Opinion of the European Economic and Social Committee on the Communication from the Commission to the Council and the European Parliament on a first assessment of national energy efficiency action plans as required by Directive 2006/32/EC on energy end-use efficiency and energy services — Moving forward together on energy efficiency COM(2008) 11 final
Date: 2008-09-17
Institutions: European Economic and Social Committee
Subjects: ESC opinion, EU Member State, action programme, energy consumption, energy policy, energy saving, project evaluation, public awareness campaign

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Official Journal of the European Union

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Opinion of the European Economic and Social Committee on the ‘Communication from the
Commission to the Council and the European Parliament on a first assessment of national energy
efficiency action plans as required by Directive 2006/32/EC on energy end-use efficiency and
energy services — Moving forward together on energy efficiency’

COM(2008) 11 final

(2009/C 77/14)

On 23 January 2008 the Commission decided to consult the European Economic and Social Committee,
under Article 262 of the Treaty establishing the European Community, on the

Communication from the Commission to the Council and the European Parliament on a first assessment of national
energy efficiency action plans as required by Directive 2006/32/EC on energy end-use efficiency and energy services —
Moving forward together on energy efficiency.

The Section for Transport, Energy, Infrastructure and the Information Society, which was responsible for
preparing the Committee's work on the subject, adopted its opinion on 16 July 2008. The rapporteur was
Mr Iozia.

At its 447th plenary session, held on 17 and 18 September 2008 (meeting of 17 September), the European
Economic and Social Committee adopted the following opinion by 142 votes to six with three abstentions.

1. Conclusions and recommendations

In several

recent opinions on energy efficiency in
1.1
general (1) and energy efficiency in buildings in particular (2), the
European Economic and Social Committee has expressed strong,
almost unanimous support for a serious policy on energy effi-
ciency.

1.2
The EESC deplores the failure of the Member States to
produce their national energy efficiency action plans (NEEAPs)
on time. The EESC also regrets that, with a few exceptions, the
documents analysed do not demonstrate a strong and serious
commitment by the Member States to achieving these objec-
tives. This is particularly true in the main areas of energy
consumption: private transport and housing.

1.3
Only two Member States met the deadline for notifica-
tion, a further 15 were between two and six months late, two
presented their plans when the Commission's assessment had
already been completed and the remaining eight did so even
later. It was not until early April 2008 that all the plans were
ready, ten months after the original deadline.

The EESC notes that

the savings resulting from the
1.4
energy efficiency plans under the Commission's programmes are
supposed to make the main contribution to reducing green-
house gases. The target of reducing energy consumption by 20 %
in 2020 includes a reduction in CO2 emissions of 780 Mteq.
Given that UE emissions amounted to 5 294 Mteq for the
EU-25 in 2006 (European Environment Agency Report 2006),
it
that energy efficiency can make an invaluable
is clear
contribution.

1.5
The EESC notes that, in order to prevent world tempera-
tures rising by more than 2 °C, the concentration of greenhouse
gases (currently around 425 ppm of CO2 eq by volume) will

(1) CESE 242/2006, rapporteur: Mr Buffetaut and CESE 1243/2007,

rapporteur: Mr Iozia.

(2) CESE 1338/2007, rapporteur: Mr Pezzini.

have to be kept well below the limit of 550 ppm (3). Given that
the concentration increases by 2-3 ppm every year, stabilising it
at 450 ppm could offer a 50 % probability of meeting the target
of limiting the increase in average temperature to less than 2 °C.

There were glaring differences in the way the Member
1.6
States produced their plans. The NEEAPs ranged in length from
13 pages to 221 pages, making it virtually impossible to draw
any comparisons. Many were produced only in the national
language, making them difficult
to understand. The EESC
recommends the adoption of a model like the one produced as
part of the EMEEES project (Evaluation and Monitoring for the
EU Directive on Energy End-Use Efficiency and Energy Services)
in conjunction with the Wuppertal Institute for Climate Envir-
onment and Energy.

1.7
The Member States have, for example, reached agreement
with the EEA on a model for the National Inventory Report.
The EESC believes that the same procedure could be adopted
here, provided that the model could be made more flexible by
using specific appendices for each field (housing, transport, etc.).

The EESC believes that

1.8
the instrument of voluntary
agreements with national operators is useful, but it should be
clear from any agreements approved that failure to meet the
targets will result in the imposition of compulsory standards.

The Commission is already taking a number of measures,
1.9
which were announced back in 2006, to make energy savings
compulsory and plans to follow Australia's example and phase
out incandescent light bulbs which use 90 % of their energy to
produce heat and only 10 % to produce light. The EESC hopes
find ways of cutting the price of
that manufacturers will

(3) Parts per million.

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that government

fluorescent bulbs,
in the EU
Member States will promote their larger-scale manufacture, that
energy-saving bulbs will become more durable and compact and
that problems with their recycling can be solved.

institutions

1.10
The next EEA report, due to be published by the end of
June 2008, will show that there was a reduction in greenhouse
gases between 2005 and 2006 of 35.8 Mteq of CO2. Interest-
ingly, the main contribution to this has come from private
houses and offices, which have achieved savings of 15.1 Mteq.
Production of electricity and heating, on the other hand,
showed an increase of 14 Mteq. Despite the reduction, the
report shows that the UE-27 achieved an improvement of less
than 0.5 % compared with 1990, and certain Member States
need to step up their efforts.

1.11
The liberalisation of the energy market could accelerate
energy savings because production and distribution systems
with different levels of efficiency will face one another in the
market, which could potentially stimulate research and invest-
ment to reduce waste. Over 30 % of energy is lost at the gener-
ating stage alone. In a recent opinion (4) the EESC backed the
Commission's proposals on the third energy package, aimed at
creating an effective European energy market.

that

The EESC firmly believes

1.12
room for
improvement and more needs to be done. It would like more
details about the Commission's conclusions on completion of
its assessment of the national action plans and wishes to be
given the opportunity to express its own opinion on the
outcome of this assessment.

there is

1.13
The EESC has repeatedly called for the involvement of
civil society in Europe and the Member States, on the grounds
that the full knowledge and support of the European public are
essential if the targets for energy efficiency are to be met. The
recommendations coming from civil society need to be given
serious consideration. The measures adopted must always take
into account the difficulties many millions of ordinary people
have in coping with the problems of daily life. Energy saving
programmes will inevitably entail costs and should provide for
carefully chosen measures and appropriate support for the less
well-off, who have to meet the costs of rising energy prices but
are unable to reduce their bills, for example because they cannot
afford energy-saving measures in the home.

The EESC insists that

the initiatives in the field of
1.14
energy efficiency must be specific and feasible and wonders
whether at least some of the measures should be made compul-
sory, with checks to determine how far the practical results fall
short of the plans, as was the case with vehicle emissions, the
CO2 reduction in general, greenhouse gas emissions and renew-
able energies.

The national action plans do not clearly specify what
1.15
measures and resources will be used to involve the final users in

(4) CESE 758/2008, rapporteur: Mr Cedrone.

a major European energy efficiency and energy saving plan. The
EESC has on several occasions drawn attention to the essential
role that organised civil society could play in identifying good
examples of information provision and the sharing of best prac-
tice. The EESC would like to discuss this issue with the European
institutions that do not seem to be particularly committed or
aware.

1.16
The EESC recommends that the European Commission
and the Member States set up a specific integrated monitoring
system of the sort used for water policies, for example. Such a
system is essential in view of the lack of information about and
assessment of the impact of the EU's energy efficiency policies
on final users (particularly SMEs) and the absence of any metho-
dology for verifying the consistency between international and
for monitoring the results
European targets or a process
achieved by these users.

In some sectors, such as social housing, the building
1.17
stock consists of very old and inefficient dwellings. More than
25 million homes require urgent and complex modifications.
The EESC hopes that plans will be launched to renovate public
housing with funding from the EIB. There is no mention of
such measures in the NEEAPs.

1.18
The EESC believes that market instruments, similar to
those already in operation, could make a valuable contribution.
Creating a market in ‘negawatts’, or electrical energy efficiency,
for final consumers as well could provide a useful incentive for
ordinary citizens to adopt good energy saving practices. Given
that replacing incandescent
light bulbs alone could produce
savings equivalent to at least 80 power stations of 1 000 MW
(almost equal to Italy's gross installed capacity), it is clearly in
the interests of producers to support energy efficiency, which
will enable them to satisfy more customers while generating the
same amount of electricity.

1.19
The EESC hopes that there will be a renewed positive
trend, that the Member States will take policy on energy effi-
ciency and energy saving seriously and that this will be reflected
in serious, credible and realistic national plans with measurable
objectives. An indication should also be given of the resources
which the Member States intend to devote to providing adequate
support for the investment by individuals and companies that is
required.

2. Introduction

In its Communication on the first assessment of national
2.1
energy efficiency action plans
entitled ‘Moving
forward together on energy efficiency’, the Commission fulfils
an obligation under Article 14(5) of Directive 2006/32/EC to
publish an assessment of
the 27 national action plans by
1 January 2008. The second report must be published before
1 January 2012 and the third before 1 January 2015.

(NEEAPs)

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2.2
The targets to which the Communication refers were laid
down in Article 4(1) of the Directive, which states that ‘Member
States shall adopt and aim to achieve an overall national indica-
tive energy savings target of 9 % for the ninth year of applica-
tion of this Directive, to be reached by way of energy services
and other energy efficiency improvement measures.’

The Commission reports that only two Member States
2.3
met
the deadline for notification (Finland and the United
Kingdom), while a further 15 notified plans late: Austria,
the Czech Republic, Cyprus, Denmark, Estonia,
Bulgaria,
Germany,
the Netherlands,
Italy, Lithuania, Malta,
Ireland,
Poland, Romania and Spain. Belgium and Slovakia submitted
their NEEAPs at the end of 2007, too late to be included in the
assessment.

3. The Commission Communication

It appears from the plans that five Member States have
3.1
set themselves more ambitious targets than those laid down in
the Directive, others have set much higher targets, but have not
made them official commitments. Of the 17 plans evaluated, six
did not cover the full period referred to in the Directive (i.e. up
to 2016). Examples of the exemplary role of the public sector
were found in Ireland, which has adopted a public sector
savings target of 33 % by 2020, Germany, which is committed
to a 30 % reduction in CO2 emissions for the public sector by
2012, and the United Kingdom, which is aiming for carbon
neutral central government buildings by 2012.

The report mentions a number of national campaigns,
3.2
such as Ireland's Power of One, which includes an internet site
for exchanging best practices between the public and private
sector, the use of energy audits in public buildings in Denmark,
with compulsory implementation of the resulting recommenda-
tions, Germany's major retrofit programme for its federal build-
ings which has a budget of 120 million euros, and the appoint-
ment in Malta of Green Leaders — officials in each ministry
responsible for energy efficiency and promoting renewable
energy.

3.3
The United Kingdom will apply the Code for Sustainable
Homes to all its housing developments, requiring all new homes
to comply with the Code's Level 3 — a 25 % energy perfor-
mance improvement compared to the 2006 building code.
Austria is working to make public buildings more efficient than
the legal requirements, while Spain plans to update public street
lighting systems with modern and more efficient equipment and
improve energy efficiency in the treatment and supply of
drinking water.

3.4
Poland and Finland will require the public sector to
achieve energy savings at a level at least equal to the national
level, while
target,

at municipal

achieved

already

as

the Netherlands aims to lead the field by ensuring that by 2010
100 % of national and 50 % of
local and regional public
procurement includes sustainable procurement criteria.

Tax incentives are felt

3.5
to be extremely important.
Germany and Austria are targeting energy efficiency in build-
ings, which account for 40 % of energy consumption, and
Lithuania plans to introduce a reduced rate of VAT (9 % instead
of 18 %) on publicly financed housing. The Netherlands plans
to offer an Energy Investment Deduction to private companies,
while Italy has introduced a gross tax deduction of up to 55 %
for the purchase of energy efficient consumer durables (A+ rated
refrigerators and boilers) and lighting equipment, and for energy
efficiency building refurbishment.

3.6
Voluntary agreements are seen as a useful tool, particu-
larly in Finland (in the period under review they covered around
60 % of final energy use and the aim is to reach 90 % by
2016), the Netherlands, where they apply mainly to businesses,
and Denmark which, by contrast, uses them for public procure-
ment. Spain, Poland, the United Kingdom, Romania and Ireland
plan to introduce voluntary agreements as a key instrument to
achieve energy savings.

3.7 Market-based instruments feature in the national plans of
a small number of countries. One example is Italy's white certifi-
cates scheme, which it plans to extend until 2014 and which
Poland intends to adopt. The United Kingdom's Energy Effi-
ciency Commitment will be extended until 2020. It has been
renamed the Carbon Emission Reduction Target and will have a
savings target almost double that for the period 2008-2011.
Several countries (particularly Austria, Germany, Ireland, Italy,
Poland and Spain) attach great importance to the Energy Service
fulfilled their
Companies
expectations.

(ESCOs), which have not

yet

3.8
Bulgaria, Romania and the United Kingdom are planning
to set up funds and funding mechanisms targeting the commer-
cial and residential sectors. Information, education and training
policies are not implemented in the same way by the national
energy agencies, which have different mandates; some countries,
like Denmark and Italy, have chosen to devolve these tasks to
regional and local agencies.

3.9
Transport, which accounts for over a third of energy
consumption, is seen as particularly important by many coun-
tries, but in practice only Austria and Ireland are proposing
specific measures to promote a modal shift to public transport.

3.10 Most of the plans presented adopt a ‘business-as-usual’
approach, and in several Member States there is a considerable
gap between the political commitment and the measures
adopted and resources allocated.

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3.11
In addition to closely monitoring the transposition of
the Directive, the Commission will try to facilitate its implemen-
tation by means of the Intelligent Energy Europe Programme. It
will launch a web-based platform to gather and present input
from stakeholders, who will be involved in supporting the
implementation of the Directive and, hopefully, contribute to
the adoption of national measures and the preparation of the
next NEEAPs. The national plans will be assessed as part of the
Energy Efficiency Watch project.

The Commission concludes by reiterating the impor-
3.12
tance of international cooperation and referring to its initiative
of setting up an international platform on energy efficiency to
help develop technical standards, trade and technology transfer.
The major challenges Europe faces and the responsibility it
wants to assume in the field of climate change, security and
sustainability of energy supplies, and reducing greenhouse gas
emissions require strong and effective programmes to improve
energy efficiency.

4. Specific comments

The first clearly negative aspect of this Communication is
4.1
that only two of the 27 Member States met the deadline for
presenting National Energy Efficiency Action Plans laid down in
the Directive. A further 15 managed to produce their conclu-
sions shortly thereafter and two countries submitted reports too
late for inclusion in the assessment, but there was no sign of
any report from the remaining eight. A year after the deadline
of 30 June 2007 one Member State has still failed to produce a
report.

The second negative element

4.2
to emerge from the
Commission's conclusions is that, with a few exceptions, the
documents analysed did not demonstrate the strong and serious
commitment that the situation demands. It is more and more
common for Heads of State and Government, representing the
Member States, happily to approve directives in Brussels which
they cannot or will not comply with when they get home. The
Lisbon Agenda is the most blatant example, but the books are
full of such contradictory behaviour. And there will no doubt be
more instances in future.

4.3
Reading the national action plans, one is struck by the
absence of any frame of reference and the lack of uniformity in
the format and content of the plans, which makes them difficult
the
to read and almost impossible to compare. As part of
EMEEES project (Evaluation and Monitoring for the EU Directive
on Energy End-Use Efficiency and Energy Services) carried out
in conjunction with the Wuppertal Institute for Climate Envir-
onment and Energy, a model was drawn up, precisely to facili-
tate the drafting of the national action plans. Belgium wrote a
letter complaining that this important model was not produced
until 11 May, just a few days before the deadline for submitting
the national plans.

4.4
The documents range from 13 pages for the Czech
Republic and Lithuania to 41 pages for Romania and 89 for
Malta, among the new EU Member States. In the case of the
large states, France's report was 37 pages, Germany's 102 pages,
Spain's 211 pages and the United Kingdom's 214 pages. As for
Belgium, because of its federal system it had to produce four
documents amounting to a total of 221 pages. The total
number of pages produced by 25 Member States (Sweden and
Portugal do not yet appear on the Commission site) was 2 161,
all with different data, tables and measures. Each country chose
its own reference parameters, methodologies and means of
communication: the result is discouraging because it is impos-
sible to identify any trend.

The material published by France, Slovenia, Greece
4.5
(a draft only),
the Netherlands and Luxembourg is in the
national language (making it impossible for the rapporteur to
read). It is extremely difficult for any exchange of best practice
to take place when documents have to be read in their original
language, but
let alone
required, to use a single language for their submissions. The
Commission has translated all of
the documents into one
language, but the delays in submitting the NEEAPs have had
repercussions on the translation schedule.

the Member States were not asked,

4.6
The EESC would stress the contrast between the objec-
tives of the national plans and the two factors referred to here.
Neither encyclopaedic plans nor summaries help us to under-
stand exactly where a country is heading. Excessive detail and
excessive conciseness both have the same effect of making a
report difficult to read and understand. The EMEES model could
be a happy medium between the two extremes. The EESC
strongly recommends that for the next round of national plans
a common model be adopted that is easy to read and compare.

4.7 With a few commendable exceptions, mentioned in this
opinion, the EESC is disappointed by the serious lack of initia-
tives in the public sector and agriculture. The NEEAPs have little
or nothing to say about these highly important sectors.

5. General comments

5.1
In January 2007 the Council asked the Commission to
take measures in the field of energy and climate change to meet
ambitious targets. These targets were laid down in the third
the renewable energy and climate change
energy package,
package, the Directive on reducing CO2 emissions from new
cars, the new Energy Star Regulation, the Green Paper on urban
mobility, which includes incentives for efficient vehicles, and the
Strategic Energy Technology Plan.

5.2
These measures contain a few recommendations and a
large number of rules. However, having formally approved the
measures, the governments are incapable of resisting the pres-
sures from national industry and standing by the choices they
have made. They then call for changes in policies which they
have collectively agreed, as in the case of CO2 emissions.

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5.3
The reason why the Member States do not seem to be
too concerned can be found in the Directive itself. Recital 12
specifically states that
‘Even though Member States commit
themselves to making efforts to achieve the target figure of 9 %,
the national energy savings target is indicative in nature and
entails no legally enforceable obligation for Member States to
achieve it.’

(19 October 2006), but
the legislation and guidelines were
premised on relatively low oil prices. When the Directive was
presented,
the price of oil was hovering around
USD 42 per barrel, while the average price in 2006 was just
under USD 62.

in 2004,

of

This

type

(directives

5.4
containing
legislation
non-binding objectives without penalties in the event of non-
compliance) was typical of the legislative initiatives taken in a
particular period and in certain specific fields. Until very
recently the Member States insisted on their own sovereignty in
matters of energy choices, energy supplies, production and
distribution. This led to the sort of ‘soft law’ which characterised
the period in question. The Biofuels Directive (2003/30/EC) set
quantitative targets, but
imposed no specific obligation to
achieve them.

In these circumstances and under such conditions the
5.5
target of achieving a 20 % reduction in consumption by 2020,
by increasing energy efficiency, will be extremely difficult to
meet unless stringent additional measures and/or objectives are
adopted.

5.11
In this context it was understandable that the targets
were indicative and that the Commission did not include in the
Directive a firm obligation on Member States to meet them. As
the EESC once wrote: ‘the best energy is unused energy’, but if
the Member States,
energy-saving is left to the goodwill of
without any incentive other than their own conscience, the
target becomes problematic or simply impracticable.

5.12
But can the European Union afford not to meet the
targets of reducing energy intensity by 1.5 % per year? Not to
save 390 Mtoe which produce 780 Mt of CO2? On the one
hand, clear and ambitious targets are being set for reducing
greenhouse gas emissions by 20 % and meeting 20 % of our
energy needs using renewable sources, while on the other, the
most directly attainable target, which would bring an immediate
saving, is downplayed and treated like a hypothetical aspiration.

5.6
The EESC has supported and will continue to support all
initiatives aimed at achieving an ever higher level of energy effi-
ciency, in the belief that CO2, emissions and the EU's energy
dependency are two issues of major importance.

5.13
The EESC notes that in some countries implementation
of the plans is devolved to the regional governments, without
proper coordination. This means in practice that there is a lack
of harmonisation and consistency between regions.

At

the same time,

the EESC notes the contradiction
5.7
between general non-binding measures and specific measures
aimed at achieving the result, which are binding. Why is the
whole not binding but the individual parts are? The Commis-
sion itself should set a good example by making public the
energy efficiency and energy savings achieved in its own build-
ings, the initiatives it has undertaken and the funding that has
been allocated. An appendix giving the ‘federal’ viewpoint would
help readers to understand the importance of such policies.

5.8
The EESC emphasises the wide disparity between the
publicised expectations about the adoption of measures capable
of significantly improving energy efficiency and the generally
disappointing and unambitious proposals presented by the
Member States, and reiterates the need for practical measures in
the short, medium and long term to give substance to the
declared objectives.

5.9
If this is the conclusion reached, the EESC urges the
adoption of measures capable of achieving the objectives rather
the sort made on other
than a purely cosmetic gesture of
occasions.

The EESC welcomed both Directive 2006/32/EC of the
5.10
European Parliament and of the Council of 5 April 2006 on
energy end-use efficiency and energy services, and the subse-
quent Action Plan for Energy Efficiency: Realising the Potential

The EESC deplores the lack of real choice on the supply
5.14
side and believes greater choice should be provided, coupled
with incentives for less well-off groups, and especially for consu-
mers and small and medium-sized businesses, in order rapidly
to achieve the desired results. In some countries incentives have
produced very encouraging results, for example in the case of
white goods.

5.15
The EESC considers the experience with ESCOs to have
been a success and is in favour of making such services more
widely available to the public and businesses. New professions,
new opportunities for skilled employment, benefits in the area
of energy efficiency and greenhouse gas reductions are just
some of the positive aspects of these services.

The EESC insists that the Member States are not doing
5.16
enough to meet the targets that have been set and is convinced
that, as in the case of transport emissions, the Commission's
initiatives need to be supported, where these seek to place
the
stricter obligations on the Member States. Last year
Commission took several positive initiatives,
including i) the
new Energy Star Regulation, the standards of which have now
become compulsory for public procurement for office equip-
ment;
ii) the Green Paper on urban mobility, which suggests
funding for more energy-efficient vehicles; iii) the third energy
package, which increases the powers of the national regulators
in the area of energy efficiency; iv) the Strategic Energy Tech-
nology Plan and v) the Regulation on emissions by new cars.

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5.17
Other measures are planned for the coming months.
These range from new directives on energy-efficiency require-
ments and green labels for a wide range of products (such as
public street lighting and office lighting, minimal consumption
standby and off modes) to the new regulations, expected in
2009, on televisions, domestic fridges and freezers, washing
machines and dishwashers, boilers and water heaters, personal
computers, imaging equipment, electric motors, heat pumps and
air conditioners. Also in 2009, the Commission plans to adopt
a proposal to promote the rapid replacement of domestic incan-
descent light bulbs. The revision of the directive on car labelling,
and tyre efficiency and systems for constant monitoring of tyre
pressure and quality will be at the heart of the new transport
policies.

5.18
The EESC believes it is essential to create an internal
energy market in which prices are the result of healthy competi-
tion, in line with the Directives on electricity and gas.

5.19
The EESC highlights the need for the EU Member States
to produce training plans for schools (which will then actively
have to pursue energy efficiency programmes), as well as
communication campaigns to raise public awareness of
the
energy-efficient
importance of
consumption.

and need for

responsible,

5.20
A particularly interesting initiative in the educational
field has been the organisation of a number of competitions in

Brussels, 17 September 2008.

which technical institutes compete to achieve the biggest energy
savings with the active involvement of
the students. For
example, in Italy the project ‘datti una scossa’, which offered a
prize of up to EUR 25 000 for putting the proposal into prac-
tice, proved highly successful; another example is the interna-
tional eco marathon in which a French institute presented a
prototype vehicle that travelled 3 039 km on one litre of petrol!
A team from Denmark succeeded in producing a combustion
engine emitting 9 g/km to win the Climate Friendly Award.

5.21
The economic instruments that are available in the
future will have to be effective and sustainable in the long term.
The EESC believes that particular attention should be paid to
the distribution of the incentives, which should be aimed at
final consumers. Consideration should also be given to the case
for reserving part of
the incentives for the energy service
supplier, thereby creating a common and convergent interest in
energy efficiency policies.

5.22
In order to give customers proper price signals that will
promote more rational and efficient energy use, the EESC urges
the Commission to clamp down on predatory pricing, taking
into account what is allowed under European legislation in the
area of proper promotion of renewable energies and preserving
the provisions for vulnerable consumers laid down in the gas
and electricity Directives.

The President

of the European Economic and Social Committee

Dimitris DIMITRIADIS