EN    EN EN 
EN    EN  EUROPEAN COMMISSION 
Brussels, 8.3.2011 
SEC(2011) 280 final 
  
COMMISSION STAFF WORKING DOCUMENT 
  
SUMMARY OF THE IMPACT ASSESSMENT  
 
Accompanying document to the 
  
COMMUNICATION FROM THE CO MMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMI TTEE OF THE REGIONS 
  
European Energy Efficiency Plan 2011 
    
{COM(2011) 109 final} 
{SEC(2011) 277 final}  
EN 2   EN Europe can reduce its primary energy use by 20 % in 2020 simply by applying cost-effective1 
energy savings measures. This would make the EU's economy more competitive and create 
jobs and new business opportunities. EU citizen s would pay less on their energy bills, 
reducing the number of fuel- poor households. Energy efficiency  also means better use of 
energy resources and reduced import depe ndency. Less energy use also means less CO 2 and 
other harmful emissions, less impact on the ecosy stem, and better quality  of life for people. 
Energy efficiency and savings benefit the EU eco nomy as a whole, Member States, businesses 
and private individuals. 
1. WHAT IS THE PROBLEM ? 
At the Spring Council 2007, th e EU Heads of States a nd of Governments stressed 'the need to 
increase energy efficiency in the EU so as to achieve the objective of saving 20% of the EU's 
energy consumption compar ed to projections for 2020'2.  
However, the EU is not on track  to fully realize these cost-effective energy savings. The 
PRIMES 2009 energy efficiency scenario shows a break in the trend towards ever increasing energy demand but the reduction in consumption re lative to previous proj ections will still be 
only about 9% in 2020. Therefore, if the EU does not double its efforts  on energy efficiency, 
it will not reach its 20% target and will not realize all the asso ciated benefits for the economy, 
society and environment.  
The causes of insufficient progress are market failu res (such as insufficient price signals, split 
incentives, asymmetric information, missing or in complete markets and high initial costs) and 
regulatory failures (such as lack of comprehe nsive policy frameworks, poor enforcement and 
low level of ambition). The reboun d effect is another challenge that, however, is difficult to 
address at EU level as it relates to beha viour and the free choice of individuals. 
2. E
XISTING POLICIES ARE INSUFFICIENT  
To tackle the above limitations and reap the benefits of energy efficiency a number of 
policies have been adopted at EU and national level .  
The Energy Efficiency Action Plan (EEA P) of 2006 provided a comprehensive policy 
framework, listing 85 measures, at the EU level that has led to the adopt ion of more than 20 
legal measures and numerous soft-law initiatives. Assessment of the EEAP has shown that the majority of the measures have been comple ted or are in progress of implementation. The 
EEAP has fulfilled its objective of  being an important driver for the adoption of ambitious 
policies at EU, national and local level. Howe ver, the EEAP was not designed to achieve the 
full energy savings potential and becaus e of this its updating is needed. 
A number of policies were also adopted by Member States but these will not be sufficient to 
close the gap. The first National Energy Effici ency Action Plans (NEEAPs), submitted as an 
                                                
 
1 For example, Fraunhofer ISI et al.  2009: Study on Energy Savings Potentials in EU Member States, 
Candidate Countries and EEA Countries; Action Plan for Energy Efficiency: Impact Assessment SEC(2006) 1174; Lechtenböhmer and Thomas, Wuppertal Institute. 2005: The mid-term potential for 
demand-side energy ef ficiency in the EU. 
2 7224/1/07 REV 1. 
EN 3   EN obligation under the Energy Services Directive,  give a good account of many of the policies 
that Member States have set to realise their energy efficiency and savings potential3. The 
Commission's evaluation of the NEEAPs revealed the progress attained in each Member State. It concluded that even though many NEEAPs alr eady contain coherent and 
comprehensive strategies for the achievement of  intermediate and overall targets, some show 
piecemeal thinking with a scattering of fr agmented energy efficiency measures.  
3. EU
 HAS AN IMPORTANT ROLE  
The EU's right to act as regards energy efficien cy and savings is institu ted in the Treaty on the 
Functioning of the European Union, Article 194( 1). Although much res ponsibility rests with 
Member States, the EU's right to act has been esta blished because of the importance of 
energy efficiency and savings for realizing the EU's  climate change, security of energy 
supply, competitiveness and enviro nmental protection objectives . Tackling these 
objectives requires coordinated action and cohe rent energy efficiency and savings policy. 
Therefore, the EU has a role in: 
– Setting minimum requirements in areas where there is a risk of internal market distortions 
if Member States take individual measures.  
– Establishing a common framework which crea tes the basis for coherent and mutually 
reinforcing mechanisms while leaving in being th e responsibility of Member States to set, 
in a transparent and comparable way, the concrete levels that are to be met.  
– Creating a platform for exchanging best pr actices and stimulating capacity building.  
– Using EU instruments to promote energy ef ficiency, e.g. through  financing, and to 
mainstream it into the other policy areas.  
– Promoting the EU internationally as a forerunner in the area – an activity that is also 
beneficial for EU businesses.  
4. MAIN POLICY OBJECTIVES  
The general EU policy objective, as set by EU leaders, is to increase energy efficiency in the 
EU so as to achieve the object ive of saving 20% of the EU's energy consumption compared to 
projections for 2020, as estimated by the Commission in its Green Paper4 on Energy 
Efficiency. This objective is c onsistent with the EU's overall energy policy. Increased energy 
efficiency is an essential element of the new European Energy Strategy 20205. 
                                                 
3 Originally the NEEAPs were due in mid-2007 but many were delayed and were submitted by mid-2008 
4 COM(2005) 265: P rimary energy savings amounting to 370 Mtoe in 2020 compared to a baseline 
scenario projecting the level of primary energy consumption. The baseline was updated in 2007 to take 
account of two new Member States.  
5 COM(2010) 639. 
EN 4   EN More generally, energy efficiency contributes to broader initiatives to achieve climate change 
policy objectives and to stimul ate economic recovery and smar t, sustainable and inclusive 
growth, as outlined in Europe 2020:  A strategy for smart, sust ainable and inclusive growth6.  
5. ANALYTICAL APPROACH  
The aim of this IA was to analyze the achievements and challenges  of existing policies and 
the trends in energy consumption and assess whether there are possibilitie s for additional 
action at EU level .  
The analysis was proportionate to the foreseen le vel of detail of the po licy document itself. As 
the concrete measures will be developed in the future and will be accompanied by impact 
assessments when needed, the evaluation was done mainly in qualitative terms. However, 
quantitative examples of similar policies or gene ral calculations of the possible impacts were 
presented where possible.  
The analysis discussed, first, which is the best way to approach energy efficiency at EU level 
and, second, what types of EU policy instrument s are needed to support  Member States in 
realizing the savings potential.  
Three main policy alternatives were analyzed : (i) setting only targ ets and leaving it to 
Member States to develop the policy mix needed ; (ii) no targets, but developing detailed EU 
policy instruments, inviting Member States to implement and/or supplement them; (iii) a comprehensive policy framework at Member St ate level (including obj ectives/targets), while 
the EU develops policy instruments to support Member States. 
Afterwards for each sector (i.e . the residential and tertiary, transport, industry and energy 
sectors) various types of policy instrument s were analyzed (i.e. voluntary, regulatory, 
financing, awareness and training) in order to identify whether their ap plication at EU level 
would be needed for the specific policy objectives for the sectors to be met. The selection of 
the best options was based on the progress achie ved by the existing policies and on evaluation 
of the remaining barriers, the EU value added, possible impact, effectiveness, efficiency and 
coherence.  
6. C
ONCLUSIONS : PREFERRED NEW POLICY FRAMEWORK  
Preferred general policy approach 
It is essential that a coherent policy mix is developed at Member State level with clear, simple 
and measurable objectives. Well coordinated m easures at EU level could provide Member 
States with the needed framework on which to further develop their e fforts. The Commission 
could propose individual measures for each  sector that would provide for a common 
framework and also support Member Stat es in developing th eir own tools.  
This approach would lead towards the realization of the cost-effective potential and address 
major barriers such as policy fragmentation,  lack of political commitment and policy 
                                                 
6 COM(2010) 2020. 
EN 5   EN predictability. It would ensure  that the possible synergies be tween the various policies are 
explored.  
The Commission could in additi on study the best approach to  objective setting and the 
interaction of such objectives with other policy instruments (e specially climate targets). It 
could propose the establishmen t of NEEAPs as a key documen t. A strengthened and extended 
(to all supply and demand sector s) National Energy Efficiency Action Plan could give high 
political visibility to energy efficiency and drive the process. Furthermore, in order to increase 
the engagement of local authorit ies it is suggested that the su ccessful model of the Covenant 
of Mayors supported by the Commission is con tinued to keep it growing and realising its 
potential. 
Preferred way forward for the re sidential and services sectors 
The analysis concluded that to address the challe nge of insufficiently high renovation rates of 
buildings further strengthening of the current policy framework on buildi ngs (Option A3a) is 
not necessary as the recent modification of th e legislative framework (especially of the 
Energy Performance of Buildings Directive) is  already ambitious and the focus should be on 
its implementation. This is not the case for pr oduct requirements. To increase the uptake of 
energy efficient products, the scope of Ecode sign and Energy Labelling could be further 
extended to cover more product groups, especially  in the tertiary sector, and also some 
construction materials (e.g. windows) (Optio n A3b). This would further support the 
establishment of markets for energy efficient products and materials. 
Measures on financing would be essential to tackle the serious limitations on the availability 
of liquidity for high upfront costs and also to some extent the landlord-tenant problem. The 
limited financial resources at EU level could be particularly targeted at providing technical 
assistance to Member States and local authori ties but also provide ri sk-sharing and project 
guarantee support (Option A4a). With the economic crisis it cannot be expected that 
significant additional public funds would be dedicat ed to energy efficiency  and it is therefore 
essential that these instrument s aim at better engagement of third party financing. Measures 
that could further support the engagement of private investors are energy savings obligation 
on energy utilities (Option D3d) and support for the development of energy service companies 
(ESCOs) Option D5). Furthermore, the in troduction of certain energy efficiency 
conditionalities for public funding support is  considered benefi cial (Option A4b). 
The persistent lack of a qualified building workforce due to the unde veloped character of 
markets is recognised as one of the main non- technological and non-finan cial barriers to the 
deployment of optimal energy renovations or inst allation of appliances in buildings. It could 
be tackled at EU level by supporting Member St ates with tools (e.g. development of national 
qualification roadmaps, education and traini ng curricula, accreditation and certification 
schemes) and creation of platforms on the exchange of best practices. 
Additionally measures on awaren ess raising (A5) and increas ed voluntary engagement of 
private entities (Option A2) would be benefi cial and could be implemented, if there are 
sufficient resources as the EU has a limited role  and such measures w ould remain mainly in 
the domain of Member States or local authorities.  
Preferred way forward for the transport sector 
The projected growth in the transport sector's energy consumption up to 2020 is the highest of 
any sector. To realize the rema ining potential support is need ed for the transformation of 
EN 6   EN transport towards more efficient vehicles , modes and usages. However, because the 
forthcoming Transport White Paper will give fu rther impetus to the increased decarbonisation 
and resource efficiency of the sector, no options were analyzed in the IA.  
Preferred way forward for the industry sector 
Even though industry has experienced the highest  energy efficiency improvements, still some 
potential remains. EU policies have alread y partially addressed some of the possible 
environmental impact of the sector. Therefore, the objective as regards the industry sector is 
to support the use of this untapped potential while remaining coherent  with existing policy 
instruments (e.g. Emissions Trading Scheme  (ETS) and the new Industrial Emissions 
Directive). The barriers in th e sector are mainly a lack of  strong price signals, lack of 
awareness and training (especiall y for SMEs), and also a lack of long-term policy planning 
which increases the perception of risk and de ters companies from realizing investments. 
The analysis of the possible approaches conclude d that further legal inst ruments that would be 
in line with the above-men tioned objective and existing polic y could be developed (Option 
C3). To this end, more implementing measur es under the Ecodesign Directive could be 
proposed that would cover commonly used produc ts in industrial pro cesses (such as large 
pumps or furnaces). Custom-made equipment and systems could be addressed with generic energy-efficiency requirements to be operationa lised though standards. In addition, certain 
energy management requirements (e.g. energy audits) could be established for large energy consumers. For SMEs, information toolkits  and assistance to manage their energy 
consumption could be provided (Option C5).  
Important mobilization of projects in the indu stry sector could come from energy savings 
obligations, if imposed on energy companies (Option D3d) and the promotion of ESCOs 
(Option D5).  
Measures on awareness raising (Option C4) a nd increased voluntary engagement of private 
entities (Option C2) would be also beneficial a nd could be implemented if there are sufficient 
resources. Still, the EU has limited role and su ch measures remain mainly in the domain of 
Member States or local authorities.  
Preferred way forward for the energy sector 
At present, the average efficiency of the gene ration capacity is considerably lower than best 
available technologies. The main reason for this is  the lack of sufficien tly strong price signals 
in relation to investment decisions for the cons truction of new capacities and the retirement of 
old ones. The ETS in its third phase will have a certain impact on this problem for the units it 
covers. Therefore, it not appropriate to pr opose further regulatory instruments without 
knowing its concrete effects (Option D3a). Ho wever, with the growing number of small 
generation installations, the need for further regulatory instruments to ensure their high 
efficiency could be studied.  
The full potential for residual heat use or ener gy recovery is also not  used. The analysis 
showed that further regulatory measures fo r the promotion of cogeneration and district 
heating and cooling units could be developed following further analysis and possible revision 
of the main policy framework in the area (i.e . the Co-generation Directive) (Option D3b). 
National Regulatory Authorities (NRAs) could play an importa nt role in steering energy 
efficiency improvements of the grid, promoting smart grids and promoting intelligent 
EN 7   EN metering systems that ensure peak shaping pos sibilities and optimization of energy demand 
and supply. This could be done by conferri ng more powers on them (Option D3c).  
Energy companies dispose of important inform ation about the energy consumption of their 
clients but have no stimuli to us e it for reducing their clients' energy consumption as this 
would mean fewer revenues for them. This c ould be overcome by the introduction of energy 
savings obligation schemes which would ensure that for a small short-term increase of the 
energy bill the most cost-effec tive long-term measures will be  realized (Option D3d). The 
best methods of doing this need to be studied in  further detail. In orde r not to have negative 
interactions with the ETS the certificates that prove energy re ductions should not be traded 
within the ETS. 
Usually the managers of energy companies are well aware of the possibilities for energy 
savings at their companies. However, the spec ific subsector that w ould require additional 
support in terms of information, guidelines and ex change of best practices is that of ESCOs 
(Option D5). Voluntary agreements could also le ad to energy savings and could be considered 
(Option D2). 
Will the measures be sufficient to reach the 20% objective? 
The preferred options provide for a wide range of supporting instruments that would intensify 
the uptake of the energy savings potential and the related benefits, and the maturing of the 
energy efficiency markets. Quantification was not possible for all options but from those that could be quantified it can be concluded that there is good chance that the remaining savings 
gap will be closed. However, the concrete results will depend on the level of ambition of the regulatory and non-regulatory initiatives and the pace at which they are implemented. 
Therefore, mid-term evaluation and possible updati ng of the Plan would be essential to ensure 
that there are continuous e fforts on energy efficiency.