumption 14,9 KWh/m2 per year). Launch of a European market in this kind of product must be encouraged, to make these technologies widely available at affordable prices.

4.2.4

The EESC points out the need for public investment in energy efficiency in social and public buildings, together with the use of renewable sources, in particular in the new Member States where there is potential for substantial results to be achieved in energy saving. In addition to programmes to harmonise legislation and develop training for specialists, the EESC calls for part of the Structural Funds to be earmarked for this purpose. European financial institutions should also be urged to encourage investment in modernising energy efficiency in buildings.

4.2.4.1

Proper passive houses have to have certain construction characteristics (optimum insulation in walls and floors, pre-ventilation ducts for incoming fresh air underneath the house), which make it difficult and costly to fully adapt existing buildings to this standard. This means that it might be best to focus efforts on ensuring that as many new buildings as possible, especially public buildings — for which binding rules should be phased in — meet the passive house standard. In addition to this, it is extremely important that the energy-efficient solutions of passive houses are adopted to a considerable extent when repair or maintenance work is carried out on private buildings, which could also be supported by revolving funds with very low interest rates. It must be remembered that the majority of buildings that will be in use in 2020 are already in place now. As regards rental property, the issue must be addressed of how to make large-scale investment in energy savings in residential buildings financially viable for owners, given that it is the tenants who usually derive the direct benefits.

4.2.4.2

In the Impact Assessment Report SEC(2006) 1175, the Commission expects that savings of 140 Mtoe could be made by amending the Energy Performance of Buildings Directive (2002/91/EC), lowering the current threshold from 1 000 m2 for minimum requirements (strengthening them for public buildings) and by applying the white certificates scheme more widely. The EESC is concerned that this target may be too ambitious for the short term (5). The EESC believes that Member States should adopt uniform instruments to measure the impact of the regulations (e.g. quality of heat insulation) and that it should be mandatory for them to adopt proper monitoring measures. (See the discrepancies between, for example, France, where there is little monitoring, and Flanders, where monitoring is very stringent.) The Council and Parliament should assess whether there are legal bases for authorising the Commission to issue a regulation on the subject instead of the new directive, simply repealing Directive 2002/91 after 2009.

4.2.4.3

A recently-published thesis (6) points out that:

4.2.4.4

The picture that emerges from this analysis is that substantially (at least over 16 cm) thick insulation will always bring a return on investment made to achieve the passive house target, especially vis-à-vis conventional buildings. From an operational point of view, insulation of the whole of the building envelope is more important than other measures, while an aggregate analysis of measures allows the Net Present Value (NPV) of the investment to be optimised.

4.2.5

As regards white certificates, the — albeit limited — positive experience of countries which have introduced them has been tempered by delays in industrial innovation in some EU countries. Indeed, an effective white certificates scheme requires realistic targets in terms of technical and economic potential, a wide range of options for achieving targets (sectors, projects, actors, costs), guaranteed proper market functioning (structure of demand and supply, surrounding conditions), clear, transparent, non-discriminatory rules with a streamlining effect (market access conditions, market rules) and appropriate penalties. Are these prerequisites in place in the potential European white certificates market? The necessary caution should therefore be exercised in any potential dissemination of this practice.

4.3

Losses in the transformation phase are equivalent to total basic energy consumption in residential buildings and industry, 33 %, i.e. over 580 Mtoe. The EESC believes that this should clearly be a key area of action. Losses during long-distance transmission are a major factor. An area which certainly warrants development is modern high-voltage, continuous-current transmission lines, where only 3 % of power can be lost per every 1 000 kilometres of grid. As well as bringing considerable savings, this technology eliminates the electromagnetic effects of alternating-current transmission such as ELF electromagnetic wave emissions associated with alternating-current transmission. Current technology already makes this kind of transmission economically viable over long distances (it has been in use for decades in Sweden and the United States and is being developed throughout the world), while for short distances the cost of low-voltage alternating-current conversion systems for local use, which is still high, must be taken into account. Specific research projects should encourage endeavours to reduce these costs (7).

4.3.1

Another area for action is support for solar thermal power technology, which could be introduced in partnership with the Euromed countries, whose large areas of desert are constantly exposed to the sun's rays. A recent report commissioned by the Minister for the Environment of the Federal Republic of Germany stresses the key role of this technology developed by Italian Nobel Prizewinner, Rubbia, which is now being piloted in Granada. Enel, in cooperation with Enea, has recently launched a project which introduces, for the first time anywhere in the world, integration of a combined gas cycle and a solar thermal power plant. Using innovative, unique technology developed by Enea, Archimede (Archimedes) produces a constant flow of solar electricity. However, the project also boasts other elements which are not used anywhere else in the world, harnessing five new patents, such as molten liquids — liquids which when heated give off the heat from which energy is produced. Those used hitherto could be heated to up to 300 degrees. Those used by the Archimede project can be heated to up to 550 degrees, the same temperature as vapour fossil fuel, allowing integration with conventional power stations and therefore helping to secure the stability of the energy system.

4.3.2

The EESC recommends that the European institutions make substantial endeavours in these areas, adopting specific measures to support development of thermal solar power.

4.3.3

Cogeneration of heat and electricity, whether using residual heat from electricity production for heating or using residual heat (e.g. in furnaces) to produce electricity, could yield a huge increase in fuel efficiency, from around 35 % to 70 %. The additional costs for grid managers arising from distributed generation and active distribution should be borne in mind, and the necessary investments encouraged, reflecting the different basic conditions in the different Member States as well. The EESC supports the Commission's desire to develop high-efficiency CHP plant, even though introduction of a regulatory framework for calculation methods has been postponed until 2010 and Guarantees of Origin are issued whose compliance with the minimum requirements is not always verifiable. The EESC wonders whether it might be possible to reduce the timeframes for harmonising calculation methods, to allow an internal market in CHP plant to develop: the differing legislation in different countries is currently blocking this. Each Member State has the right to choose its own calculation methods to assess the energy efficiency of plant and bring them into line with the Community system, which should tally with the provisions of the directive. However, in practice this does not happen and the results for plant vary greatly when subjected to the calculation methods of different Member States. Harmonisation is an effective tool for combating fraud as well. The EU's efforts must be stepped up, given that the results of the first check-up on 21 February are not in line with strategic objectives, as can be seen from the assessment reports submitted by Member States on progress made in developing CHP with a view to increasing the proportion of electricity produced in this way.

4.3.4

The EESC calls on the Commission and the Council to give more support to trigeneration programmes, which use residual heat for cooling as well. The COPs (coefficients of performance), i.e. the ratio between output cooling energy and input heat energy, for these plants are particularly noteworthy. Compared with a COP of 2,0 for conventional units, these plant achieve a COP of 0,7-1,3 depending on the heat used (8). Waste wood regenerators are already on the market: they can use fruit (stones, peel) and agricultural (olive residues, sweetcorn cobs) processing products, sawmill and other wood-processing waste, dead branches, bark, coffee husks, palm waste, industrial waste and discarded packaging. 100 kg of this waste produces 70 kW of continuous electrical power (80 peak) and 130 kW of heat and cooling. A tonne of waste wood costing EUR 70 replaces 160 litres of diesel costing EUR 175.

4.3.5

The Committee advocates undertaking a campaign and other measures to limit the use of product packaging, which should be recyclable. The energy consumed in the production and subsequent disposal of packaging is excessive, given that the bulk of such packaging is non-biodegradable and a serious cause of pollution.

4.4.1

At present, the energy market is not harnessing all its efficiency potential and there is a need for greater transparency on the energy efficiency of power stations and on transmission network losses. The gas and electricity markets have not been fully liberalised. In some cases, lack of transparency on price setting and on the liberalisation process itself is a barrier to a genuine energy efficiency policy. It would be appropriate in this connection to strengthen the concept of legal separation of businesses managing technical monopolies from those operating under a system of free competition, as provided for by the directives on the liberalisation of the electricity and gas markets respectively (Directive 2003/54/EC and Directive 2003/55/EC), together with the more stringent requirement of separation of ownership.

4.4.2

The sector's pricing policy should foster energy efficiency and savings, particularly as regards fossil fuels, and encourage renewables. Particular consideration should be given to vulnerable consumer groups, following the principle that they should be guaranteed the necessary energy supply for basic consumption, while continuing to make it financially beneficial for them to save energy: for example, ‘social’ rates could be ensured for the least well-off but only up to a given threshold of consumption, or such households could be granted financial support.

4.4.3

A useful scheme to stimulate energy savings is the introduction of electronic meters, which provide a system of remote energy distribution management and optimise management of grid load. According to Enel (the largest Italian electricity provider), which supplied its 30 million clients with electronic meters free of charge, systematic organisation of energy use, brought about not least by a targeted pricing policy, leads to more effective exploitation of production, particularly at off-peak times. Electronic meters help to make the end user aware of their consumption, encouraging more intelligent use of resources. They have been recognised as an energy-efficiency mechanism under the Energy Services and Security of Supply Directives.

4.4.4

The distributed generation model (i.e. where there are many different producers, some of them very small) is problematic in a number of respects in terms of procedures for operating medium- and low-voltage networks, which are designed solely for unidirectional flow. Huge investments are necessary to bring networks into line with new production methods. Of course, local production entails fewer losses during transmission but the investment necessary is very high and there is great reluctance locally to accept even small power stations.

4.5

The transport sector has striven hard to reduce energy use and pollutant emissions, but it is right to call for a further effort, given that it is the fastest-growing sector in terms of energy use and a source of greenhouse gases: CO2 emissions from road transport rose by 26 % between 1990 and 2004. The fact that European industry relies on third countries for transport fuel (98 % of which is fossil fuel) increases its responsibility to make a key contribution to energy efficiency and the reduction of emissions and gas and oil product imports.

4.5.1

The Commission has sent a strong signal to the market with its recent decision to draw up legislation on the 120 g CO2 target, labelling for road tyres and specific maximum rolling resistance limits, and the changes to requirements governing fuels, petrol blends with high levels of ethanol, biofuels, low-carbon fuel and diesel with ultra-low sulphur content. Between 2011 and 2020, fuel suppliers in the EU will have to achieve a 10 % reduction in the greenhouse gas emissions their fuels produce when they are refined, transported and used. The reduction will save 500 million tonnes of carbon dioxide emissions by 2020. The reason for this decision was the fact that emissions fell from 186 g CO2 km to 163 g CO2 km, i.e. by only 12,4 %, between 1995 and 2004, with a sharp increase in average power, with regard to which it is more difficult to reduce harmful emissions. This incongruity suggests that it would be beneficial to increase taxes on non-energy efficient luxury vehicles, as some Member States have done. The Commission estimates that CO2 emissions will be reduced by a further 400 million tonnes by 2020.

ACEA, the European Automobile Manufacturers' Association, has called for the start of the process to be put back from 2012 to at least 2015, and for all players to be involved, as recommended by the Cars 21 High Level Group. European manufacturers feel that, if they do not go hand in hand with long-term planning to replace models, the measures in question will entail unsustainable costs for European enterprise.

4.5.2

The EESC points out that large-scale substitution of fossil fuels for biofuels would entail the risk of placing fuel production in competition with food production as regards allocation of fertile land for different uses. The price of food could then rise to meet the price of energy production, in turn aligned with the price of fossil fuels, effectively placing motorists from the north in competition (9) with the starving poor in the south. A genuine ethical problem is raised by the use as fuel in countries in the northern hemisphere of agricultural resources which could save millions of lives in the developing south. Iowa's entire maize crop could be used for ethanol production. If we consider that a 25-gallon SUV tank holds 94,5 litres, which is equivalent to one person's food ration for a year, the issue becomes tangible and calls for some sort of response. The EESC is about to issue an opinion on this specific subject (10).

4.5.3

The EESC notes that the Commission is both encouraging voluntary agreements and announcing mandatory measures. The Commission itself acknowledges the key role of self-regulation in that targets can be achieved more quickly and cost-effectively than under legal requirements. Voluntary agreements can have advantages over regulation. They can be implemented quickly and cost-effectively and thus bring rapid progress. They are flexible and can be brought into line with technological options and market trends. The EESC asks the Commission to look carefully at the reasons for poor progress in containing CO2 emissions in the European automotive industry, which is in the lead as regards research and development investment. The EESC agrees with the Commission's statement that binding standards do not always allow research potential to be fully developed and may hamper progress in the solutions to be adopted.

4.5.4

The construction industry has a crucial part to play in implementing energy efficiency both in new buildings and in adaptation of existing buildings. But in several countries the industry has been slow to adapt to improved methods and has been resistant to the imposition of higher standards. A major effort needs to be made to re-educate all concerned in the industry of the need and feasibility of higher standards, and to persuade them to be constantly in the lead in pioneering better efficiency standards instead of resisting change. Designers, managers and craftspeople of all the different trades in the construction professions need new training on what can be achieved on energy efficiency and new incentives to achieve these levels.

4.6

The EESC fully supports the incentives and financing and tax strategies proposed by the Commission, in particular involving the EIB and the EBRD. It also supports moves to raise the European banking sector's awareness of the need to provide financial support for the implementation of national energy plans. The removal of the remaining legal barriers for companies providing energy-efficiency solutions (ESCOs) is particularly important to this end.

4.6.1

The EESC calls for a dedicated conference to be held on financing energy efficiency, to raise awareness among stakeholders and encourage the European banking sector to participate in a major project to modernise the European economy. Banks could take part in a sort of millennium challenge, with awards for those which had adopted the best solutions to fund energy efficiency.

4.7

Campaigns to raise awareness among the general public are essential, in the EESC's view; they could be developed by national and local authorities, manufacturers and energy suppliers. The role of regional authorities as ‘impartial’ channels conveying information to the public must be stressed. Wide publicity should be given to the successful results of energy savings initiatives. Advertising should promote energy efficiency and respect for the environment as the genuinely defining qualities of products, to encourage a more appropriate view of what constitutes status symbols, which are currently all too often explicitly associated with products which are not energy efficient when actually used. The EESC supports the creation of the ‘Covenant of Mayors’ but feels that the goal of bringing together Europe's 20 most important cities is too unambitious. The target should be much higher and local expertise harnessed. One excellent way of connecting local administrators, who are responsible for key policy in the field of urban transport, for example, and in all neighbourhood activities which have a direct impact on the public, would be to set up a portal for the exchange of expertise between the EU's towns and cities, where over 80 % of the EU's population live. The awarding of ‘energy-efficient municipality certificates’ (the first certificate was awarded to a small Italian municipality: Varese Ligure) is without a doubt a major incentive to local authorities to adopt energy-efficiency policies. The Commission could also launch a ‘European energy efficiency competition’ between Europe's schools, with prizes for those whose solutions most effectively combine savings with quality.

4.7.1

The EESC regrets that the Action Plan overlooks the major role that the social partners and social dialogue have to play at all important levels in assessing, promoting and developing energy-savings policies. The EESC calls on the Commission to take steps to encourage the incorporation of environmental sustainability issues into the various levels of existing social dialogue structures, particularly in sectoral dialogue and in European Works Councils. A job-related approach, improving the quality of information provided to workers and worker consultation and participation, could yield great benefits in terms of energy efficiency, considering the processes and new technologies in industry, worker mobility issues, recycling and home-working, to mention only the most important: it is therefore absolutely essential for workers' representatives to be involved in energy efficiency strategies. One potential area for the social partners to discuss is collective agreements which, on the basis of genuine partnerships, distribute to workers part of the savings made in a business. Trade union organisations have a key role to play in improving knowledge and awareness at both European and national levels, helping to disseminate best practices.

4.7.2

It is important that the issue of energy savings goes hand in hand with good corporate social responsibility practices, particularly in multinationals, where more intensive social dialogue is needed to address all energy efficiency-related matters; these will help to bring progress in defining a European strategy for moderate carbon use, taking into account all the health hazards, such as fine particles, which are now creating an emergency situation in many European towns. The dissemination of best practices, such as not using carbon in printers, and other initiatives, helps to raise awareness and create positive attitudes towards sustainable policies.

4.8

The international dimension of the issue of increasing energy intensity is firmly stressed by the Commission. The EESC endorses the partnership proposals and the drawing-up of an International Framework Agreement. As regards the planned international conference on energy efficiency, the EESC warns against underestimating the need to involve countries from the ACP, Euromed and ENP programmes. International cooperation is essential if we are to successfully achieve sustainable development, and greater diplomatic endeavours must be made to achieve a new, post-Kyoto international protocol by 2009 with the conference which is to open this year in Bali.

4.9

European industry, which is developing major energy saving technologies, can, through industrial cooperation, give other countries considerable assistance in improving the quality of their electricity production, energy consumption and resulting greenhouse gas emissions, thereby helping to reduce overall consumption.