Opinion of the European Economic and Social Committee on the Communication from the Commission — Action Plan for Energy Efficiency: Realising the Potential COM(2006) 545 final
Date: 2007-09-27
Institutions: European Economic and Social Committee
Subjects: energy consumption, energy policy, energy saving, energy supply, energy use, price of energy, sustainable development

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Opinion of the European Economic and Social Committee on the ‘Proposal for a Directive of the
European Parliament and of the Council on statutory plates and inscriptions for motor vehicles and
their trailers, and their location and method of attachment’

COM(2007) 344 final — 2007/0119 (COD)

(2008/C 10/07)

On 13 July 2007 the Council decided to consult the European Economic and Social Committee, under
Article 95 of the Treaty establishing the European Community, on the abovementioned proposal.

Since the Committee unreservedly endorses the proposal and feels that it requires no comment on its part,
it decided, at its 438th plenary session of 26 and 27 September 2007 (meeting of 26 September), with
165 votes in favour and 8 abstentions, to issue an opinion endorsing the proposed text.

Brussels, 26 September 2007.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

Opinion of the European Economic and Social Committee on the ‘Communication from the
Commission — Action Plan for Energy Efficiency: Realising the Potential’

COM(2006) 545 final

(2008/C 10/08)

On 19 October 2006 the Commission decided to consult the European Economic and Social Committee,
under Article 262 of the Treaty establishing the European Community, on the abovementioned communica-
tion.

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 5 September 2007. The rapporteur
was Mr Iozia.

At its 438th plenary session, held on 26-27 September 2007 (meeting of 27 September), the European
Economic and Social Committee adopted the following opinion by 145 votes to one with three abstentions.

1. Conclusions and recommendations

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.

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 condi-
targets between
tions, so as to ensure fair distribution of
Member States commensurate with each Member State's poten-
tial. 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.

In the light,

inter alia, of the recent IPCC (Intergovern-
1.2
mental 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

The EESC suggests to the Commission that a specific
1.3
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,

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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.

1.10
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.

1.5
The EESC recommends that priority initiatives be under-
taken, 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, develop-
ment 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 ener-
getics 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.

The EESC believes that

the EU's ability to present a
1.7
united front on energy efficiency in international relations needs
to be strengthened. To this end,
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.

recommends that

it

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.

financing of

The ESSC believes that

the necessary
1.11
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 beha-
viour at grass-roots level, with a widespread increase in knowl-
edge and awareness, will it be possible to achieve perceptible
results, given that the end users are actually the primary consu-
mers of energy. Energy use in residential buildings, private trans-
port and work activities depends directly on individuals. Educa-
tion 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 civilisa-
tion. 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 pollu-
tion and related climate change.

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 justifi-
ably concerned that, thanks to this lack of coordination, the
Commission document will be not nearly as effective as it could
have been.

1.13
The EESC stresses the successes achieved by the house-
hold 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).

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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
losses are reduced from over 10 % to 3 % of
transmission,
power every 1 000 km. Moreover, continuous-current transmis-
sion also has advantages in terms of people's exposure to elec-
tric and magnetic fields and eliminates the ELF electromagnetic
wave emissions associated with alternating-current transmission.

Given the excellent results being achieved in the area of
1.15
solar thermal power, the EESC alls on the Commission and the
Council to encourage and support the dissemination of this
technology.

to invest

The EESC endorses the Commission's goal of increasing
1.16
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
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 redu-
cing impact on the environment, and integrated more easily
into national grids as part of distributed generation develop-
ment. 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.

The EESC feels that

1.18
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.

ensuring,
feasible in both technical and production terms.

in particular, however,

that

they are sensible and

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 allo-
cation 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.

The EESC fully supports the incentives and financing
1.21
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 stake-
holders and encourage the European banking sector to partici-
pate 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 popula-
tion live.

that

The EESC regrets

the Action Plan overlooks
1.23
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 Euro-
pean Works Councils. Trade union organisations have a key role
to play in improving knowledge and awareness at both Euro-
pean and national levels, helping to disseminate best practices.

The transport sector has striven hard to reduce energy
1.19
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

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) L. Brown, www.earthpolicy.org and 2005 FAO Report.

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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 develop-
ment, 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. The Commission Communication

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 Communi-
cation 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 emis-
sions 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
approximately
the
by
EUR 100 billion.

savings

annual

fuel

of

2.3
The debate triggered by the Green Paper on Energy Effi-
ciency 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, transmis-
sion and transformation and in industry.

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 resi-
dential sector, thanks to wall and roof
improved
lighting and more efficient household appliances; while for
commercial buildings
in energy
management systems could bring savings of up to 30 %.

improvement

an overall

insulation,

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
reduction in energy intensity,
including the 20 % expected from the new measures proposed
i.e. 390 Mtoe, per year for the period 2005-2020)
(1,5 %,
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.

the overall

2.7
The Action Plan will provide benefits in terms of envir-
onmental protection, reduced imports of fossil fuel meaning less
dependence on third countries, and a more profitable, competi-
tive EU industry thanks, not least, to technological innovation
boosted by the processes set in motion, with positive employ-
ment effects.

The plan is structured around 10 urgent, priority actions,
2.8
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 distri-
bution losses in the energy transformation sector; and to adopt
a holistic approach for the transport sector.

The Strategic Energy Technology Plan, due to be

2.10
adopted in 2007, will spur further efficiency gains.

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.

2.11
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.

Looking at

2.5
savings are
possible in end-use sectors, including 25 % in the manufacturing

savings potential, beneficial

2.12
Energy efficiency issues need to be addressed at global
level and so international agreements and partnerships are
essential.

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Rigorous

2.13
implementation of existing directives and
regulations such as the recent Directive on Energy End-Use Effi-
ciency 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 Regu-
lation will help to achieve the expected goals.

Energy Service Companies. The Commission will call on the
banking sector
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.

to offer

2.14 The priority actions

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 appli-
ances. 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 applic-
able 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 regu-
lations 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
the matter, particularly in
congested areas.

to address

2.14.5
Facilitating appropriate financing of energy effi-
ciency investments for small and medium enterprises and

Spurring energy efficiency in the new Member
2.14.6
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 develop-
ment 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
the mayors of 20 of Europe's largest and most
together
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.

Conclusions

The Commission concludes its Communication by announcing
that a mid-term review will take place in 2009 and calling for
strong support from the Council, the European Parliament and
national, regional and local policy-makers.

3. General comments

The Commission's Action Plan takes a comprehensive
3.1
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 consump-
tion and make technically achievable savings of more than 20 %.

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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
It will be a
replaced as quickly and efficiently as possible.
historic
trends of
against
going
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.

challenge,

current

the

3.3.1
Responsibility for energy efficiency needs to be disse-
minated 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
to
sector
promoting energy efficiency so as to have the edge on interna-
tional 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.

too, which should anticipate the necessary shift

The Commission's plan should both reduce energy
3.3
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 envir-
onmentally-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):

— reducing use of resources and energy;

— preventing air, water and soil pollution;

— reducing waste at source;

— minimising risk for people and the environment.

(2) Factor Four: Doubling Wealth, Halving Resource Use. Ernst. U von

Weizsäcker, A.Lovins et al.

3.4
in four
The Action Plan identifies ten priority actions,
priority areas: energy conversion, transmission and distribution;
buildings for residential, commercial and professional use; trans-
port; 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.

to introduce measures to reduce fossil

3.5
The EESC suggests that a further priority action should
be added,
fuels for
heating and cooling, and notes that
the proposal does not
introducing district heating and
analyse the possibility of
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 ener-
gies 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, facili-
tating 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.

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3.6
The Commission proposal announces many legislative
measures, such as new directives and regulations, and the revi-
sion 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 enlarge-
ment 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.

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.

3.7
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 interna-
tional 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 strength-
ening 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 initia-
tives 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 direc-
tive'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.

3.10
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 infrastruc-
ture 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. Facili-
tating 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 inevi-
tably 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 strate-
gies 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 justifi-
ably concerned that, thanks to this lack of coordination, the
Commission document will be not nearly as effective as it could
have been

These problems affect

3.11
legislative
activity, communications and recommendations. The same diffi-
culties 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).

the Commission's

3.9
The implementation of the proposed measures will bring
savings leading to a drop in VAT revenue which could affect the

(3) TEN/276 — Transport in urban and metropolitan areas; rapporteur:

Mr Ribbe.

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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. Differentia-
tion 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.

The EESC feels that it is essential for awareness-raising
3.15
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 consul-
tants 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 effec-
tive 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 relo-
cate 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
in
be signed guaranteeing long-term,
exchange for commitments to invest in innovation, technology
or infrastructure in the fields of production, transport and distri-
bution. 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 moni-
toring capacity on the part of regional bodies and the intention
to replace them with binding undertakings if they prove ineffec-
tive.

stable energy prices

3.17
The measures identified must always take into account
the state of the market, which is becoming increasingly globa-
lised. 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 consis-
tently 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 relo-
cate 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 com-
munity,
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. Specific comments

The EESC will not discuss

each individual action
4.1
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 partici-
pants, which have enhanced the EESC's knowledge of the matter
and contributed substantially to its work.

Firstly,

4.2
the measures adopted thus far on dynamic
energy performance requirements for energy-using products,
buildings and energy services have yielded successful results.
Producers
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 wide-
spread education and awareness-raising on environmental issues

and consumers have

shown great

interest

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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 manufac-
turers that act ethically will not come to nothing and it must be
commended to the regional authorities responsible for its imple-
mentation.

also be ensured that initiatives funding the purchase of house-
hold 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
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.

‘bogus’

4.2.1
Labelling is a good practice, which should be encour-
aged 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 Commis-
sion 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 appli-
ances market.

Considerable savings are achievable in the building
4.2.3
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 (suffi-
ciency) and the basic consumption limit should also be indi-
cated, 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, Krons-
berg 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.

In the field of household appliances, because of the
4.2.2
lack of rapid procedures for verifying the accuracy of labels and
punishing abuse, there is a danger that well-intentioned enter-
prises 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 effi-
cient, obsolete appliances must be prevented from entering the
second-hand market in developing countries as well. It should

(4) Opinion on Energy-efficiency labelling for office equipment; rappor-

teur: Mr Voles.

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 harmo-
nise 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 build-
ings.

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4.2.4.1
Proper passive houses have to have certain construc-
tion 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 build-
ings 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 build-
ings that will be in use in 2020 are already in place now. As
regards rental property, the issue must be addressed of how to
in energy savings in residential
make large-scale investment
buildings financially viable for owners, given that
is the
tenants who usually derive the direct benefits.

it

3. To achieve the levels of energy use of passive houses
through better insulation, specific technical skills are needed
which are certainly not unobtainable. These principles
should be applied not only at the design stage but also,
most importantly, in the operating stage.

4. The applications for which energy is used meet users'
primary needs, and they are clearly not flexible: even sharp
variations in energy prices do not lead to equally sharp
behaviour changes in the short term. Limiting energy use or
looking for alternative energy sources are ex-post reactions
as people adjust to a new, long-term balance, but such steps
only bring a slight improvement in the elasticity of
the
energy demand curve.’

current

lowering the

(2002/91/EC),

In the Impact Assessment Report SEC(2006) 1175,
4.2.4.2
the Commission expects that savings of 140 Mtoe could be
made by amending the Energy Performance of Buildings Direc-
tive
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:

‘1. When upgrading the energy efficiency of existing buildings
— whether
residential, commercial or educational
purposes — it is not always possible to reach the target of
low energy-use buildings and passive houses.

for

2. To undertake this kind of operation an investment is needed
which could weigh heavily on an individual: the idea of even
the most potentially remunerative investment is likely to be
discarded when the financial means are not available.

(5) Article 15(2) of the Directive in question provides for a standstill period
of three years before it has to be fully applied, in cases where the
Member State can prove that there is a lack of qualified and accredited
experts. This gives Member States the option not only of postponing
the introduction of white certificates, but also of deferring checks on
boilers and air conditioning plant. It is thus unlikely that the Council
will be willing to reopen the matter before 2009 (and the Commission
itself confirms this); before the measures which are expected to bring
the hoped-for results can become effective, more years will have to pass
for a new directive to be adopted on the matter.

(6) ‘Comparison between assessment models for estimating the energy and
macroeconomic impact of the Passivhaus standard, Giulio Scapin —
Padua University — [2005-06]’, 30.05.2007, Tesi on line.it.

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 opera-
insulation of the whole of the building
tional point of view,
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 penal-
ties. Are these prerequisites in place in the potential European
white certificates market? The necessary caution should there-
fore be exercised in any potential dissemination of this practice.

Losses in the transformation phase are equivalent to total
4.3
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
is modern high-voltage, continuous-
warrants development
current transmission lines, where only 3 % of power can be lost
per every 1 000 kilometres of grid. As well as bringing consid-
erable savings, this technology eliminates the electromagnetic

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effects of alternating-current transmission such as ELF electro-
magnetic 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
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).

the world), while

for

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 commis-
sioned 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 tech-
nology developed by Enea, Archimede (Archimedes) produces a
constant
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.

flow of solar electricity. However,

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.

for harmonising calculation methods,

EESC supports the Commission's desire to develop high-effi-
ciency 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 time-
frames
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 provi-
sions 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.

for

4.3.4
The EESC calls on the Commission and the Council to
give more support to trigeneration programmes, which use resi-
dual heat for cooling as well. The COPs (coefficients of perfor-
mance), i.e. the ratio between output cooling energy and input
heat energy,
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.

4.3.3
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

(7) It should also be borne in mind that many of the transformers in use
contain what is considered to be one of the most harmful substances
for man: PCB (polychlorinated biphenyl), and replacement and decon-
tamination campaigns are under way. (It has been calculated that, in
Italy alone, about 200 000 out of 600 000 transformers use or have
been contaminated by PCB because of its excellent heat insulation
qualities, as at the time of their large-scale use its extremely harmful
chemical and physical properties in the event of fire were not known.)
They should therefore be replaced.

The Committee advocates undertaking a campaign and
4.3.5
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.

(8) From Wikipedia: A specific area of cogeneration is trigeneration,
which, in addition to producing electricity, uses the waste heat energy
from transformation to produce cooling energy, or chilled water for air
conditioning or industrial processes, as well. Heat energy is trans-
formed into cooling energy by means of an absorption refrigeration
cycle, which works by changing the state of the coolant and using an
absorbent.

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4.4 Functioning of the market

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
legal separation of
connection to strengthen the concept of
businesses managing technical monopolies from those operating
under a system of free competition, as provided for by the direc-
tives 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.

The sector's pricing policy should foster energy effi-
4.4.2
ciency 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 manage-
ment of grid load. According to Enel (the largest Italian electri-
city provider), which supplied its 30 million clients with elec-
tronic 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 proble-
matic in a number of respects in terms of procedures for oper-
ating 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.

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 respon-
sibility 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 emis-
sions 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
it
reduce harmful emissions. This incongruity suggests that
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 recom-
mended by the Cars 21 High Level Group. European manufac-
turers 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.

The EESC points out that large-scale substitution of
4.5.2
fossil fuels for biofuels would entail the risk of placing fuel
production in competition with food production as regards allo-
cation 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 coun-
tries in the northern hemisphere of agricultural resources which
Iowa's
could save millions of
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).

lives in the developing south.

4.5
The transport sector has striven hard to reduce energy
use and pollutant emissions, but it is right to call for a further

(9) L. Brown, www.earthpolicy.org, and 2005 FAO report.
(10) TEN 286 — Progress in the use of biofuels; rapporteur: Mr Iozia.

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and

voluntary

agreements

The EESC notes that the Commission is both encoura-
4.5.3
ging
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 agree-
ments can have advantages over regulation. They can be imple-
mented 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 develop-
ment investment. The EESC agrees with the Commission's state-
ment
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
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.

instead of

4.6
The EESC fully supports the incentives and financing and
tax strategies proposed by the Commission, in particular invol-
ving 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 stake-
holders and encourage the European banking sector to partici-
pate 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 energy
suppliers. The role of regional authorities as ‘impartial’ channels
conveying information to the public must be stressed. Wide

authorities, manufacturers

and local

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 quali-
ties 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
important cities is too unambitious. The
Europe's 20 most
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
is
awarded to a small
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.

Italian municipality: Varese Ligure)

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 devel-
oping energy-savings policies. The EESC calls on the Commis-
sion to take steps to encourage the incorporation of environ-
mental 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 there-
representatives to be
fore absolutely essential
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.

for workers'

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

15.1.2008

EN

Official Journal of the European Union

C 10/35

health hazards, such as fine particles, which are now creating an
emergency situation in many European towns. The dissemina-
tion of best practices, such as not using carbon in printers, and
other initiatives, helps to raise awareness and create positive atti-
tudes towards sustainable policies.

ACP, Euromed and ENP programmes. International cooperation
is essential if we are to successfully achieve sustainable develop-
ment, 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.

4.8
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

Brussels, 27 September 2007.

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
energy consumption and
resulting greenhouse gas emissions, thereby helping to reduce
overall consumption.

electricity production,

their

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS

Opinion of the European Economic and Social Committee on the ‘Proposal for a Directive of the
European Parliament and of the Council on airport charges’

COM(2006) 820 final — 2007/0013 (COD)

(2008/C 10/09)

On 1 March 2007, the Council decided to consult the European Economic and Social Committee, under
Article 80(2) of the Treaty establishing the European Community, on the abovementioned proposal.

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 5 September 2007. The rapporteur
was Mr McDonogh.

At its 438th plenary session, held on 26 and 27 September 2007 (meeting of 26 September 2007), the
European Economic and Social Committee adopted the following opinion by 143 votes to 2 with
2 abstentions.

1. Recommendations

assistance according to circumstances. Aid is quite common in
public transport.

1.1
The Commission should lay down design criteria for
various types of airport to ensure that they are practical, func-
tional and can be commercially justified where costs are recov-
ered through airport charges.

The State should pay for security at airports. This is a

1.2
national security problem.

The construction and operation of

regional airports
1.3
should be encouraged. They play a vital role in the economy of
the regions. They also relieve congestion at major airports and
often lend valuable assistance to Search and Rescue operations.

1.5
The Commission should lay down design criteria for
airport processors (e.g. Check In, Passenger Search) and then
consider the impact of regulation change on these key processor
dynamics and the associated impact on resource levels and costs
to operators to continue to achieve Service Level Agreements
and in particular airline turn around time criteria.

1.4
Airports have to be considered as a basic public utility
that do not necessarily make money and may need financial

The Commission should recognise the scale of charges
1.6
required to achieve compliance at the smallest airport where the
passenger volume may not support the economics of the busi-
ness.