# C_2006088EN.01005301.xml

| 11.4.2006 | EN | Official Journal of the European Union | C 88/53 |
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11.4.2006

EN

Official Journal of the European Union

C 88/53

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Opinion of the European Economic and Social Committee on Energy Efficiency

(2006/C 88/13)

In a letter dated 7 June 2005, the European Commission asked the European Economic and Social Committee, under Article 262 of the Treaty establishing the European Community, to draw up an opinion on Energy Efficiency.

Energy Efficiency.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for preparing the Committee's work on the subject, adopted its opinion on 31 January 2006. The rapporteur was Mr Buffetaut.

Mr Buffetaut

At its 424th plenary session, held on 14 and 15 February 2006 (meeting of 14 February), the European Economic and Social Committee adopted the following opinion by 78 votes to 2 with 1 abstention.

1.   Conclusion: Promoting Energy Efficiency

| 1.1 | The search for energy efficiency has become a necessity for enterprises; accordingly, in most cases, voluntary agreements should be able to cope with the major challenges of increased energy costs. |
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1.1

The search for energy efficiency has become a necessity for enterprises; accordingly, in most cases, voluntary agreements should be able to cope with the major challenges of increased energy costs.

| 1.2 | The European Union could play a particularly useful role by systemising information on best practices and innovations in this field. DG Energy could become an information hub for energy efficiency. |
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1.2

The European Union could play a particularly useful role by systemising information on best practices and innovations in this field. DG Energy could become an information hub for energy efficiency.

| 1.3 | Public awareness campaigns can also play a useful role. To be successful, these campaigns must take place as close as possible to end consumers and to the professional sectors concerned. It is, therefore, up to the national and local authorities to take responsibility for such action. |
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1.3

Public awareness campaigns can also play a useful role. To be successful, these campaigns must take place as close as possible to end consumers and to the professional sectors concerned. It is, therefore, up to the national and local authorities to take responsibility for such action.

| 1.4 | Lastly, recourse to regulation should be the exception rather than the rule given that several legal instruments have already been adopted whose implementation must still be assessed. |
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1.4

Lastly, recourse to regulation should be the exception rather than the rule given that several legal instruments have already been adopted whose implementation must still be assessed.

| 1.5 | Energy efficiency isn't simply a slogan, a luxury or a gadget. From an international perspective, where the demand for energy will continue to grow, particularly due to the rapid development of emerging economies such as China, India or Brazil, it is in the best interests of the public, businesses and the EU Member States. The International Energy Agency forecasts that world energy demand will increase by 60 % by the year 2030, whilst the European Union — which is 80 % dependent on fossil fuels — will see its energy imports rise from 50 to 70 % over the same period. However, compared with energy-producing countries and other large energy consumers, the European Union is not a united player on the world energy market. It is for this reason that during the informal Hampton Court summit last October, Tony Blair, as president of the Council, advocated the creation of a common energy policy. |
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1.5

Energy efficiency isn't simply a slogan, a luxury or a gadget. From an international perspective, where the demand for energy will continue to grow, particularly due to the rapid development of emerging economies such as China, India or Brazil, it is in the best interests of the public, businesses and the EU Member States. The International Energy Agency forecasts that world energy demand will increase by 60 % by the year 2030, whilst the European Union — which is 80 % dependent on fossil fuels — will see its energy imports rise from 50 to 70 % over the same period. However, compared with energy-producing countries and other large energy consumers, the European Union is not a united player on the world energy market. It is for this reason that during the informal Hampton Court summit last October, Tony Blair, as president of the Council, advocated the creation of a common energy policy.

| 1.6 | It is important not to ignore the fact that the rapid rise in demand and increase in energy costs can have a heavy impact on the economic growth of the European Union, encourage certain high energy consuming sectors to relocate and, consequently, damage the social situation of Member States whose social security systems are already overstrained as a result of ageing populations and a declining birth rate. In this respect, energy efficiency measures are very worthwhile because in the final analysis they contribute to a reduction in costs and thereby to increased competitiveness. |
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1.6

It is important not to ignore the fact that the rapid rise in demand and increase in energy costs can have a heavy impact on the economic growth of the European Union, encourage certain high energy consuming sectors to relocate and, consequently, damage the social situation of Member States whose social security systems are already overstrained as a result of ageing populations and a declining birth rate. In this respect, energy efficiency measures are very worthwhile because in the final analysis they contribute to a reduction in costs and thereby to increased competitiveness.

| 1.7 | In the same way, competition over energy resources could lead to heightened political tensions and even threaten the peace and stability of certain regions, a threat which could spread easily through international terrorism. |
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1.7

In the same way, competition over energy resources could lead to heightened political tensions and even threaten the peace and stability of certain regions, a threat which could spread easily through international terrorism.

| 1.8 | Lastly, the reasonable, efficient and economic use of energy resources is a vital stabilising factor for our planet and for future generations. |
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1.8

Lastly, the reasonable, efficient and economic use of energy resources is a vital stabilising factor for our planet and for future generations.

| 1.9 | The EESC believes that the Green Paper on Energy Efficiency: Doing More with Less raises a number of relevant questions and proposes realistic courses of action. It fully supports the plan to reduce energy consumption by 20 % and feels that it is vital not only to quickly reach the objective of a 1 % annual reduction in energy consumption but to also set an effective reduction target of 2 % as part of a second phase. |
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1.9

The EESC believes that the Green Paper on Energy Efficiency: Doing More with Less raises a number of relevant questions and proposes realistic courses of action. It fully supports the plan to reduce energy consumption by 20 % and feels that it is vital not only to quickly reach the objective of a 1 % annual reduction in energy consumption but to also set an effective reduction target of 2 % as part of a second phase.

Doing More with Less

| 1.10 | It believes that voluntary agreements with the large economic sectors undoubtedly represent an effective solution, and one which is preferable, where possible, to restrictive regulatory measures.
  As the two sectors with the largest energy consumption, the transport and construction industries must be the focus of intense efforts and the search for innovation.
  The continued and gradual introduction of efficient innovations in the field of energy efficiency responds to the needs of both consumers and industry. The European Union and the Member States must become strongly involved in convergent policies aimed at promoting energy efficiency, the exchange of best practices, the distribution of the best technologies as well as information and incentive campaigns for households and consumers. |
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1.10

It believes that voluntary agreements with the large economic sectors undoubtedly represent an effective solution, and one which is preferable, where possible, to restrictive regulatory measures.

As the two sectors with the largest energy consumption, the transport and construction industries must be the focus of intense efforts and the search for innovation.

The continued and gradual introduction of efficient innovations in the field of energy efficiency responds to the needs of both consumers and industry. The European Union and the Member States must become strongly involved in convergent policies aimed at promoting energy efficiency, the exchange of best practices, the distribution of the best technologies as well as information and incentive campaigns for households and consumers.

2.   Introduction

In 2000, the Commission had stressed that there was an urgent need to promote energy efficiency more actively, both at EU level and in the individual Member States. This need was affirmed in the light of the aims adopted under the Kyoto agreements, as well as in view of the need to provide a more viable energy policy for a continent that has a high resource dependency, and to work to ensure the safety of its supply.

Accordingly, an action plan was published which aimed to strengthen energy efficiency within the European Community, with the following objectives:

| — | to draw attention to energy efficiency, |
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to draw attention to energy efficiency,

| — | to put forward joint measures and action within the framework of the Kyoto agreements, |
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to put forward joint measures and action within the framework of the Kyoto agreements,

| — | to clarify the respective roles of the Community and the Member States, |
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to clarify the respective roles of the Community and the Member States,

| — | to realise the potential for improving energy efficiency, the objective being to achieve a reduction of 1 % per annum in energy intensity, a cumulative objective considered to be feasible, |
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to realise the potential for improving energy efficiency, the objective being to achieve a reduction of 1 % per annum in energy intensity, a cumulative objective considered to be feasible,

| — | to promote new technologies. |
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to promote new technologies.

2.1   The situation five years after

The one percent objective remains an objective to be reached but a number of legal instruments have been put into place; agreements on objectives have been signed with various economic sectors; a wider discussion has been initiated by the Commission or at the Council's request. The Kyoto agreements have come into effect; objectives have been outlined for the development of renewable energy. The objective to reduce the energy intensity will probably not be realised straight away, but will rather take place sector by sector, on a gradual basis.

2.1.1   Legal instruments

Certain instruments have been adopted, others are in the process of being adopted; some are specific, whilst others have a broader scope: Regulation on a Community energy efficiency labelling programme for office equipment
   (1)
  , Directive on the energy performance of buildings
   (2)
  , Directive on the promotion of cogeneration
   (3)
  , Proposal for a Directive on energy end-use efficiency and energy services
   (4)
  .

Regulation on a Community energy efficiency labelling programme for office equipment

1

, Directive on the energy performance of buildings

2

, Directive on the promotion of cogeneration

3

, Proposal for a Directive on energy end-use efficiency and energy services

4

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Furthermore, the agreements negotiated with certain economic sectors establish norms for minimum efficiency; these voluntary agreements represent an alternative to drawing up new legislation.

We must ensure, however, that this does not produce a tangled web of overlapping legislation with a further increase in unclear bureaucratic rules, which would act as an economic hindrance and be detrimental to the objective of improved efficiency in the energy sector.

2.1.2   A broader discussion

At the same time, the European Union has launched a broader discussion, notably through a number of strategies, such as the sustainable development strategy adopted by the Gothenburg European Council in 2001, which was to be renewed by the end of 2005; unfortunately this has not yet happened. Other strategies worthy of mention include the strategies on recycling, the sustainable use of natural resources and urban development, which include energy-based aspects.

2.1.3   Kyoto

The Kyoto Protocol became effective after ratification by the Russian Federation but without the backing of the United States, which, for all that, is investing considerable amounts of money into researching methods of reducing CO2 emissions.

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In this context, the Commission published a communication entitled Winning the battle against global climate change and the Spring European Council affirmed its intent to give new impetus to international negotiations.

Winning the battle against global climate change

2.1.4   The development of renewable energy

Policies and objectives have been outlined for the development of renewable energy, particularly in the area of wind energy, as well as beyond, in all fields of eco-technology.

The demand for energy continues to grow and the EU's energy dependency remains high, which could have a heavy impact on its already unsatisfactory economic performance given the very rapid growth in global demand, particularly due to the expansion of emerging economies such as China, India and Brazil.

Wider discussion and the implementation of a European energy efficiency policy is therefore not simply a luxury, but a necessity, for three reasons:

| — | need for sustainable development, |
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need for sustainable development,

| — | economic necessity, |
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economic necessity,

| — | need for political independence. |
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need for political independence.

The EESC's discussion will therefore cover the issue of ‘energy efficiency, the need for sustainable development, competitiveness and economic independence’ which reflects the concerns outlined in the Green Paper.

The EESC's discussion

3.   The Green Paper on Energy Efficiency

| 3.1 | On 22 June 2005, the Commission published a ‘Green Paper entitled Green Paper on energy efficiency or Doing more with less’. This document appeared after both the publication of the Proposal for a Directive on Energy End-Use Efficiency and Energy Services and the parliamentary debates on this proposal, and followed on from the request made to the EESC for an exploratory opinion on energy efficiency. Given that Green Papers usually precede texts of a legal nature, this order of events may seem to be rather disconcerting; however, the scope of this Green Paper is actually broader than that of the proposed Directive. The EESC's exploratory opinion may be considered to be a contribution to the consultative work undertaken by the Commission. |
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3.1

On 22 June 2005, the Commission published a ‘Green Paper entitled Green Paper on energy efficiency or Doing more with less’. This document appeared after both the publication of the Proposal for a Directive on Energy End-Use Efficiency and Energy Services and the parliamentary debates on this proposal, and followed on from the request made to the EESC for an exploratory opinion on energy efficiency. Given that Green Papers usually precede texts of a legal nature, this order of events may seem to be rather disconcerting; however, the scope of this Green Paper is actually broader than that of the proposed Directive. The EESC's exploratory opinion may be considered to be a contribution to the consultative work undertaken by the Commission.

| 3.2 | The Commission starts by noting that the demand for energy is continuing to grow in spite of the fine words about more rational use of energy, and believes that it is advisable ‘to make a strong push towards a re-invigorated programme promoting energy efficiency at all levels of European society’. It considers that the EU could cut down on its current energy usage by at least 20 %. The EESC is pleased with the stated ambition of the Commission and the European Parliament to diversify supply and set objectives. It believes that a worthwhile initiative is being set up, one which should, moreover, lead to job creation through the development of new technology. Nonetheless, in the face of heightening global competition, it is vital to ensure that the energy policies implemented do not lead to any increase in energy costs, which would push up production costs. Accordingly, CO2 emission certificates could constitute a significant cost for high energy consuming sectors (e.g. the cement industry) and encourage relocation. The socio-economic repercussions of the measures outlined or implemented must not be disregarded. |
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3.2

The Commission starts by noting that the demand for energy is continuing to grow in spite of the fine words about more rational use of energy, and believes that it is advisable ‘to make a strong push towards a re-invigorated programme promoting energy efficiency at all levels of European society’. It considers that the EU could cut down on its current energy usage by at least 20 %. The EESC is pleased with the stated ambition of the Commission and the European Parliament to diversify supply and set objectives. It believes that a worthwhile initiative is being set up, one which should, moreover, lead to job creation through the development of new technology. Nonetheless, in the face of heightening global competition, it is vital to ensure that the energy policies implemented do not lead to any increase in energy costs, which would push up production costs. Accordingly, CO2 emission certificates could constitute a significant cost for high energy consuming sectors (e.g. the cement industry) and encourage relocation. The socio-economic repercussions of the measures outlined or implemented must not be disregarded.

2

| 3.3 | As is common practice with Green Papers, the Commission raises 25 questions on the options outlined in order to structure the public consultation process. It sets out action to be taken at EU, national, regional and local level, and, finally, action through international cooperation, by referring to policies to be implemented and sectors concerned, all illustrated with examples. |
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3.3

As is common practice with Green Papers, the Commission raises 25 questions on the options outlined in order to structure the public consultation process. It sets out action to be taken at EU, national, regional and local level, and, finally, action through international cooperation, by referring to policies to be implemented and sectors concerned, all illustrated with examples.

| 3.4 | Surprisingly, certain issues have not been discussed in spite of their significance. For example, the question of urban and public lighting in general has not been mentioned; neither have the issues of production using recycled products which, in certain cases, is more energy efficient (metals, aluminium etc.), or harnessing bio gas from landfills. |
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3.4

Surprisingly, certain issues have not been discussed in spite of their significance. For example, the question of urban and public lighting in general has not been mentioned; neither have the issues of production using recycled products which, in certain cases, is more energy efficient (metals, aluminium etc.), or harnessing bio gas from landfills.

| 3.5 | The aim of the Green Paper is to identify the bottlenecks (e.g. lack of appropriate incentives, lack of information, lack of training and lack of available financing mechanisms) that currently prevent the most cost-effective improvements from being put into effect. The measures to be promoted are those which can provide a net saving after taking account of the necessary investment. Answers are expected to these questions in the form of suggestions or examples that will help meet the proposed objective. Following the Green Paper, an action plan should be drawn up in 2006. |
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3.5

The aim of the Green Paper is to identify the bottlenecks (e.g. lack of appropriate incentives, lack of information, lack of training and lack of available financing mechanisms) that currently prevent the most cost-effective improvements from being put into effect. The measures to be promoted are those which can provide a net saving after taking account of the necessary investment. Answers are expected to these questions in the form of suggestions or examples that will help meet the proposed objective. Following the Green Paper, an action plan should be drawn up in 2006.

| 3.6 | The Commission appears to be relatively optimistic as it believes that the thorough implementation of all of the measures taken after 2001 (Directive on the energy performance of buildings; Directive on the promotion of cogeneration), taken together with the new measures, could lead to energy savings of approximately 1.5 % of annual consumption, thus resulting in 1990 levels of consumption. |
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3.6

The Commission appears to be relatively optimistic as it believes that the thorough implementation of all of the measures taken after 2001 (Directive on the energy performance of buildings; Directive on the promotion of cogeneration), taken together with the new measures, could lead to energy savings of approximately 1.5 % of annual consumption, thus resulting in 1990 levels of consumption.

Directive on the energy performance of buildings; Directive on the promotion of cogeneration

4.   Energy efficiency: a need for sustainable development, competitiveness and economic independence

| 4.1 | An energy chain exists which encompasses the producer, transporter, distributor and consumer. It is therefore important to be active at all stages of the chain, from supply to demand. Action could prove to be most effective at the two ends of the chain: production and consumption. |
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4.1

An energy chain exists which encompasses the producer, transporter, distributor and consumer. It is therefore important to be active at all stages of the chain, from supply to demand. Action could prove to be most effective at the two ends of the chain: production and consumption.

| 4.2 | As far as production is concerned, efficiency gains are being regularly introduced into production methods. |
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4.2

As far as production is concerned, efficiency gains are being regularly introduced into production methods.

| 4.2.1 | Accordingly, the cogeneration of heat and electricity seeks to recover energy that would otherwise have been wasted; new technologies are also applied, allowing sources of alternative energy to be used. In this way, the capture and exploitation of mine gas can supply power for cogeneration installations (e.g. at Freyming Merlebach in Lorraine). The heat of blast furnaces can also be recovered and harnessed (technique used at Brescia, Italy).
  In the Nordic countries, some heating and electricity cogeneration units have been converted to wood power, and are behind the development of a local wood industry.
  Moreover, research into how to resolve problems such as the clogging-up of installations and cases of abnormal combustion should lead to an improvement in the performance of such installations. |
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4.2.1

Accordingly, the cogeneration of heat and electricity seeks to recover energy that would otherwise have been wasted; new technologies are also applied, allowing sources of alternative energy to be used. In this way, the capture and exploitation of mine gas can supply power for cogeneration installations (e.g. at Freyming Merlebach in Lorraine). The heat of blast furnaces can also be recovered and harnessed (technique used at Brescia, Italy).

In the Nordic countries, some heating and electricity cogeneration units have been converted to wood power, and are behind the development of a local wood industry.

Moreover, research into how to resolve problems such as the clogging-up of installations and cases of abnormal combustion should lead to an improvement in the performance of such installations.

| 4.2.2 | The recovery of biogas at landfill sites enables the use of a source of energy that had previously been lost, whilst combating the greenhouse effect at the same time. Such innovation and recovery encourages the setting-up of installations close to the consumer and helps reduce or avoid transport-related energy losses. |
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4.2.2

The recovery of biogas at landfill sites enables the use of a source of energy that had previously been lost, whilst combating the greenhouse effect at the same time. Such innovation and recovery encourages the setting-up of installations close to the consumer and helps reduce or avoid transport-related energy losses.

| 4.2.3 | In the case of electricity production, tangible efficiency gains have been made in several sectors, such as the solar and wind power sectors; similar gains are expected of all types of new generation large conventional nuclear power stations. |
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4.2.3

In the case of electricity production, tangible efficiency gains have been made in several sectors, such as the solar and wind power sectors; similar gains are expected of all types of new generation large conventional nuclear power stations.

| 4.3 | With regard to consumption, energy-saving technology is constantly being introduced in the various energy-consuming sectors. The increase in the cost of electricity to the end user is forcing the industry to adopt innovative techniques. |
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4.3

With regard to consumption, energy-saving technology is constantly being introduced in the various energy-consuming sectors. The increase in the cost of electricity to the end user is forcing the industry to adopt innovative techniques.

| 4.3.1 | In the vehicle and transport sectors, innovation and progress are having an effect on engine specifications, fuel quality and efficiency, and on tyre development. Vehicle energy consumption has been improving for the last ten years, but it must be acknowledged that this has been offset by an increase in the number of vehicles. The increased use of bio-fuels is encouraged by tax incentives e.g. by taxing bio-fuels at a different rate to oil-based products (5).
  The automobile industry has signed up to a voluntary agreement with the EU to attain average CO2 emission levels of 140g/km f by 2008. The Parliament and the Council of the European Union would like the ACEA to commit to an objective of 120g/km by 2010. At all events, if the agreement is respected, private cars entering the market in 2008/2009 will be consuming 25 % less fuel than in 1998. |
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4.3.1

In the vehicle and transport sectors, innovation and progress are having an effect on engine specifications, fuel quality and efficiency, and on tyre development. Vehicle energy consumption has been improving for the last ten years, but it must be acknowledged that this has been offset by an increase in the number of vehicles. The increased use of bio-fuels is encouraged by tax incentives e.g. by taxing bio-fuels at a different rate to oil-based products (5).

5

The automobile industry has signed up to a voluntary agreement with the EU to attain average CO2 emission levels of 140g/km f by 2008. The Parliament and the Council of the European Union would like the ACEA to commit to an objective of 120g/km by 2010. At all events, if the agreement is respected, private cars entering the market in 2008/2009 will be consuming 25 % less fuel than in 1998.

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| 4.3.2 | In the case of transport, local authorities across Europe are conducting urban transport policies designed to improve the quality of public transport and reduce the use of private vehicles. In France, for example, every municipality must prepare an urban mobility plan and present it for approval. In other cases, more coercive measures are being adopted, such as urban tolls (e.g. in London). |
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4.3.2

In the case of transport, local authorities across Europe are conducting urban transport policies designed to improve the quality of public transport and reduce the use of private vehicles. In France, for example, every municipality must prepare an urban mobility plan and present it for approval. In other cases, more coercive measures are being adopted, such as urban tolls (e.g. in London).

| 4.3.3 | One should promote the use of modes of transport that are losing momentum, e.g. rail — whose share of the freight market has continued to fall (-7 %) — and navigable waterways. Nonetheless, it must be recognised that, in spite of all the talk, there has hardly been any development in these two key energy efficiency sectors, mainly because of the lack of infrastructure and the high cost of installation or modernisation (e.g. the Rhine/Rhone canal or the transalpine road-rail link). To compound matters further, the construction of this type of infrastructure often, rightly or wrongly, meets resistance from environmental pressure groups as well. |
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4.3.3

One should promote the use of modes of transport that are losing momentum, e.g. rail — whose share of the freight market has continued to fall (-7 %) — and navigable waterways. Nonetheless, it must be recognised that, in spite of all the talk, there has hardly been any development in these two key energy efficiency sectors, mainly because of the lack of infrastructure and the high cost of installation or modernisation (e.g. the Rhine/Rhone canal or the transalpine road-rail link). To compound matters further, the construction of this type of infrastructure often, rightly or wrongly, meets resistance from environmental pressure groups as well.

| 4.3.4 | Urban lighting management is also an area that is seeing energy saving innovations. Network teleprocessing systems enable monitoring of network operations in real time as well as the regulation of electric current and the adjustment of the volumes required in line with actual needs, leading to energy savings for the local community.
  Public lighting that uses less modern technology (mercury vapour, for example) is often being replaced by high-pressure sodium lights which are less powerful and less expensive. White diodes, which do not use much energy, are also being developed, as is solar energy. As for home lighting, low energy consumption lamps are gradually gaining a place on the market and are leading to a reduction in consumption. Certain electricity providers offer customers discount vouchers for the purchase of low-energy light bulbs (Italy). |
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4.3.4

Urban lighting management is also an area that is seeing energy saving innovations. Network teleprocessing systems enable monitoring of network operations in real time as well as the regulation of electric current and the adjustment of the volumes required in line with actual needs, leading to energy savings for the local community.

Public lighting that uses less modern technology (mercury vapour, for example) is often being replaced by high-pressure sodium lights which are less powerful and less expensive. White diodes, which do not use much energy, are also being developed, as is solar energy. As for home lighting, low energy consumption lamps are gradually gaining a place on the market and are leading to a reduction in consumption. Certain electricity providers offer customers discount vouchers for the purchase of low-energy light bulbs (Italy).

| 4.3.5 | In the case of buildings, the application of the directive on energy performance should soon start showing results. In any case, insulation norms have led to considerable progress being made in all new construction work; the same is true in the glazing sector. |
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4.3.5

In the case of buildings, the application of the directive on energy performance should soon start showing results. In any case, insulation norms have led to considerable progress being made in all new construction work; the same is true in the glazing sector.

| 4.3.6 | Several large industrial sectors such as the automobile industry have also signed up to voluntary commitments to improve the energy efficiency of their products which are, moreover, subject to European product labelling standards. The use of cogeneration units in industry is slowly developing. It is worth noting that certain high-energy consumption sectors such as the aluminium sector are also making not inconsiderable energy savings thanks to their use of recycled products. |
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4.3.6

Several large industrial sectors such as the automobile industry have also signed up to voluntary commitments to improve the energy efficiency of their products which are, moreover, subject to European product labelling standards. The use of cogeneration units in industry is slowly developing. It is worth noting that certain high-energy consumption sectors such as the aluminium sector are also making not inconsiderable energy savings thanks to their use of recycled products.

| 4.4 | Based on the above examples, it would appear that energy efficiency has become a natural and worthwhile procedure for economic players, particularly given the sustained increase in the cost of energy. This leads to the conclusion that voluntary action can be as effective as regulations over the medium or long term. |
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4.4

Based on the above examples, it would appear that energy efficiency has become a natural and worthwhile procedure for economic players, particularly given the sustained increase in the cost of energy. This leads to the conclusion that voluntary action can be as effective as regulations over the medium or long term.

5.   Questions in the Green Paper

5.1   Question 1: How can one better stimulate European investment in energy efficiency technologies?

The EESC believes that tax incentives can be effective in stimulating investments but that, in addition, energy efficiency services used on a continual basis can increase the energy efficiency of installations.

Nonetheless, it feels that there are other voluntary and non-tax measures which could also prove to be effective e.g. energy saving awards, the sharing of ‘best available technology,’ the organisation of internal campaigns to encourage businesses to develop simple, daily routines (automatic switching-off of lights, monitoring of electric and electronic installations etc.) as well as campaigns aimed at the general public. By the same token, energy providers could encourage consumers and customers to adopt a responsible approach to consumption, e.g. by promoting the use of low-energy light bulbs. This is also a question of personal and group responsibility. An old Indian proverb rightly states that, ‘we live in a world which we should leave as an inheritance to our children.’ It would be thus morally unthinkable to take an irresponsible attitude towards future generations.

As far as using funds for research is concerned, this could certainly have a multiplier effect as part of the partnership between public and private research centres.

5.2   Question 2: Relevance of the emissions quota mechanisms for energy efficiency

This policy could possibly be used to set up domestic projects in the housing and transport firm sectors which, as we know, consume vast amounts of energy. Certain countries have in fact already introduced energy saving certificates laying down obligations for energy producers in the field of CO2 emissions and energy saving. If no concrete action is taken, such producers are taxed (in France at a rate of two centimes per KwH), prompting them to launch customer initiatives to ensure that energy saving takes place.

2

It is important to ensure that potential increases in energy costs do not bring about any adverse socio-economic effects (relocation); that being said, such increases must always be viewed in the light of the risk of a major future energy crisis. What is a cost today could ensure a gain in the future. In the same manner, the various mechanisms such as emissions certificates or energy saving programmes must be assessed based on the extent to which they encourage investment in clean and energy saving technologies.

With regard to the plan to allocate CO2 emission certificates, it is unfortunate that those installations that have already invested in cleaner technologies which consume lower amounts of energy are not treated any more favourably than those facilities that have yet to make such efforts.

2

Furthermore, the allocation plans should take more account of cogeneration, a process that the European Union is keen to encourage.

5.3   Question 3: Usefulness of annual energy efficiency programmes at individual Member State level, and comparison of these plans

If such plans have been implemented, they should be consistent with the investment cycles. In practice, investments are not amortised over the course of one year, it is important, therefore, that plans take account of the necessary timings for implementation and amortisation.

These plans will only be capable of outlining objectives; nonetheless, their comparison could be useful as an instrument for spreading effective, best-performing practices.

5.4   Question 4: Usefulness of developing tax instruments

Tax instruments can be effective provided that they are well chosen and targeted. Nonetheless, the implementation of tax instruments is clearly a sensitive issue, and is primarily a matter for national administrations, and one must respect the principles of subsidiarity and the administrative freedom of local authorities. The modification of VAT rates, in turn, requires a unanimous decision at Council level.

The systematic use of eco labels is simpler and could turn out to be effective.

5.5   Question 5: Develop more environmentally friendly state aid rules by encouraging eco- innovation and productivity improvements

To achieve this, the sectors that consume the most energy — housing and transport — should be targeted. Nonetheless, it is important to ensure that state aid does not unfairly distort competition.

5.6   Question 6: Public authorities as an example

The EESC believes that the inclusion of energy efficiency criteria in public calls for tender should be encouraged, as should the performance of energy efficiency reviews in public buildings. Perhaps the concept of ‘best energy bidder’ should be developed?

In any case, an assessment of the work carried out on public buildings would be necessary to determine the relation between cost and effectiveness.

5.7   Question 7: Relevance of energy efficiency funds

Energy efficiency funds could be important instruments for more efficient energy use and for greater energy savings. With the help of such funds, private investment could be made easier and energy companies could provide their customers with options for lower energy use, thus speeding up development of energy efficiency services, and providing a stimulus for R&D and for timely market placement of energy efficient products. They are thus a useful accompaniment to the introduction of emissions trading.

On the other hand, more consistent consideration should be given to taking account of energy efficiency in the cohesion and regional development funds.

There is no doubt of the urgent need to increase loans for research and development, following the example of the USA, which has invested considerable public funds in energy technology.

5.8   Question 8: Energy efficiency of buildings

Whilst it is true that the sector is strategic, with potentially considerable energy efficiency gains, one must ensure that property owners and tenants are not faced with charges beyond their means, or an administrative burden that is too unwieldy or complex. One must therefore make sure that the Member States do not produce texts whose application is difficult to monitor due to their complexity and which will only be applied by certain businesses, thereby unfairly distorting competition. In the case of buildings, energy performance is a global issue but state organisations intervene on an individual basis. Accordingly, a structured approach is needed. In practice, it will be the architect, accompanied by a consultancy agency that will be responsible for the implementation of energy norms, which is why there is a need for clear and simple texts to ensure their effective implementation.

Any extension in the directive's scope of application may only be considered following an assessment of the application of the 2001 directive and, in particular, a lowering of energy thresholds, currently set at 1 000 m2. It is also worth stressing that the revision of thermal regulations every five years does not allow much time for implementation by a sector whose businesses are often small in size. A period of 7 years would certainly be more realistic so as to give businesses the time to implement these regulations without being forced to apply new regulations even though the old ones are barely effective.

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It would be useful to assess the measures taken by Member States and to exchange best practices.

5.9   Question 9: What incentives could be given to property owners to improve energy efficiency?

There is no doubt that an incentive-based tax policy is preferable, e.g. a reduction in property tax for property owners based on their investments in energy efficiency. In any event, such intervention should remain at national level.

It would in any case be very useful to see the development of a market for energy services as already exists in certain EU countries, particularly in Scandinavia and France.

5.10   Question 10: Improving the performance of energy-consuming products for household use

Feedback should be used as part of the integrated policy for products.

| — | This aim should be linked to the implementation of the directive on the eco-design of energy consuming products. |
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This aim should be linked to the implementation of the directive on the eco-design of energy consuming products.

| — | The establishment of voluntary commitments across the industry should be assessed. |
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The establishment of voluntary commitments across the industry should be assessed.

The Energy Label is compulsory for certain domestic appliances (refrigerators, freezers, washing machines, dishwashers, electrical bulbs). It could be extended to cover more appliances (e.g. domestic electric ovens and microwave ovens). It could also cover equipment in other areas that use a lot of energy, such as in heating and airconditioning (e.g. domestic gas boilers, circulator pumps and airconditioning split-units).

5.11   Question 11: Improving the energy efficiency of vehicles

One should await the outcome of the ACEA's voluntary commitment to the Commission.

In any case, the automotive industry is making constant progress in introducing innovations in vehicle energy efficiency, engine specifications and reduced consumption.

The question remains of the number of ageing cars on the road, which often has a social aspect. Nonetheless, it would be useful to encourage the purchase of new cars, for reasons of both safety and energy efficiency. Specific measures could perhaps be introduced in the form of loans to ensure that low-income households do not lose out.

Lastly, as stressed by the EESC in its report on sustainable transport, the taxation of various modes of transport remains highly unequal and penalizes certain forms of transport.

5.12   Question 12: Public information campaigns

To be successful, national campaigns should be favoured over European ones, particularly those specifically aimed at households. Awareness-raising campaigns for children would be useful for ensuring they acquire good energy-saving habits at an early age (e.g. the simple act of switching off the light when leaving the room). Accurate information for consumer would also be very useful to enable them to choose the energy consuming appliances that are best suited to their needs.

As a number of national campaigns have already been held, an exchange of experiences could be organised.

5.13   Question 13: Efficiency of electricity transmission and distribution, promotion of cogeneration

Electricity production suffers losses at the transformation stage (approximately 30 %) and during transport (approximately 10 %). Transport-related losses could be reduced by cutting transport time.

Savings could also be made by improving how demand is managed, particularly for large energy users. It would be useful to develop agreements between users and producers to manage demand more effectively.

The deregulation of the market should enable improved efficiency thanks to emulation between distributors; nonetheless, it is too early to assess this process.

In the case of cogeneration, one should carefully define the status of cogeneration-derived electricity; moreover, the parameters of the cogeneration directive appear to be hard to reach, all the more so given that they are interpreted in various ways across the Member States.

5.14   Questions 14 and 15: Role of electricity and gas providers in offering an energy service and introduction of white (energy efficiency) certificates

It is questionable whether it is indeed in the interest of the energy provider to promote methods of reducing consumption. For this reason, a number of Member States have introduced energy efficiency certificates.

All those involved in the energy chain must be taken into account if reductions in energy consumption are to be achieved. A voluntary code of good conduct would be useful.

Naturally, a more accurate definition is needed of what is understood by the concepts of an energy efficiency service and an energy performance contract.

In the case of white energy certificates, it would be useful to assess how they are used in those Member States where they have been introduced before they are applied across the whole of the EU.

5.15   Question 16: Stimulating industry in technologies that generate cost-effective energy efficiencies

How effective are existing measures (carbon, voluntary commitments)?

Voluntary commitments should be favoured over coercive measures. In any case, measures have already been taken in many European countries, in cases where they are economically and financially viable. Any action should, therefore, focus on measures that need incentives or aid; if this is not done, a windfall effect will be produced.

5.16   Question 17: A balance between modes of transport and increasing transport by rail and inland waterway

The rail sector often lacks flexibility and the waterways network is not yet fully developed and has too many bottlenecks. More investment is needed in the interoperability of the various modes of transport; the external costs must be integrated; and the emphasis must be shifted to those modes with more scope for energy efficiency. Allowing for regulated rather than pure and simple competition would more accurately reflect the needs of the sector and could make it more dynamic.

5.17   Question 18: Financing infrastructure in the trans-European transport network (6)

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A number of large trans-European networks have been slow in coming. The public finance crisis across Europe has often delayed their implementation. Public-private partnerships must also be encouraged. The EESC recommends, as a priority, investing EU money in the expansion of forms of transport which have proved to be especially energy efficient.

It is also to be hoped that encouragement will be given to public-private partnerships.

5.18   Question 19: Transport regulatory measures or standards

Priority should be given to technological innovations and to establishing standards that have been defined jointly by industry and public authorities.

5.19   Question 20: Should public authorities be obliged to purchase energy efficient vehicles?

The idea of imposing such obligations goes against the grain of the principles of subsidiarity and the administrative freedom of local authorities. That being said, numerous public authorities are already making these kinds of purchases. The standards governing calls for tenders could help encourage this practice.

That being said, the proposal for a directive on the promotion of clean road transport vehicles [COM(2005) 634] intends to extend this practice by introducing clean vehicle quotas into the calls for tender of public authorities.

5.20   Question 21: Infrastructure charging for transport and external costs (pollution, accidents etc.)

The EESC has on several occasions expressed itself in favour of taking account of external costs and has called on the Commission to submit an appropriate plan. It is therefore advisable that an assessment be made of the measures adopted up to now in the various countries in order to be able to measure precisely how effective they are.

5.21   Question 22: Energy efficiency project financing schemes managed by energy efficiency companies

Whilst such initiatives have proved successful, it is important to try and make them more widespread and to provide support for them throughout the EU.

5.22   Question 23: Energy efficiency issues in the Union's relationships with third countries

The cost of energy will make energy efficiency a much more higher profile issue than it has been in the past. International finance institutions should integrate this concern into their technical and financial assistance.

5.23   Question 24: Use of European know-how in developing countries

Existing measures should be simplified and made more effective (CDM,JI) (7).

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5.24   Question 25: Possible negotiation of tariff or non tariff advantages within the WTO for energy efficient products

It is not very probable that the European Union will be able to make such measures acceptable within the WTO as such moves could be seen as being likely to discriminate against developing countries.

Brussels, 14 February 2006.

The President

of the European Economic and Social Committee

Anne-Marie SIGMUND

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(1)  Regulation (EC) No 2422/2001, OJ L 332, 15.12.2001.

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(2)  Directive 2002/91/EC, OJ L 001, 4.1.2004.

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(3)  Directive 2004/8/EC, OJ L 52, 21.2.2004.

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(4)  COM(2003) 739.

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(5)  Council Directive 2003/96/EC OJ L283 of 27 October 2003 restructuring the Community framework for the taxation of energy products and electricity.

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(6)  OJ C 108, 30.4.2004.

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(7)  (CDM=Clean Development Mechanism, JI=Joint Implementation).

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