COMMISSION STAFF WORKING DOCUMENT   IMPACT ASSESSMENT  ANNEX I Accompanying document to the   COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS COMMISSION STAFF WORKING DOCUMENT   Energy Efficiency Plan 2011     COM(2011) 109 final SEC(2011) 277 final
Date: 2011-03-08
Institutions: European Commission
Subjects: consumer, energy consumption, energy policy, energy saving, energy transport, financial aid, impact study, innovation

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COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 8.3.2011 
SEC(2011) 278 final 

COMMISSION STAFF WORKING DOCUMENT 

IMPACT ASSESSMENT 

ANNEX I  

Accompanying document to the 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 
COMMISSION STAFF WORKING DOCUMENT 

Energy Efficiency Plan 2011 

COM(2011) 109 final 
SEC(2011) 277 final 

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ANNEX I  

REPORT ON THE PUBLIC CONSULTATION  

ON 

EVALUATION AND REVISION OF THE ACTION PLAN FOR 
ENERGY EFFICIENCY 

In line with the Commission's commitment to transparent and interactive policy-
making, this documents aims at providing an overview and general impression of 
the feedback provided to the Commission in the context of a public consultation. 
The statements and opinions expressed in the document do therefore in no way 
necessarily reflect those of the Commission or the Commission services. 

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Table of contents 

1. 

1.1. 

1.2. 

2. 

2.1. 

2.2. 

2.3. 

3. 

4. 

4.1. 

4.2. 

4.3. 

4.4. 

4.5. 

4.6. 

4.7. 

4.8. 

4.9. 

Context and Process ..................................................................................................... 6 

Context and purpose..................................................................................................... 6 

Process and timing ....................................................................................................... 6 

Background information about the respondents .......................................................... 7 

Individual respondents ................................................................................................. 8 

Number of participants for each type of organisation responding............................... 8 

Type of private sector/association responding............................................................. 9 

General opinion about the current Energy Efficiency Action Plan and its revision .... 9 

Specific questions....................................................................................................... 10 

Introduction ................................................................................................................ 10 

The promotion of energy efficient buildings ............................................................. 11 

Transport .................................................................................................................... 13 

Product policy ............................................................................................................ 14 

Financing.................................................................................................................... 16 

Fiscal incentives ......................................................................................................... 18 

Education and Training .............................................................................................. 19 

Awareness of consumers and SMEs .......................................................................... 20 

SMEs .......................................................................................................................... 21 

4.10. 

Public sector ............................................................................................................... 22 

4.11. 

Energy utilities ........................................................................................................... 23 

4.12. 

Incentives for SMEs to enter the energy efficiency market....................................... 25 

4.13.  White certification scheme......................................................................................... 25 

4.14.  Binding targets ........................................................................................................... 27 

4.15.  Measurement and verification.................................................................................... 28 

4.16. 

International cooperation ........................................................................................... 29 

5. 

Final remarks.............................................................................................................. 29 

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Executive Summary 

At  the  Spring  Council  2007,  the  EU  Heads  of  States  and  Governments  stressed  the  need  to 
increase energy efficiency in the EU so as to achieve the objective of saving 20 % of the EU's 
energy consumption compared to projections for 20201. However, evaluations suggest that the 
energy saving potential is not being realised fast enough and the measures adopted so far can 
only  achieve  energy  savings  of  about  11%  by  2020,  if  properly  implemented  by  Member 
States.  

On  19  October  2006,  the  Commission  adopted  the  Action  Plan  for  Energy  Efficiency: 
Realising the Potential (EEAP)2. As announced in the Plan, the Commission is to prepare in 
2009  a  revised  Action  Plan,  as  requested  by  the  European  Council.  In  this  regard  a  Public 
Consultation on the Evaluation and Revision of the Energy Efficiency Action Plan was launched 
on 8 June 2009 with a deadline on 3 August 2009. 

This report presents the results of the public consultation on the Evaluation and Revision of the 
Energy Efficiency Action Plan. This public consultation was also held in order to receive input 
for the New Energy Efficiency Action Plan planned to be adopted by the end of this year.   

There  were  203  submissions  to  the  on-line  public  consultation,  173  organisations  and  30 
individuals.  In  addition,  6  submissions  via  email  were  sent  to  the  Commission  by 
organisations which did not make use of the web-based interface to reply to the questionnaire.  

Overall, 173 organisations, the 30 individuals and the additional submissions have generally 
acknowledged that the measures in the current Energy Efficiency Action Plan should continue 
to be implemented. However, the majority of the stakeholders argued that the time had come 
for a more focused and targeted approach in order to promote energy efficiency further.  

The topics highlighted to be targeted were energy efficiency of buildings, access to financing, 
energy  efficiency  both  on  the  supply  and  demand  side  for  SMEs  and  a  better  use  of  the 
Structural and Cohesion funds with regard to energy efficiency projects.  

It was also pointed out that the new Energy Efficiency Action Plan should recognise the role 
of  the  local  politicians  in  the  delivery  of  energy  efficiency  in  Europe.  The  Covenant  of 
Mayors was mentioned to be a successful policy instrument to bring energy efficiency policy 
to  local  level.  Several  stakeholders  were  also  of  the  opinion  that  cogeneration  and  district 
heating planning had to be further promoted since  the existing legislation  had  not given  the 
correct  incentives  to  develop  these  policy  areas  satisfactorily.  White  certificates  were 
mentioned  as  an  instrument  that  could  give  the  correct  incentives  in  this  regard.  However, 
there  seemed  to  be  a  general  reluctance  for  a  unified  EU  wide  Certification  Scheme  to  be 
introduced.  

The majority of stakeholders welcomed binding targets on energy efficiency, however, there 
were  some  divergent  views  on  which  parameters  to  use  as  a  base  for  the  methodology  and 
verification for measuring energy efficiency.  

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7224/1/07 REV 1. 
COM(2006) 545. 

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Energy efficiency was also argued to be a global issue and not only a policy for Europe. A 
reference  was  made  to  that  several  countries  like  United  States  and  Japan  had  already 
launched  efficiency  programmes.  Several  stakeholders  pointed  out  that  it  was  therefore 
crucial that Europe from a competitiveness aspect did not miss opportunities in the timing of 
developing an energy efficient economy.  

Finally, it was also emphasised by numerous stakeholders that the different legal instruments 
should  not  overlap  or  be  conflicting.  The  Commission  should  endeavour  to  synchronise  the 
different frameworks on energy efficiency for optimal effect on the market with due regard to 
avoiding any distortion of the internal market. 

A  broad  range  of  ideas  for  possible  actions  were  put  forward  by  respondents.  This  report 
explores the feedback in more details. The policy conclusions drawn by the Commission will 
be set out in an official communication and not addressed in the present report. 

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1. 

CONTEXT AND PROCESS 

1.1. 

Context and purpose  

At  the  Spring  Council  2007,  the  EU  Heads  of  States  and  Governments  stressed  the  need  to 
increase energy efficiency in the EU so as to achieve the objective of saving 20 % of the EU's 
energy consumption compared to projections for 20203. However, evaluations suggest that the 
energy saving potential is not being realised fast enough and the measures adopted can only 
achieve energy savings of about 11% by 20204, if properly implemented by Member States5. 
This progress is very unsatisfactory and more actions need to be taken in order to address the 
remaining challenges and reap the potential savings. 

On  19  October  2006,  the  Commission  adopted  the  Action  Plan  for  Energy  Efficiency: 
Realising  the  Potential  (EEAP)6.  It  gave  an  outline  for  a  coherent  framework  of  legislation, 
policies and measures with a view to save a substantial part of the 20% of EU annual primary 
energy  consumption  by  2020.  It  proposed  a  selection  of  cost-effective  energy  efficiency 
improvement  initiatives  to  be  put  in  place  and  implemented  until  2012.  As  announced  in  the 
Plan,  the  Commission  is  to  prepare  in  2009  a  revised  Action  Plan,  as  requested  by  the 
European Council.  

To explore possible policy options, several meetings were held with stakeholders. However in 
order  to  obtain  an  even  wider  input  for  the  New  Energy  Efficiency  Action  Plan,  a  public 
consultation  on  the  current  Action  Plan  was  launched  on  8  June  2009  with  a  deadline  on  3 
August  2009.  Public  authorities,  businesses,  non-governmental  organisations,  citizens  and 
other  interested  parties  were  asked  several  questions  with  regard  to  the  current  Energy 
Efficiency  Action  Plan  and  whether  there  were  to  be  suggested  additional  measures  at  EU 
level in order to further promote energy efficiency. A list of all contributions is to be found in 
Annex I to this report. 

1.2. 

Process and timing 

The  consultation  consisted  of  a  questionnaire  in  English  with  structured  questions, 
supplemented  by  open  "free  text"  questions  where  participants  could  provide  feedback  not 
captured in the structured part. The on-line questionnaire and the background document can 
be  found  in  Annex  II  and  III  to  this  report.  Moreover,  the  Commission  will  publish  the 
submissions that answered affirmatively to be published on-line.  

The  public  consultation  complied  with  the  Commission's  minimum  consultation  standards, 
including  the  8  week  minimum  duration.  The  standard  Commission  internet  tool  for 
Interactive  Policy  Making7  was  used.  As  participation  was  voluntary  and  based  on  self-
selection, the views expressed by respondents are not necessarily representative of the views 
held by all stakeholders or citizens.  

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7224/1/07 REV 1. 
The latest estimates, forthcoming Impact Assessment Report on the new Energy Efficiency Action Plan.  
COM(2008) 772. 
COM(2006) 545. 
http://ec.europa.eu/yourvoice/ipm/index_en.htm  

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2. 

BACKGROUND INFORMATION ABOUT THE RESPONDENTS 

In all, 203 responses from individuals and organisational participants were received through 
the IPM tool (the on-line questionnaire).  

Number of requested records  Requested records (203) 
173 

85.2% 

Representative of an 
organisation 
Individual citizen 
30 
Total number 
203 
Tab. 1 Total number of respondents 

14.8% 
100% 

A few other responses, 6 submissions, were submitted by organisations which did not make 
use of the web-based interface to reply to the questionnaire. The statistical data in this report 
refer only to responses made by the 203 responses submitted through the IPM tool. However, 
the  views  in  all  the  submitted  responses,  including  those  submitted  without  using  the  IPM 
tool, have been considered by the Commission services.  

2.1  Organisations responding 

Organisation Participants

50

48

45

40

35

30

25

20

15

10

5

0

30

16

11

9

9

8

8

7

5

5

4

4

4

3

2

2

2

2

2

1

1

1

1

1

1

0

0

0

Fig. 1: Number of organisations responding per country of residence 

Most  responses  were  received  from  organisation  representing  EU  as  a  whole,  followed  by 
Germany,  France,  Netherlands  and  Austria.  Moreover,  there  were  two  contributions  from 
Switzerland. 

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2.1. 

Individual respondents 

In  all,  30  responses  from  individuals  were  received.  The  replies  came  from  citizens  from 
Austria,  Belgium,  Czech  Republic,  Denmark,  France,  Germany,  Ireland,  Italy,  Lithuania, 
Malta, Netherlands, Romania, Slovakia, Spain, Sweden and UK (in alphabetical order). The 
number cannot be seen as representative for the citizens of EU, but the Commission services 
welcome  these  submissions  since  energy  efficiency  is  a  policy  highly  concerned  with  the 
citizens of the EU. 

2.2. 

Number of participants for each type of organisation responding 

Number of requested records

82

90

80

70

60

50

40

30

20

10

0

24

17

16

15

13

3

2

1

0

0

Industry and private
sector, incl. their
associations, excl.
SMEs

Non-governmental
organization

OTHER

Member States or public
body
(national/regional/local),
incl. Regulators

Energy utility

Small and Medium Size
Enterprises (SMEs)

Consumer organization

University/
education/research
institute

Financing organization European institution or

body

Energy Efficiency
Agency (national,
regional, local)

Fig. 2: Number of participants for each category of organisations 

The  largest  single  fraction  of  responses  was  from  private  sector  companies  or  industry 
associations.  The  second  largest  fraction  of  the  submissions  was  from  non-governmental 
organizations. 

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2.3. 

Type of private sector/association responding 

100

94

Number of requested records

85

72

68

61

44

31

90

80

70

60

50

40

30

20

10

0

Energy Efficiency
services in the
residential sector

Energy Efficiency
services in the
tertiary and industry
sectors

Energy-using
products and
appliances

Energy production,
supply,
transmission or
distribution

Construction

Transport sector

Other

Fig. 3: Type of private sector companies or industry associations that responded 

Within  the  fraction  of  private  sector  companies  or  industry  associations,  the  largest  single 
group  was  from  companies/organisations  dealing  with  energy  efficiency  services  in  the 
residential sector, in the tertiary and industry sector. However, also industry related to energy-
using  products,  energy  utilities  and  construction  were  highly  represented  in  the  received 
submissions.  

3. 

GENERAL OPINION ABOUT THE CURRENT ENERGY EFFICIENCY ACTION PLAN AND 
ITS REVISION 

As a first and general question the public consultation asked whether the 6 key areas and 85 
actions  in  the  current  Energy  Efficiency  Action  Plan  should  be  continued,  redefined, 
discontinued  and  if  so  the  public  consultation  enquired  for  the  underlying  reasons  for  the 
suggested modifications.  

Several  stakeholders  made  reference  to  the  global  economical  crisis.  Moreover,  numerous 
stakeholders were concerned because of the climate change. Concern was also raised of the 
increasing import dependence of Europe and in this regard the security of supply of energy. 
Energy Efficiency was therefore concluded to be a good political response to the economical 
crises by creating job opportunities. Energy Efficiency could also mitigate climate change and 

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security of supply by using the energy in Europe smarter and more efficiently. On the aspect 
of  mitigating  climate  change  and  also  security  of  supply,  it  was  emphasised  by  several 
stakeholders that it was of importance to find the optimal balance between energy efficiency 
and renewable energy policies.  

On how to best promote energy efficiency, the overall majority stated that the measures in the 
current Energy Efficiency Action Plan should continue to be implemented. However, several 
stakeholders argued that the time had come for a more focused and targeted approach in order 
to promote energy efficiency further. Some of the topics that were highlighted in this regard 
were  the  energy  efficiency  of  buildings  and  particularly  energy  efficiency  of  the  existing 
building stocks. Another topic often referred to as significant was financing but also to create 
the awareness of the existing opportunities of access to finance for energy efficiency projects. 
Several  stakeholders  pointed  to  the  fact  that  the  Structural  and  Cohesion  funds  should  be 
further used to promote energy efficiency in the different Member States. In this regard it was 
suggested that the new Energy Efficiency Action Plan should recognise the role of the local 
politicians  in  the  delivery  of  energy  efficiency  in  Europe.  The  Covenant  of  Mayors  was 
mentioned to be a successful policy instrument to bring energy efficiency policy to local level 
and to "think globally but act locally". 

A lot of the stakeholders were of the opinion that cogeneration and district heating planning 
had  to  be  further  promoted.  The  existing  legislation  had  not  given  the  correct  incentives  to 
develop these policy areas satisfactorily.  

Energy  efficiency  was  also  argued  to  be  a  global  issue  and  not  only  a  policy  for  Europe. 
Several  countries  like  United  States  and  Japan  had  already  launched  several  efficiency 
programmes. It is therefore crucial that Europe from a competitiveness aspect does not miss 
opportunities in the timing of developing an energy efficient economy.  

It was also emphasised among several stakeholders that the different legal instruments should 
not overlap or be conflicting. The Commission should endeavour to synchronise the different 
frameworks on energy efficiency for optimal effect on the market with due regard to avoiding 
any distortion of the internal market. 

4. 

SPECIFIC QUESTIONS 

4.1. 

Introduction 

Following  the  general  question,  the  public  consultation  also  put  forward  several  specific 
questions.  The  specific  questions  consisted  of  a  questionnaire  in  English  with  structured 
questions,  supplemented  by  open  "free  text"  questions  where  participants  could  provide 
feedback  not  captured  in  the  structured  part.  This  report  will  provide  the  statistical  data 
regarding the structured questions. For the open "free text" questions the submissions will be 
generally  described  with  certain  direct  references  to  some  of  the  suggestions  in  the 
submissions. 

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4.2. 

The promotion of energy efficient buildings  

The questionnaire  contained a question regarding whether more could be done on buildings 
besides  the  existing  Energy  Performance  of  Buildings  Directive  (2002/91/EC).    Out  of  the 
203 contributions, 154 (75.9 %) submissions were of the opinion that more could be done in 
order to further promote energy efficiency in buildings. 24 (11.8 %) of the submissions stated 
that they were not in favour of additional measures and 25 (12.3 %) of the contributions did 
not have any opinion in this regard. Concerning energy efficiency in buildings there were 3 
open "free text" questions. The first question was how to assess the need to move towards a 
requirement  that  all  new  buildings  have  low  or  zero  energy  consumption  and  carbon 
emissions after a certain date. The second question was addressing the need for introducing at 
EU  level  measures  concerning  training  of  architects,  builders  and  installers.  The  third 
question related to which other measures at EU level need to be undertaken.   

Concerning the first question there was a majority in favour of developing buildings of low or 
zero energy consumption and carbon emissions after a certain date. Furthermore, the majority 
were  of  the  opinion  that  the  main  challenge  was  to  promote  energy  efficiency  in  existing 
buildings.  A holistic approach was argued to be the best way to proceed with due regard to 
district heating and renewable energy. There were also different views on how to define low 
or zero energy consumption and carbon emissions  buildings. Some stakeholders argued that 
the  CO2  aspect  was  the  key  issue,  while  others  were  proponents  of  only  relating  the 
definitions  to  primary  energy  consumption.  Some  stakeholders  also  referred  to  the  different 
climate  between  the  Northern  and  Southern  part  of  Europe  which  should  also  be  accounted 
for when deciding  on  the development of buildings of low or zero energy consumption and 
carbon emissions.  Furthermore, there were divergent statements regarding setting the date for 
implementation of such a policy. There were also voices for taking due regard to and preserve 
the cultural heritage contained in some of the existing buildings of Europe.  

Examples  of  stakeholder  feedback  on  that  all  new  buildings  will  have  low  or  zero 
energy consumption and carbon emissions after a certain date: 

•  "The  setting  of  such  requirement  is  important  for  the  launch  of  construction  and 
reconstruction of buildings in the best available standards in the short and medium term. 
Facing  the  need  to  tackle  the  climate  change  and  the  rising  energy  prices,  the  savings 
potential in buildings ought to be exploited". (A Ministry of Environment in one of the 
Member State of EU) 

•  "In steps of about three years the standard should be developed: for example in Germany: 
EnEV  2009,  EnEV  2012,  EnEV  2015  (passive  house  standard),  EnEV  2018  zero 
emission standard". (Organisation for architects) 

•  "Each  year,  new  buildings  represent  about  1%  of  the  buildings  stock.  This  very  small 
percentage  should  feature  the  latest  technologies  in  terms  of  energy  efficiency  and 
renewable  energies  to  ensure  that  new  buildings  make  the  EU  less  dependent  on 
imported,  expensive  and  scarce  energy.  Indeed,  Plus-Energy  Buildings  and  Net  Zero 
Energy  buildings  are  crucial  for  security  of  supply  reasons.  Decisions  taken  now  will 
have a crucial impact on the future landscape of the European building stock…. Existing 
buildings should not fall out of the scope of the EU scrutiny: the refurbishment rate of 
existing buildings is very low in the European Union and furthermore, Europe has a large 
stock  of  historic  buildings  which  are  far  away  from  being  energy  efficient.  If  the 
European Union takes the threat of climate change seriously, it needs to address existing 
buildings. The recast of the Energy Performance of Buildings’ Directive should provide 

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the  first  opportunity  to  set  targets  for  existing  buildings  to  become  net  zero  energy 
buildings by 2018". (Organisation for promoting renewable energy) 

Concerning  the  second  question,  the  majority  welcomed  the  idea  of  introducing  measures 
concerning training of architects, builders and installers. However, several stakeholders were 
of the opinion that this was best pursued by the Member States due to the different structures 
of  the  sector  across  EU,  and  the  range  of  institutions,  professional  bodies  and  educational 
bodies involved in the training in the different Member States. Nevertheless, the stakeholders 
expressed that EU had a role to play for facilitating action on training through for instance EU 
programmes such as the Intelligent Energy Europe. The EU could also assist concerning the 
exchange  of  best  practises,  but  also  facilitate  for  the  mutual  recognition  of  qualifications 
between  Member  States.    Some  stakeholders  made  reference  to  Annex  IV  of  the  Directive 
2009/28/EC on the promotion of the use of energy from renewable sources and that a similar 
annex  could  be  adopted  for  the  Energy  Performance  Directive  on  Buildings  (2002/91/EC). 
Reference  was  also  made  to  the  American  system  where  architects  must  maintain  their 
certification by earning a number of credit points from mandatory courses. Such courses can 
be  arranged  by  the  government,  institutional  and  private  actors  under  the  approval  of  an 
authority. 

Examples of stakeholder responses on introducing at EU level measures concerning 
training of architects, builders and installers: 

•  "While  training  activities  are  a  largely  national  competence,  the  Commission  does 
have  a  leadership  role  to  play  in  spreading  best  practice  and  providing  finance  to 
stimulate  such  activities.  The  EU  should  ensure  mutual  recognition  of  training 
programmes  across  Europe  as  well  as  harmonised  accreditation  of  inspectors  and 
assessors. European funds could also be used to finance training activities at national 
level". (Industry organisation for energy efficiency services) 

•  "The operatives on construction sites who actually install energy efficiency materials, 
products  and  components  must  be  fully  aware  of  the  need  for  those  items  to  be 
installed  to  a  high  level  of  workmanship  and  with  a  high  level  of  care.  Bringing 
assistance to relevant institutions and associations that can quickly fill the training and 
education  gaps  is  one  tool  that  could  significantly  assist  in  improving  the  energy 
efficiency of buildings in the medium term". (Organisation for architects)  

•  "Optimal  outcomes  in  the  built  environment  will  only  be  possible  if  builders, 
installation  companies  and  architects  are  provided  with  all  the  relevant  training  and 
information  they  need  to  make  an  optimal  decision  about  which  solution  is  most 
suitable  for  the  building  in  question.  Unless  training  is  addressed  and  offered  in  a 
timely fashion, it is widely feared that it will be a key barrier". (Association for micro-
generation) 

On the third "free text" question on what other measures at EU level should be adopted for the 
promotion  on  energy  efficiency  in  buildings,  several  ideas  for  further  measures  were 
suggested.  One  suggestion  that  several  stakeholders  referred  to  was  the  need  for  further 
promotion  of  cogeneration,  district  heating  and cooling.  It  was  stated  that  the  existing  legal 
instruments  did  not  give  the  necessary  incentives  for  these  technologies  to  achieve  their 
potential.  Furthermore,  smart  metering  should  be  rolled  out  in  different  Member  States  in 
order to help consumers to save energy. ICT was also argued by several stakeholders to be an 
important instrument for the promotion of energy efficiency. It was also argued that buildings 

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when  sold  should  have  to  reach  a  certain  standard  of  energy  efficiency.  A  Smart  City 
Campaign for Buildings was also envisaged to be launched by the EU. 

Examples of stakeholder responses on introducing further measures at EU level: 

•  "Possible measures could introduce an obligation to upgrade the energy performance 
of  a  building  whenever  it  is  sold  or  rented  up  to  a  certain  standard  (for  example 
obligation  to  reach a higher energy class of the  energy performance certificate or to 
renovate according to very low energy standards), and an obligation on countries to at 
least double their renovation rates of existing buildings. To make this approach more 
flexible,  it  could  be  possible  to  set  different  targets  for  different  type  of  buildings 
(public buildings, commercial buildings, and residential buildings) or for buildings of 
different  ages,  for  example  by  initially  focusing  only  on  buildings  built  after  1945. 
Adequate financing is crucial to ensure the success of any policy intending to improve 
the energy performance of existing buildings.  Financing  should  not only come  from 
national  sources  through  fiscal  and/or  financial  incentives  but  the  use  of  available 
funds from other sources should be optimized (EU structural and cohesion funds, use 
of  auctioning  revenues  under  the  EU  ETS).  In  addition,  an  energy  performance 
contracting  model  needs  to  be  promoted  in  order  to  increase  refurbishment  rates  in 
existing buildings". (NGO) 

•  "The  requirement  that  all  new  buildings  and  major  renovations  be  equipped  with 
intelligent  metering  systems  is  rational  and  necessary.  This,  however,  must  be 
reconciled  with  the  smart  metering  requirements  in  the  3rd  Energy  Package". 
(Industry) 

•  "ICT  can  play  an  important  role  in  making  buildings  more  energy  efficient,  and  its 
role should be recognised as such. Public procurement (for public buildings) is a tool 
that  may  be  used  for  encouraging  innovative  ICT  solutions  to  reduce  energy 
consumption of building". (Industry)  

•  "The  European  Commission  could  launch  an  “Energy  Smart  Building”  Campaign. 
This  campaign  would  aim  at  stimulating  the  market  for  energy  efficiency  and 
renewable  energies  in  buildings  and  would  be  implemented  via  national  campaigns, 
for instance by national energy agencies and/or ministries, in strong connection with 
cities.  ………  It  is  estimated  that  at  least  150  000  jobs  will  be  newly  created  in  the 
Energy  Smart  Buildings  sector  in  the  coming  years,  which  will  become  one  of 
Europe’s job-motors. The proposed stimulus would largely benefit SMEs involved in 
the  energy  efficiency  and  renewable  energy  sectors".  (European  Renewable  Energy 
Industry Association) 

4.3. 

Transport 

The  public  consultation  addressed  also  energy  efficiency  in  transport.  93  (45.8%)  of  the 
submissions were in favour of additional measures on energy efficiency at the EU level in the 
transport sector, while 22 (10.8%) were opposed to further measures. 88 (43.3%) submissions 
did not have any opinion in this regard.  

Most  of  the  stakeholders  in  favour  of  additional  measures  on  energy  efficiency  in  the 
transport sector welcomed the electrification of the transport sector for cars, buses, rail, motor 
cycles,  scooters  and  mopeds.  It  was  argued  that  the  current  Emission  Trading  Scheme  is 
penalising the rail sector. Even though the aviation will be included, stakeholders argued that 

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only 15% of the allowances in this regard will be auctioned and the rest will be transferred to 
the  aviation  sector  free  of  charge.  As  railways  are  affected  by  ETS,  the  other  modes  of 
transport  that  have  higher  emissions  were  argued  to  receive  a  competitive  benefit.  Another 
concern raised in the public consultation regarding transport was a request for a more robust 
regulation on CO2 emission for vans. There were also proponents who argued that legislation 
should not only be concerned with the concrete CO2 emissions, but also the efficiency of the 
car as such. A reference of importance in this regard was the weight of vehicles. Eco-driving 
was another measure suggested to be launched at the EU level. The use of a bicycle, but also 
the city planning of facilitating increased number of cyclists, was also stated to be an efficient 
measure to reduce significantly CO2 emissions. 

Examples of stakeholder responses relating to transport: 

• 

• 

• 

"The  current  technology-based  approach  to  reduce  CO2  emissions  from  cars  needs  to  be 
supplemented  with  infrastructure  and  driver  behaviour  related  measures,  as  is  the  case  in 
other  sectors.  In  this  respect,  eco-driving  is  a  no-regret  measure  that  can  be  implemented 
rather  easily,  leads  to  solid  results  rather  quickly  and  can  contribute  to  fighting  climate 
change". (NGO) 
"The  transportation  sector  plays  a  central  role  in  the  European  economy  and  accounts  for 
almost 20% of the total European consumption of primary energy. 98% of the energy that is 
used in this sector is fossil fuel. It is therefore important that the energy consumption in the 
transportation  sector  is  made  efficient  and  that  new  fuel  sources  are  developed  for  this 
sector. The Electrification of the transportation sector, including promotion of electric cars, 
is  an  important  element  with  regards  to  making  the  energy  consumption  in  the 
transportation sector more efficient". (Energy utility) 
"The EU should provide different options to encourage technical development of hybrid and 
electrical  cars,  e.g.  funding  research  and  demonstration  projects,  contributing  fiscal 
measures such as tax incentives, heightening of public awareness to environmental issues. 
Other  measures  would  include  mandatory  targets,  removal  of  administrative  and  planning 
barriers and sharing best practices on the promotion of clean vehicles and intermodal shifts. 
Local authorities should be fully involved and engaged in making it attractive to utilize an 
electric car, free of charge batteries stands, less taxes, free parking spaces in the cities, etc. 
The EU should consider whether transport and the efficiency hereof should be regulated on 
equal terms as any other energy consumption and become part of the Directive for Energy 
end-use Efficiency and Energy Services". (Association of electricity industry in Europe)  

4.4. 

Product policy 

Stakeholders  were  also  asked  whether  they  were  in  favour  of  further  measures  in  order  to 
increase the impact of the Eco-design Directive (2005/32/EC) and Energy Labelling Directive 
(92/75/EEC). 110 (54.2%) of the submissions were in favour of further measures, 45 (22.2%) 
of the contributions were against additional measures, while 48 (23.6%) had no opinion in this 
regard.  

The  majority  of  the  stakeholders  expressed  satisfaction  with  both  the  Eco-design  Directive 
(2005/32/EC)  and  Energy  Labelling  Directive  (92/75/EEC).  However,  there  was  some 
concern  raised  regarding  these  two  Directives.  Several  stakeholders  argued  that  it  was  of 
significant importance that the labels for consumers were clear and not confusing. There had 

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been  to  many  labels  and  marks  discussed  in  recent  times.  Moreover,  there  were  some 
resistance for including further product groups in the near future because of the argument that 
there  is  still  a  lack  of  experience  of  the  adopted  implementing  measures  of  the  Eco-design 
Directive  (2005/32/EC).  However,  others  were  of  the  opinion  that  the  Eco-design  Directive 
(2005/32/EC)  should  set  stricter  requirements  and  a  faster  implementation.  It  was  also 
necessary  to  enhance  the  market  surveillance  in  this  regard  since  it  was  argued  that  this 
function  was  not  adequately  performed  by  some  Member  States.  Moreover,  there  were 
divergent views on voluntary agreements. Some submissions stated they were in favour while 
others argued that voluntary agreements were inefficient.  

It  was  also  argued  that  the  extended  scope  of  the  Eco-design  Directive  (2005/32/EC)  and 
Energy Labelling Directive (92/75/EEC) should not cover certain construction products. This 
should  rather  be  included  in  the  Energy  Performance  of  Buildings  Directive  (2002/91/EC). 
The reason for this was stated to be that the performance of construction products can only be 
assessed at the level of the functional unit, which is the building. Neither of the two directives 
provides a methodology as to how this could be achieved. The absence of such a methodology 
may distort competition, confuse markets and have a negative effect on market transparency. 
Even worse, the indicators would not provide a methodology to identify the most sustainable 
solution for a building over its whole life cycle. 

Several stakeholders expressed that it was of importance that the different legal instruments in 
place should not overlap or be conflicting but taken due account to when deciding on which 
legal  instrument  would  be  the  most  adequate  to  promote  the  energy  efficiency  aim  in 
question. 

Examples  of  stakeholder  responses  relating  Eco-design  Directive  (2005/32/EC)  and 
Energy Labelling Directive (92/75/EEC): 

• 

• 

"The energy and environmental performance of construction products can only be assessed 
at  the  level  of  the  functional  unit,  which  is  the  building.  Neither  of  the  two  directives 
provides  a  methodology  as  to  how  this  could  be  achieved.  The  absence  of  such  a 
methodology  may  distort  competition,  confuse  markets  and  have  a  negative  effect  on 
market  transparency.  Even  worse,  the  indicators  would  not  provide  a  methodology  to 
identify  the  most  sustainable  solution  for  a  building  over  its  whole  life  cycle.  All 
requirements  regarding  buildings  and  building  components  should  be  addressed  in  the 
EPBD". (Association for insulation in buildings and renewable energy) 
"The  impact  of  Eco-design  directive  could  certainly  be  increased  by  setting  stricter 
requirements and a faster implementation. In addition, two crucial elements should also be 
reinforced: market surveillance and a better coordination with existing legislation covering 
the  same  products  (i.e.  RoHS,  WEEE  and  EPBD).  In  order  to  safeguard  competitiveness 
among manufacturers and ensure European consumers’ rights, it is imperative that products 
subject to Eco-design requirements are properly verified before entering the EU market. At 
present,  market  surveillance,  organised  at  Member  State  level,  is  not  performing  this 
function  adequately;  therefore,  a  more  coordinated  approach  across  Europe  is  necessary. 
Ensuring a better integration of existing EU product-related regulation is another essential 
issue  when  developing  eco-design  requirements.  Although  avoiding  duplications  is 
important, making sure that no gaps or grey areas are overlooked is even more critical. For 
this reason where technically possible Eco-design measures for specific products should set 
more  ambitious  requirements  than  allowed  under  another  regulation  (i.e.  lower  mercury 

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levels than those allowed under RoHS could be applied for domestic lighting). When facing 
overlaps with existing legislation, implementing measures should be thoroughly designed to 
avoid  gaps  and  ensure  that  the  combined  potential  of  the  relevant  regulations  is  fully 
exploited.  For example Eco-design measures on heating and  cooling equipment  should be 
fully coordinated and integrated with the respective provisions in the Energy Performance 
of Buildings Directive, in particular those dealing with building components and systems. A 
bold approach on heating equipment could help save more than 200 million tons of CO2 in 
the EU-27 by 2020, one of the largest savings achievable". (NGO) 

4.5. 

Financing   

The public consultation also addressed the lack of access to appropriate financing which is an 
important bottleneck for further promoting energy efficiency. Various financing instruments 
are at present time being developed by different institutions such as the European Investment 
Bank  (EIB),  the  European  Bank  for  Reconstruction  and  Development  (EBRD),  national 
promotional  banks  and  private  banks  in  particular  in  association  with  the  Covenant  of 
Mayors.  Demonstration  projects  of  the  application  of  energy  efficient  technologies  in  a 
competitive  manner,  for  example  "smart  cities"  could  also  be  considered.  The  question  was 
therefore raised in the public consultation whether stakeholders thought that other financing 
measures at EU level are needed. 

135  (66.5%)  of  the  stakeholders  answered  confirmatively,  18  (8.9%)  responded  negatively 
and  18  (24.6%)  stakeholders  had  not  any  opinion  in  this  regard.  Several  stakeholders 
expressed that Structural Funds should be reformed with a strong focus on energy efficiency 
projects.  At the same time it was argued that the EU should facilitate that the current funding 
opportunities  under  the  Structural  and  Cohesion  Funds  were  properly  spent  by  encouraging 
Managing authorities to develop and promote energy efficiency projects in their regions.  

It was also stated by several stakeholders that there were numerous funding opportunities in 
place,  but  that  these  funding  possibilities  seemed  confusing  and  difficult  to  access  which 
discouraged participation. The Commission was therefore encouraged to facilitate a one-stop-
shop  procedure  to  remove  these  barriers  to  funding.  It  was  also  suggested  that  many  small 
scale  investments  should  be  linked  together  and  thereby  apply  for  financing.  Consequently, 
there would not only be access to finance for the large energy efficiency projects but also for 
smaller energy efficiency schemes.  

Up-front  financing  was  also  highlighted  to  be  of  significant  importance  by  several 
stakeholders. It was suggested that the EIB should lend money to specialised national energy 
efficiency funds which would provide up-front financing solutions to ESCOs and in particular 
SMEs.  Alternatively,  these  funds  could  provide  loan  guarantees  to  facilitate  lending  from 
private banks.  

Several  stakeholders  also  made  reference  to  the  importance  of  using  energy  performance 
contracts  (EPCs).  The  experience  of  KfW  in  financing  EPC  was  referred  to  as  a  successful 
funding  mechanism  in  this  regard. However,  apart  from  raising  the  awareness  in  the  public 
and  private  sector  of  EPC  it  was  also  pointed  to  the  need  of  addressing  accounting  and 
budgeting  rules.  Accounting  and  budgeting  rules  in  several  Member  States  were  stated  to 
prevent or discourage EPCs.  

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Some stakeholders also stated that there was a particularly need for enhanced investments in 
CHP  and  district  heating.  Furthermore,  investment  in  smart  grids  and  smart  metering  were 
also emphasised.  

There were also statements suggesting that the Member States should be strongly encouraged 
to use the auctioning revenues from ETS for energy efficiency projects. 

It  was  also  emphasised  that  due  regard  should  be  taken  to  fuel  poverty.  Finance  for  energy 
savings should not place a burden on consumers who already are facing the highest level of 
billing to their homes. 

It  was  further  suggested  that  not  only  "smart  cities"  projects  should  be  launched  but  also 
"smart industries" should be developed. There is increasing interest in the potential of having 
industries, including power stations, working in co-ordination to provide connected heat loads 
and use high efficiency cogeneration. Smart industry zones could be created encouraging the 
linking of industries together and maximizing the efficiency of electricity and heat delivery to 
the group, combined with distribution of heat to the local community and the commercial or 
agricultural zones. 

Examples of stakeholder responses relating to financing: 

• 

• 

• 

"The continued reinforcement of the use of the European Cohesion policy as a key tool in 
the  leverage  and  promotion  of  investment  aimed  at  reducing  the  environmental  impact  of 
the residential sector….. The revenues of the EU Emissions Trading Scheme should be used 
to  promote  energy  efficiency  and  renewable  energy  in  existing  housing  stock". 
(Organisation for social housing)  
"Tackling head-on the cost barriers which inhibit energy efficiency actions will bring about 
dramatic progress. Lower interest loans, with long pay back periods, and “pay as you save” 
schemes from the EIB in conjunction with national banks will help incentivise business and 
consumers  to  install  energy  efficiency  measures.  This  model  is  being  trialled  on  public 
buildings through the C40 large cities climate leadership group (with a major project being 
undertaken in London). Measures to guarantee energy savings as a basis for loan pay back 
helps  tackle  the  barriers  of  upfront  costs.  SMEs  in  particular  should  be  targeted  with  low 
interest loans as they often require extra support in the short term to overcome difficulties in 
accessing credit". (Industry organisation). 

"One of the main barriers is the current frame of mind of average investors  in building 
energy efficiency measures. Indeed, large institutional investors are very much focused on 
large  projects  for  which  the  associated  risks  over  the  lifetime  of  the  project  are  easily 
identified/quantified. However, the energy revolution that is needed involves a plethora of 
small/medium  projects  to  be  promoted  by  a  large  number  of  actors  or  their  agents  (e.g. 
energy services companies). Thus large budgets (that can be equivalent to that of a single 
large project) need to be committed towards a pool of smaller projects so that it can finance 
smaller  operation  efficiently.  Experience  shows  that  investors  are  currently  shying  away 
from it. A limited number of financial products, including from the EIB, are targeting this 
kind of operations but do not seem to be known enough by the market. The EU can play a 
role to promote and encourage the use of such financing products adapted to small projects". 
(Industrial organisation for  energy services in the residential sector) 

• 

"The financing measure at EU level is correct and appropriate. The problem is the access 
to these financing instruments at country level. For small enterprises it is not easy knowing 

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• 

the  rules  of  access  and  it  is  not  always  clear  who  to  contact".  (ESCO  operating  in  the 
lightning sector) 
"Apart  from  raising  the  awareness  in  the  public  and  private  sector  of  energy  performance 
contracting  (EPC),  is  to  address  accounting  and  budgeting  rules  that  can  prevent  or 
discourage EPCs. Ideally, an ESCO contract should be over multiple years (e.g. 10 years or 
more) with no upfront investment costs and aimed at the existing building stock where the 
biggest  energy  saving  potentials  are  located.  Operators  in  public  sector  (ministries, 
hospitals,  schools,  universities  etc)  need  to  receive  assurances  that  they  will  retain  the 
financial benefits of reduced energy costs and not just see their efforts translated into budget 
reductions;  they  also  need  to  be  able  to  engage  in  long-term  contracts.  Both  these  critical 
factors are often impossible to realise due to budgetary and accounting rules; and Member 
States  need  to  remove  such  administrative  barriers  so  there  is  a  real  incentive  for  public 
sector operators to engage in long-term partnerships with ESCOs". (Chamber of Commerce)

4.6. 

Fiscal incentives 

The stakeholders were also asked whether they were in favour of additional measures at the 
EU level for fiscal incentives. 147 (72.4%) of the stakeholders responded confirmatively, 16 
(7.9%)  of  the  submission  answered  negatively,  while  40  (19.7%)  had  no  opinion  in  this 
regard.  

The  majority  welcomed  fiscal  incentives  for  the  promotion  of  energy  efficiency.  Several 
stakeholders from the industry expressed that the main problem of developing and promoting 
energy efficiency services was not the supply of energy services but the lack of demand. In 
their view fiscal incentives could help to create further demand of energy efficient products 
and energy efficiency services. One example mentioned in this regard was to examine income 
tax  rebates  for  energy-saving  measures  for  consumers  which  have  been  employed  in  the 
United States with some success.   

Regarding VAT, some stakeholders expressed that VAT reductions should not be applied to 
all  products  and  services.  It  was  pointed  out  that  reduced  VAT  rates  should  not  to  be 
permitted  for  certain  energy  construction  saving  products,  such  as  insulation.  The 
effectiveness of energy efficiency measures was stated not to be the sum of the products used, 
but  how  they  were  incorporated.  Otherwise,  it  would  encourage  undeclared  labour  and 
increases  the  risk  of  bad  workmanship  which  would  be  counter-productive  to  the  goal  of 
increased energy efficiency. 

Some  stakeholders  regretted  the  recent  withdrawal  of  the  Commission's  legislative  plans  on 
reduced  rates  of  VAT  for  energy  and  environmental  policy  purposes.  Preferential  rates  on 
materials  which  enable  savings  on  energy  demand  in  buildings  would  have  contributed  to 
lowering the prices  of low energy buildings and  making  them  more  attractive.  Even  though 
some of the stakeholders stated that they understood that the issue of reduced VAT rates could 
be politically difficult at this point in time, they invited the Commission to encourage Member 
States  to  make  use  of  other  fiscal  tools  such  as  progressive  property  tax  in  relation  with  a 
building’s energy certificate. Differentiated tax levels would be instrumental in inciting future 
owners  to  opt  for  the  most  energy  efficient  buildings.  Another  suggestion  instead  of  re- 
proposing  VAT  reductions  at  EU  level,  was  the  proposal  that  the  EU  should  provide  a 
framework of available options that could be compatible with state aid rules as well as sharing 
of best practise between Member States.  

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Several stakeholders were also of the opinion that an efficient and timely roll out of smart grid 
and smart metering required fiscal incentives to be adequately and timely developed.  

A reference was also made to the landlord/tenant dilemma regarding investment in buildings. 
A tenant is not interested to invest in energy efficiency in a building that is not owned by the 
tenant. Furthermore, a landlord has not so much interest to invest in energy efficiency since 
the  landlord  is  usually  not  paying  the  bill  of  the  energy  consumption.  Financial  incentives 
could  trigger  landlords  to  make  investments  in  energy  efficiency.  Such  measures  could 
include tax-breaks on the refurbishment of houses or revolving funds for the same purpose.  

Examples of stakeholder responses relating to fiscal incentives: 

• 

• 

• 

"Landlord/tenant  dilemma:  in  several  EU  countries  over  50%  of  buildings  are  rented,  and 
neither the tenants (as they do not own the houses) nor the landlords (as they do not pay the 
energy bills) have incentives to invest in such measures as insulation. Financial incentives 
should  oblige  landlords  to  make  the  right  investments.  Such  measures  could  include  tax-
breaks  on  the  refurbishment  of  houses  or  revolving  funds  for  the  same  purpose.  The 
European  Economic  Recovery  plan  suggests  urgent  tax  measures  to  improve  the  energy 
efficiency  of  the  housing  stock  and  public  buildings.  Taxation  ought  to  be  one  of  the 
instruments  that  governments  should  apply  to  promote  energy  efficiency  investments". 
(Industry association for energy efficiency services)  
"VAT reductions for energy-efficient products are not recommended. They bear the risk of 
high free-rider effects. Targeted financial incentives  for the purchase of  such products are 
better in this respect, since they are not given automatically and more easily adapted to the 
required level. On the other hand, targeted incentives for investments in energy efficiency in 
buildings  or  production  facilities  can  be  given  through  fiscal  incentives.  A  number  of 
Member  States  have  made  good  experiences  with  enhanced  capital  allowances  or  with 
rebates on energy taxes (often coupled to voluntary agreements with industry). A Concerted 
Action  is  advisable  to  exchange  experiences  and  to  develop  common  conclusions. 
Following this, an EU Directive could require Member States to provide a certain level of 
funding through such fiscal incentives, leaving them freedom on the concrete way how to 
do it". (University, institute) 
"High  up-front  costs  are  often  a  psychological  obstacle.  Fiscal  policies  should  therefore 
continue to be developed and coordinated at the EU level. Such policies could take the form 
of ecological tax reform, such as tax differentiation (e.g. reduced VAT for the most energy 
efficient  products  and  services),  enhanced  use  of  fiscal  incentives  (e.g.  tax  rebates  for 
consumers  buying  products  labelled  as  the  most  energy  efficient  goods  or  if  consumers 
insulate their homes) or more easily accessible financing schemes and subsidies for energy 
efficiency  investments  of  private  households.  This  will  make  consumer  uptake  of  such 
products increase and ensure a level playing field in Europe. In this context, we particularly 
call  on  the  Commission  to  consider  re-introducing  the  plan  for  an  EU  proposal  to  reduce 
minimum VAT rates for green products and services, which was recently dropped due to the 
current financial crisis". (Consumer organisation) 

4.7. 

Education and Training 

The  public  consultation  also  addressed  the  vital  need  for  further  education  and  training  in 
energy  efficiency.  The  stakeholders  were  therefore  asked  whether  they  wanted  EU  level 
actions to catalyse training at schools and universities. 

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145  (71.4%)  of  the  stakeholders  answered  confirmatively,  11  (5.4%)  responded  negatively 
and 47 (23.2%) stakeholders had not any opinion in this regard.  

It was stated by the majority in favour of additional measures that it was essential that energy 
efficiency  becomes  part  of  education  and  training.  It  was  further  emphasised  that  the  best 
long-term  results  are  achieved  when  education  starts  early.  In  higher  education  the  classes 
were suggested to become more practical. 

Examples of stakeholder responses relating to education and training: 

• 

• 

• 

"Schools and universities are places where  people are educated on a variety of topics that 
will  benefit  them  for  the  remainder  of  there  live.  As  such  schools  and  universities  are  an 
excellent  place  for  education  and  training  on  energy  efficiency.  It  is  especially  important 
that the training will be continued during several years of the education so it can be ensured 
that  energy  efficient  behaviour  gets  locked 
into  people’s  normal  behaviour.  To 
systematically include the topic of energy efficiency in education will surely help to meet 
the European Union’s long-term challenge of arriving at a energy-efficient and low-carbon 
economy". (ICT company) 
"An  EU  wide  spread  of  best  practice  examples  and  case-studies  to  be  used  in  further 
education  courses  and  as  part  of  the  university  courses.  The  business  sector  should  be 
actively  integrated  in  the  development  of  such  training  elements.  This  could  be  done  for 
example  by  introducing  regular  visits  of  energy  advisors  to  schools".  (Chamber  of 
Commerce) 
"There  should  also  be  opportunities  not  only  for  students  but  professionals".  (Industrial 
organisation for energy efficiency services in the tertiary and industry sectors) 

4.8. 

Awareness of consumers and SMEs 

The stakeholders were also asked whether they were in favour of additional measures at the 
EU level for raising awareness on energy saving opportunities, particularly for consumers and 
SMEs.  141  (69.5%)  of  the  stakeholders  responded  confirmatively,  24  (11.8%)  of  the 
submission answered negatively, while 38 (18.7%) had no opinion in this regard.  

The majority of stakeholders in favour of additional measures for awareness raising on how to 
save  energy,  welcomed  information  campaigns  but  not  at  EU  level.  Communication  was 
argued to be needed given at local level and close to the citizens.  There were several practical 
examples suggested such as the organisation of information days in cities and regions. It was 
also suggested that local Energy Agencies or Chambers of Commerce could play a key role 
on awareness raising as they are close to consumers and SMEs. The Covenant of Mayors was 
also mentioned to be a good structure to be used for information campaigns.  

Concerning consumers and SMEs and their energy bills, ICT solutions were suggested to be 
efficient. The consumers should be able to access a website or digital indicator to be aware at 
any  time  of  their  energy  consumption  allowing  them  to  take  conscious  decisions  on  energy 
saving. It was also suggested in this regard that the mere information was not sufficient for 

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significant energy saving, the information needed to be accompanied by advice how to save 
energy. 

Examples of stakeholder responses relating to awareness of energy saving for consumers 
and SMEs: 

• 

• 

"Our answer is actually a no for EU-level Campaigns: Communication needs to be closer to 
the citizens. Therefore, any EU legislation and regulation should include requirements to the 
Member States to ensure communication (including at lower government levels) that makes 
citizens and market actors aware of the benefits of the legislation and regulation and how to 
apply  it.  The  contents  of  that  decentralised  communication  could  and  should  be  co-
ordinated at EU level. This could be a new task for the EACI". (University, Institute)  
"Communication  campaigns  on  energy  efficiency  and  sustainable  development  are  very 
important  but  are  not  sufficient.  It  asks  a  strong  involvement  from  inhabitants  to  look  for 
information and have the “good energy behaviour”. All the European citizens don’t have the 
capacity  and  time  to  be  well  informed.  European  Union  has  to  develop  a  new 
communication  strategy  based  on  local  level,  with  a  direct  dialogue  with  inhabitants.  In 
France,  to  inform  people  on  wastes  management,  there  is  “wastes  management 
ambassadors” in each neighbourhood, who are intermediaries beside inhabitants. European 
Union  could  promote  Energy  ambassadors  in  each  member’s  states,  it  means  local  actors 
who could inform, train and answer question, directly to citizen on energy saving. Covenant 
of  Mayors  could  be  a  good  way  to  implement  it  at  the  first  step".  (Association  for  social 
housing) 

•  "When  it  comes  to  requirements  of  information  about  energy  efficiency  via  the  energy 
supply  companies  or  the  transmission  or  distribution  operators  it  is  important,  that 
information are given in a cost and climate protecting way (e.g. via internet if possible, just 
one time by the supplier and not additionally by the grid operator and the meter operator)". 
(Energy utility) 

•  "The  easy  access  to  consumption  patterns,  through  a  website  or  a  digital  indicator  in  a 
central location, allows consumers and SMEs to keep a constant eye on their consumption, 
allowing them to make conscious decisions. The indication should be kept in close relation 
to  the  cost  savings  made  by  energy  users,  as  the  price  of  energy  has  a  large  impact 
consumers and on a business’s bottom line profits". (Producer of energy using products) 

4.9. 

SMEs 

The  public  consultation  also  addressed  the  significant  need  for  further  promoting  energy 
efficiency  for  SMEs.  The  stakeholders  were  asked  whether  they  thought  that  specific 
measures  targeted  to  SMEs  are  necessary.  121  (59.6%)  of  the  stakeholders  answered 
confirmatively,  20  (9.9%)  responded  negatively  and  62  (30.5%)  stakeholders  had  not  any 
opinion in this regard.  

Looking at the demand side on energy savings for SMEs, the majority of the stakeholders in 
favour  of  further  measures  for  promoting  energy  efficiency  welcomed  awareness  raising 
rather than new incentives. Moreover, several stakeholders expressed that subsidised or free 
energy audits would be an efficient tool to facilitate real energy savings for SMEs. 

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Concerning  the  supply  side,  micro-credits  for  SMEs  were  stated  to  be  of  significant 
importance in order to help ESCOs to be created. 

On the decision- making process, some stakeholders raised the concern that SMEs were not 
adequately  involved,  particularly  with  the  proceedings  regarding  the  Eco-design  Directive 
(2005/32/EC)  since  the  cost  of  sending  representatives  were  too  high.  An  on-line  system 
aimed at collecting industry data allowing SMEs to take part in the process was suggested to 
facilitate further participation by SMEs in this regard. 

Examples of stakeholder responses relating to SMEs: 

•  "Most traditional banks still see no return in loans financing energy efficient improvements 
in  SMEs  and/or  they  are  still  not  prepared  for  this.  We  are  talking  about  micro  credits  of 
around 20.000 to 30.000 Euros required by SMEs directly or through ESCOs. This hampers 
improvement  in  energy  efficiency  in  many  SMEs  due  to  their  often  precarious  financial 
situation.  The  EU  and  its  Member  States  could  set  up  specific  measures  to  change  this 
attitude, for instance through awareness campaigns addressed to the banks. At the same time 
the EU could explore new, alternative financing ways to ensure the conditions are laid for 
these  micro  credits  to  be  provided  (for  instance  through  venture  capital,  etc.)."  (Industry 
organisation) 

•  "SMEs  will  enter  the  energy  efficiency  market  so  long  as  that  market  provides  clear  and 
profitable  commercial  opportunities.  This  would  be  achieved  if  all  the  existing  policies, 
legislation and financial instruments in place at EU (and Member State) level operated fully 
and  effectively.  No  particular  new  incentives  for  SMEs  are  needed;  rather  the  emphasis 
should  be  placed  on  making  all  existing  (and  proposed)  instruments  work  fully  and 
effectively. This should be underpinned by adopting binding targets for energy efficiency, 
which  would  send  a  clear  signal  to  SMEs  that  energy  efficiency  is  a  market  area  worth 
investing  in.  For  example,  Energy  Performance  Contracting  (EPC)  generates  jobs  by 
employing local labour and local contracting companies which tend to be SMEs. If EPC is 
supported, this will automatically provide for SME growth". (Construction Association ) 
•  "The current eco-design standard setting procedure suffers from a lack of SME participation 
in the process. Even though SMEs are generally considered the source of innovation in the 
engineering sector, their high performing products are not considered in the process, as their 
participation in the process is not ensured. The cost for an SME to send a representative to 
Ecodesign  Consultation  Forums  is  too  high,  resulting  in  standard  setting  meetings  being 
dominated  by  multinational  corporations  and  broad  associations.  As  associations  can  only 
participate based on the lowest common denominator, their impact is limited. This results in 
a watering down of requirements. An online system aimed at collecting industry data would 
allow SMEs to take part in the process at a fraction of the cost, allowing the EU to develop 
meaningful legislation". (Producer of energy using products) 

4.10. 

Public sector 

The  public  sector  should  lead  by  providing  the  best  example  on  the  promotion  of  energy 
efficiency.  The  stakeholders  were  therefore  asked  whether  actions  at  EU  level  should  be 
adopted in order to further make the public sector to promote energy efficiency. 137 (67.5%) 
of  the  stakeholders  responded  confirmatively,  31  (15.3%)  of  the  submission  answered 
negatively, while 31 (15.3%) had no opinion in this regard.  

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The  majority  of  stakeholders  wanting  additional  measures  for  the  public  sector  stated  that 
public buildings should be setting a leading example and should be the first buildings to be 
zero net buildings. Moreover, green public procurement was stated nearly by all stakeholders 
to  be  of  significant  importance.    Some  of  the  stakeholders  wanted  to  make  green  public 
procurement mandatory.  Some concern was raised that green public procurement applied by 
the governments seems to favour larger companies and not SMEs.  

Examples of stakeholder responses relating to public sector: 

•  "The public sector can help raise awareness of the benefits of energy efficiency for business 
and consumers. For example Energy Performance Certificates (EPCs) and Display Energy 
certificates (DECs) provide details on the energy performance of buildings. The A-G rating 
of EPCs provides important information highlighting improvements that can be made to the 
fabric of the building to make it more efficient. By showing how efficiently energy is used 
in  a  building  the  DEC  rating  encourages  investment  in  energy  efficient  equipment  and 
promotes behavioural change. A further role out of DECs from public buildings to all non–
domestic  buildings  could  be  a  powerful  tool  in  motivating  businesses  to  monitor  and 
manage  their  energy  consumption.  The  role  of  green  public  procurement  is  also  highly 
significant in the switch to energy efficiency". (Industry organisation) 

• 

•  "The leading role of the authorities cannot be underestimated. Public procurement offers a 
route to increased efficiency of products. Public authorities should also change their ways of 
working  as  far  as  possible  towards  a  low-carbon  one,  fully  utilizing  the  possibilities  that 
ICT  and  broadband  communications  (mobile  and  fixed)  can  bring".  (Company  in  the  ICT 
sector) 
"The  public  sector  should  lead  by  example  and  improve  the  energy  efficiency  of  their 
buildings in the short term, through binding implementation dates. The public sector should 
also  be  mandated  to  implement  all  recommendations  indicated  in  the  energy  performance 
certificate  during  the  lifetime  of  that  certificate.  The  public  sector  in  each  Member  State 
needs to make an overall and systematic plan to renovate the public sector building stock. If 
resources are pooled to renovate multiple buildings at the same time, a higher cost-savings 
can be achieved. Scaling up in this way will not only bring the best economies of scale, but 
also of knowledge and best practice. The National Energy Efficiency Action Plans could be 
used  as  the  tool  to  outline  these  plans.  A  change  in  attitude  is  needed  regarding  public 
procurement practices for energy efficiency. It is about buying energy saving, not products 
or services. Public authorities need help in changing mindsets to this way of thinking. The 
green public procurement policy advocated by the EC can help Europe to move towards a 
more  sustainable  building  stock.  The  EC  needs  to  make  sure  that  this  policy  is  based  on 
objective,  scientific  and  well  accepted  criteria.  Financing  should  also  be  available  to  the 
Public  sector  to  allow  implementation  of  these  ambitious  plans".  (Industry  association  in 
energy efficiency services) 

4.11.  Energy utilities 

The  stakeholders  were  also  asked  whether  they  thought  that  specific  measures  targeted  to 
energy utilities were required.  111 (54.7%) of the stakeholders answered confirmatively, 34 
(16.7%) responded negatively and 58 (28.6%) stakeholders had not any opinion in this regard.  

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The majority of the stakeholders in favour of further measures for the energy utilities wanted 
stricter  requirement  on  energy  utilities  to  invest  and  provide  energy  efficiency  services. 
However,  there  were  some  stakeholders  who  favoured  that  the  requirements  should  be  of 
voluntary  character,  while  others  were  of  the  opinion  that  the  further  obligations  should  be 
legally binding. On which segment the requirements should be set, some of the stakeholders 
expressed  the  distribution  companies  were  the  best  segment  since  they  are  closest  to  the 
consumers.  

There were also arguments that when energy utilities were investing in energy services they 
should  be  able  to  pass  the  cost  on  to  the  end-consumers.  This  could  also  be  done  in 
coordination with the national regulatory authorities by passing-through costs in the network 
rates or supply prices.   

Energy  utilities  were  also  encouraged  by  certain  stakeholders  to  invest  in  Best  Available 
Technique  (BAT)  in  their  own  installations.  Moreover,  it  was  suggested  that  in  the  licence 
process  for  new  plants,  energy  utilities  should  demonstrate  to  the  national  regulatory 
authorities that their plants are of the most cost-effective option. 

Some  of  the  stakeholders  made  reference  to  the  new  codes  to  be  developed  by  the  Third 
Liberalisation  Package.  It  was  proposed  in  this  regard  that  the  code  on  energy  efficiency 
should be ambitiously set for concrete energy savings. 

Examples of stakeholder responses relating to energy utilities: 

•  "There is a burning need to change the regulatory framework in order for the energy utilities 
to  play  a  much  bigger  role  in  the  energy  efficiency  and  to  offer  energy  performance 
contracting.  It  is  necessary  to  provide  the  energy  utilities  with  an  incentive  to  invest  in 
energy  efficiency  –  for  example  a  possibility  to  make  profit  through  energy  savings. 
Moreover, it is necessary to further promote a fair and open market with energy". (Ministry 
of environment in one of the Member States of the EU) 

•  "In  particular  Article  6  of  the  Energy  End-use  and  Energy  Services  Directive  needs  to  be 
fully enforced, and then strengthened. Also it should be made a requirement for all energy 
companies, before any new generation plant is built, to demonstrate publicly to the regulator 
(or  government)  that  a  new  plant  would  be  a  more  cost-effective  option  than  helping 
consumers to save energy. This is standard practice already in many US States". (Industry 
association in energy efficiency services) 

•  "The  incentives  for  energy  companies  to  pursue  end-use  energy  efficiency  depend  on  the 
framework  conditions.  Articles  6  (2)  and  10  of  the  EU  Directive  on  energy  end-use 
efficiency and energy services (ESDir) enable Member States to create such a framework. 
However,  they  are  not  yet  specific  and  concrete  enough.  Three  components  need  to  be 
regulated  to  remove  disincentives  and  create  positive  incentives  for  energy  companies  to 
pursue  end-use  energy  efficiency,  under  the  condition  that  the  cost-effectiveness  of  the 
programmes  for  participating  energy  consumers  and  society  can  be  made  plausible:  (1) 
There  must  be  the  possibility  to  recover  programme  costs.  If  network  operators  or  energy 
suppliers with regulated supply prices (as, e.g., still in France) implement the programmes, 
the regulators must explicitly allow pass-through of programme costs in the network rates or 
supply prices. Article 10 of the ESDir should be recast in order to require national regulators 
to allow this. If unregulated suppliers are to implement programmes, giving all comparable 
suppliers the same level of obligations to save energy will also enable them to pass on the 

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costs  in  their  supply  prices.  (2)  In  the  energy  network  business,  regulators  must  take  care 
that the level of net profits of the network company is not compromised if they or anybody 
else save energy at the final energy consumers connected to the network. Article 10 of the 
ESDir  should  be  recast  in  order  to  require  national  regulators  to  allow  this".  (University, 
Institute) 

•  "New market models in liberalized markets, combined with unbundling measures, can lead 
to confusion on roles and responsibilities of the different market players : DSO – which is 
the only player with a neutral and long term relationship with the energy consumer - should 
(continue  to)  play  a  central  role  in  energy  saving  actions  and  contribute  to  the  (further) 
development  of  energy  services.  -  consider  the  specific  requirements  (high-level 
bureaucratic  und  regulatory  complexity)  to  local  energy  companies  in  the  EU  member 
states. To integrate suppliers successfully in energy efficiency programs, specific and new 
incentives will have to be developed. A central role for the DSO - with his neutral and long 
term relationship with the energy consumer – is most logic in the field of energy efficiency. 
The possible conflict between the regulator that strives for maximum cost cutting, and the 
DSO that is ambitiously stimulating energy efficiency actions must be avoided and should 
explicitly  be  addressed.  EU-level  measures  should  be  restricted  to  a  general  framework, 
leaving the practical elaboration to the Member States. In general it should be avoided that 
existing successful measures (possibly in conflict with a new EU-level general framework) 
are being stopped". (Energy utility organisation) 

•  "The role  of  energy  utilities has been fundamental  until now  to develop energy efficiency 
services  in  some  countries;  probably  their  role  might  evolve  towards  a  cooperation  with 
Regulators  to  promote  structural  investments  in  energy  efficiency.  Energy  utilities  could 
contribute not as “obliged subject” but as “intermediate” between the State and the obliged 
subject.  In  this  scheme  energy  utilities  might  commit  themselves  on  the  results  with  the 
possibility to share benefits of energy savings and therefore maybe ready to share or support 
costs  when  the  client  cannot  afford  or  does  not  want  to  divert  investments  from  its  core 
business.  This  would  have  the  effect  to  produce  results  for  the  State  in  terms  of  energy 
savings  and  CO2  reductions,  and  would  at  the  meantime  launch  projects  resulting  in  a 
stimulus for the competitiveness of the industrial system." (Energy utility) 

4.12. 

Incentives for SMEs to enter the energy efficiency market  

Energy  efficiency  offers  significant  market  opportunities.  The  stakeholders  were  therefore 
asked whether actions at EU level should be adopted in order to further provide incentives for 
companies  to  enter  these  markets  and  particularly  SMEs.  86  (42.4%)  of  the  stakeholders 
responded confirmatively, 56 (27.6%) of the submission answered negatively, while 61 (30%) 
had no opinion in this regard.  

The stakeholders responding confirmatively to this question stated in general that the creation 
of ESCOs was important in this regard. It was also mentioned  that  United States and Japan 
had already launched several efficiency programmes. It was therefore argued that it is crucial 
that  Europe  from  a  competitiveness  aspect  does  not  miss  opportunities  in  the  timing  of 
developing an energy efficient economy.  

4.13.  White certification scheme 

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The public consultation also addressed the question whether an EU wide White Certification 
scheme  should  be  introduced.  60  (29.6%)  of  the  stakeholders  answered  confirmatively,  65 
(32%) responded negatively and 78 (38.4%) stakeholders had not any opinion in this regard.  

On  this  issue  there  was  rather  diverging  opinions.  Furthermore,  there  were  several 
stakeholders who had answered yes to the question, but qualified the answer by stating that 
they would only welcome white certificate schemes to be introduced at the national level. The 
majority of stakeholders were not in favour of the introduction of a unified EU wide White 
Certificate  Market.  The  reasons  given  were  amongst  others  that  it  could  distort  the  already 
existing  schemes  introduced  in  some  of  the  Member  States,  and  it  could  overlap  with  other 
instruments such as ETS and green certificates. However, there were several proponents for 
national  white  certificate  schemes  to  be  introduced  under  the  condition  that  these  schemes 
should  be  market  driven  and  carefully  designed  in  order  not  to  overlap  with  other  schemes 
and create further administrative burden for the Member States. Some stakeholders suggested 
that white certificates should be targeted towards energy utilities in order to encourage energy 
efficiency services to be provided. 

Examples of stakeholder responses regarding White Certification Scheme: 

• 

• 

• 

"We  have  some  reservations  about  the  introduction  of  an  EU  wide  white  certificate 
scheme.  Whilst  the  CERT  in  the  UK,  and  previously  the  EEC,  is  helping  to  improve 
energy efficiency (and can help drive energy efficiency skills at a local level) an EU wide 
scheme  could  be  cumbersome,  unwieldy,  overlap  with  other  schemes  (national  and 
European)  and  not  be  appropriate  to  the  needs  of  individual  member  states.  If  such  a 
scheme  was  set  up  at  EU  level,  given  the  differences  in  market  liberalisation  in  the 
member  states,  a  white  certificate  could  enhance  the  market  position  of  incumbents  and 
hinder access for SMEs". (Chamber of Commerce) 
"Article  6  of  the  ESD  already  requires  Member  States  to  place  obligations  on  their 
utilities, including the possibility of White Certification schemes. It should be possible to 
facilitate even further at EU level the continued use of such White Certification schemes 
where utilities are involved, by the use of and, if necessary, the strengthening, of Article 
6(2)  in  the  ESD,  placing  additional  obligations  on  utilities.  Creating  an  EU-wide  or 
regional  trading  system  may,  however,  prove  difficult  at  this  stage  where  different 
national  schemes  already  exist,  and  where  an  EU  –wide  might  generate  too  much 
administrative  burden  and  render  the  national  systems  less  effective".  (Industry 
organisation) 
"White  certificate  schemes  can  be,  and  are  already,  an  effective  policy  measure  for 
promoting implementation of energy efficiency improvement measures. This is reflected 
in  the  fact  that  a  number  of  countries  have  already  adopted  such  schemes  or  similar 
supplier  obligations  and  more  are  actively  doing  so  in  the  context  of  implementation  of 
the  Energy  Services  Directive.  We  believe  therefore  that  a  proposal  for  an  EU-wide 
scheme is neither necessary or timely as it has the potential to both cast uncertainty over, 
compromise,  or  actively  conflict  with  the  operation  of  existing  successful  national 
schemes.  The  current  Energy  Services  Directive  Concerted  Action  provides  an 
opportunity for Member States to learn form each other's national schemes". (Ministry of 
a Member State) 

• 

"In  general  terms  we  support  measures  that  give  appropriate  and  cost-reflective  price 
signals  that  improve  energy  efficiency  and  we  often  believe  that  market  based 
mechanisms  constitute  the  most  economical  approach  compatible  with  a  liberalised 

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market. However, this implies a liquid, well designed, transparent and harmonised market, 
particularly  concerning  the  methodology  for  calculation,  reporting  and  verification.  In 
addition, a homogeneous product to be traded. This is not the case for energy efficiency. 
On the question of a European white certificate scheme, we believe that existing national 
experiences should be analyzed and compared before any extension. The same applies for 
the impacts of white certificate schemes to common European energy markets, energy end 
prices and the EU emissions trading scheme. Today, few Member States have opted for a 
white certificate scheme and their schemes are not compatible (i.e. white certificates are 
not tradable across their borders). Moreover, such schemes have yet failed to demonstrate 
their  effectiveness  (both  in  terms  of  additionality  and  of  real  reductions  in  energy 
consumption)  and  their  driver  in  investments  with  medium-to-long  term  payback  time. 
We  would  also  like  to  stress  that  implications  of  interactions  between  different  trading 
schemes (ETS, Green Certificates, White Certificates) should be carefully assessed. In this 
respect, we believe the conclusions of the 2005 NERA report “Interactions of the EU ETS 
with Green and White Certificate Schemes” are still valid and should be taken in serious 
considerations.  Furthermore,  the  introduction  of  certificates  should  be  consistent  with 
existing measures, bring an added value, and be cost effective – i.e. the least bureaucratic 
possible. Multiple overlapping steering mechanisms should generally be avoided and EU-
wide regulation should be as limited as possible. Any discussion on white certificates shall 
not  neglect  that  calculations  of  savings  shall  include  the  whole  energy  chain  from 
production  to  end-point  use  in  order  to  make  sure  no  point  of  the  energy  process  is 
neglected. In addition, it should specifically address issues like the risk of free riders and 
increased cost, and the effectiveness in driving investments in the industrial sector, where 
the highest potentials at the lowest cost can be found". (Association of electricity industry 
in Europe) 

4.14.  Binding targets  

The  Directive  on  energy  en-use  efficiency  and  energy  services  (2006/32/EC)  set  indicative 
targets for energy savings. Since energy efficiency is becoming increasingly important both as 
regards security of supply and climate mitigation, the public consultation raised the question 
of the need for binding targets. 108 (53.2%) of the stakeholders responded confirmatively, 50 
(24.6%) of the submission answered negatively, while 45 (22.2%) had no opinion.  

The majority that answered confirmatively, favoured a binding overall target but supported by 
secondary level targets, amongst others for CHP. However, the condition for adopting binding 
targets was to find a common measurement and verification method. 

Examples of stakeholder responses relating to binding targets: 

• 

"There is a need for an overall target for energy efficiency to be made mandatory, such as 
the 20% by 2020 compared to 1990. This should be underpinned by an understood and clear 
definition of “energy efficiency” and the development of an objective method for measuring 
and quantifying energy efficiency. 2. The binding overall target needs to be supplemented 
by  secondary  level  targets  in  specific  sectors.  3.  An  overall  mandatory  target  for  2050 
should  also  be  set  for  the  buildings  sector.  There  are  legitimate  concerns  regarding  the 
reliability of existing data in all member states for establishing baselines to measure precise 
energy  intensity.  Therefore,  there  is  a  need  for  more  practical  sector  specific  targets  to  be 

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• 

set. For buildings, for example, a target could be set that would see x% of existing buildings 
renovated  to  a  high  standard  in  each  Member  State  every  year  until  2020/2030/2050". 
 (Industry association in energy efficiency services) 
"There is a need for an overall binding target for energy efficiency. The level of ambition 
should  be  set  at  least  the  20%  savings  target  already  espoused  by  the  Heads  of  State  and 
government for 2020. There is additionally a need to define clearly what the baseline for the 
calculation  at  Member  State  and  EU  level  will  be.  The  binding  overall  target  needs  to  be 
supplemented  by  secondary  level  targets  in  specific  sectors,  including  a  target  for  the 
penetration of cogeneration in the electricity provision of a member state". (Association of 
cogeneration)  

4.15.  Measurement and verification  

Measurement  and  verification  of  energy  savings  is  an  essential  aspect  for  monitoring  the 
results  of  any  measure  introduced  at  national  and  EU  level.  The  public  consultation  raised 
therefore the questions whether it was necessary that a systematic and harmonised approach at 
EU  level  should  be  adopted.  143  (70.4%)  of  the  stakeholders  responded  confirmatively,  22 
(10.8%)  of  the  submission  answered  negatively,  while  38  (18.7%)  had  no  opinion  in  this 
regard.  

The  majority  opting  for  a  systematic  and  harmonised  approach  at  EU  level  to  be  adopted 
stated that measurement and verification methods are a prerequisite for binding targets.  The 
stakeholders  had  however  some  divergent  views  on  which  parameters  to  base  such  a 
methodology for measuring energy efficiency. 

Examples of stakeholder responses relating to measurement and verification: 

• 

"Systematic and precise measurement of Primary Energy used should be emphasised in any 
overall energy use management/monitoring at EU level. This is the most effective parameter 
and ensures parity between all energy sources". (NGO) 

•     "The indicative ESD savings target of 9% by 2016 and the 20% 2020 savings goals are not 
directly  comparable  since  the  ESD  is  an  end-use  (final  energy)  target  and  the  2020  target 
relates  to  primary  energy  use.  However,  the  MS  should  be  required  to  put  their  national 
ESD target into the context of the 2020 target to identify the gap. It should also be requested 
from  the  MS  to  indicate  how  they  consider  dealing  with  the  identified  gap.  To  improve 
methodology  and  comparability  of  energy  savings  between  Member  States,  EU  wide  and 
mandatory templates should be proposed for the next round of National Energy Efficiency 
Action  plans.  The  templates  should  be  sector  specific  and  highlight  how  the  obligation  to 
the Public sector should be implemented. A template should also be used to request the MS 
to clearly state which measures are new and which ones already exist, as well as how they 
plan  to  validate  the  impact  of  the  measures  to  be  implemented.  Several  sector  templates 
were  developed  for  the  first  NEEAPs,  which  is  a  good  starting  point  for  developing 
mandatory EU templates covering all end-use sectors. The results of the in-depth analysis of 
the NEEAPs currently undertaken by JRC, as well as the analysis done by Wuppertal and 
Ecofys  as  part  of  the  EEW  project,  should  also  be  taken  into  account  when  developing 
templates.  To  provide  consistency 
in  approach  and  confidence  for  organisations 
implementing  energy  saving  measures,  a  standard  protocol  should  be  supported  and 
implemented  for  the  measurement  and  verification  of  energy  savings  from  Energy 
Performance Contracting such as IPMVP which is used in North America and is being used 

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by all the major ESCOs in Europe". (Industry association in energy efficiency services) 
•     "Energy  efficiency  is  the  largest,  quickest,  and  most  cost-effective  resource  to  improve 
security of supply and mitigate climate change. Binding targets as for renewable energies or 
greenhouse  gas  emissions  should  therefore  also  be  set  in  the  energy  efficiency  area. 
However, energy savings can always only be measured against what would have been the 
energy consumption in the absence of energy efficiency measures (a counterfactual). Given 
the  measurement  problems  associated  with  the  definition  of  this  counterfactual,  it  may  be 
better to set binding requirements for the absolute energy consumption in a Member States 
than for energy savings from energy efficiency. These requirements for the absolute energy 
consumption  can  easily  be  measured  and  are  thus  able  to  prove  their  fulfilment  with  the 
precision  required.  However,  they  should  still  be  accompanied  by  indicative  targets  for 
energy savings against baseline projections. The level of energy savings achieved through 
policy and energy services should also be calculated in order to measure the Member States’ 
effort". (University, Institute) 

•     "This is a difficult question as savings of energy is not the same thing as energy efficiency, 
it seems attractive to work with energy units saved, but to monitor this is difficult. Our own 
work within this field is based on additionality on the sales of electricity, and then this funds 
energy efficiency activities. We argue that there are important gains also in those projects 
that are not  necessarily  resulting in the largest net gain per invested euro as activities can 
boost and support indirect effects". (NGO) 

4.16. 

International cooperation  

The public consultation asked the stakeholders whether they agreed to that energy efficiency 
should become a vector of international cooperation and a subject of international financing 
programmes,  in  particularly  regarding  EU  neighbouring  countries.  142  (70%)  of  the 
stakeholders  responded  confirmatively,  5  (2.5%)  of  the  submission  answered  negatively, 
while 56 (27.6%) had no opinion in this regard.  

that  concerns 

The stakeholders expressed that energy efficiency is a global issue as the climate change is an 
the  planet.  Moreover,  energy  efficiency  gives  several  market 
issue 
opportunities. As several countries like United States and Japan have already launched several 
energy  efficiency  programmes  which  will  create  new  products  and  energy  services,  energy 
efficiency is also linked to the competitiveness of Europe.  

Several stakeholders also expressed that they want Europe to be a leader in energy efficiency 
policy  and  that  ambitious  EU  level  decision  should  be  brought  to  the  negotiation  table  in 
Copenhagen by the end of this year.  

5. 

FINAL REMARKS 

As a last open free question, the public consultation invited the stakeholders to give their final 
comments  on  energy  efficiency.  Some  stakeholders  expressed  that  the  on-line  consultation 
should have had an open-free text also related to the No options for the different questions. 
The  Commission  takes  due  notice  of  these  remarks  and  will  endeavour  to  take  this  into 
consideration  for  future  on-line  questionnaires.  Nevertheless,  section  5  asked  for  additional 
comments  and  was  intended  for  statements  that  would  not  directly  fit  in  under  the  specific 
questions.  Several  stakeholders  used  this  option  to  elaborate  their  negative  replies  for  the 

EN 

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specific  questions  and  these  comments  have  been  included  in  this  report  on  the  public 
consultation on the Evaluation and Revision of the Energy Efficiency Action Plan. 

EN 

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Annex 1: List of organisations submitting responses 

Country 

Organisation 

Website 

Austria  

Organisation 

Alpsolar Klimadesign 

Austria  

Organisation 

Association of Austrian Electricity Companies 

Austria  

Organisation 

Enamo GmbH 

Austria  

Organisation 

Energie AG Oberösterreich 

Austria  

Organisation 

EVN Aktiengesellschaft 

Austria  

Organisation 

IG Passivhaus Österreich 

Austria  

Organisation 

Österreichische Elektrizitätswirtschafts-AG 

Austria  

Organisation 

Sonnenplatz Großschoenau GmbH 

Austria  

Citizen 

Belgium  

Organisation 

Cefic - European chemical Industry Association 

Belgium  

Organisation 

DIGITALEUROPE 

Belgium  

Citizen 

Belgium  

Citizen 

Belgium  

Citizen 

Cyprus  

Organisation 

Czech Republic  

Organisation 

CEZ Group 

Czech Republic  

Organisation 

Ministry of the environment  

Czech Republic  

Organisation 

Saint-Gobain Orsil 

Czech Republic  

Citizen 

Denmark  

Organisation 

Danish Energy Association 

Denmark  

Citizen 

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EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

A.I.S.E. (detergents industry association) 

AEGPL - European LPG Association 

American Chamber of Commerce to the European 
Union 

ANEC 

Architects' Council of Europe (ACE) 

BEUC - the European Consumers' Organisation 

BING European polyurethane insulation association 

Bosch Thermotechnik GmbH 

CECED - Household Appliance Industry Association 

CECODHAS - European Social Housing Network 

COGEN Europe 

Danfoss A/S 

EFIEES – Europ. Feder. Energy Efficiency Services 

Emerson Electric 

EON AG 

EPIA, European Photovoltaic Industry Association 

ETRMA- European Tyre & Rubber Manufacturers' Ass 

eu.bac - european building automation & controls  

EURELECTRIC 

EURIMA, European Insulation Manufacturers Assoc 

EuroACE 

EUROCHAMBRES 

EuroCommerce 

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EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Organisation 

EUROGYPSUM 

Euroheat & Power 

European Aluminium Association 

European Autoclaved Aerated Concrete Association 

European Calcium Silicate Producers Association 

European Construction Industry Federation (FIEC) 

European Copper Institute 

European Cyclists' Federation (ECF) 

European Environemental Bureau (EEB) 

European Federation for Construction Chemicals 

European Lamp Companies Federation 

European Petroleum Industry Association, EUROPIA 

European Renewable Energy Council 

FIA European Bureau 

GEODE 

Glass for Europe 

International Network for Sust. Energy - Europe 

Kingspan Group - mark.harris@kingspanpanels.com 

Micropower Europe 

NGVA Europe 

Surfrider Foundation Europe 

Surfrider Foundation Europe 

UEAPME 

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EU as a whole (for 
organisations only) 

Organisation 

EU as a whole (for 
organisations only) 

Citizen 

WWF European Policy Office 

Finland  

Organisation 

Finnish Energy Industries 

Finland  

Organisation 

National Board of Antiquities 

France  

Organisation 

ACFCI - French Chambers of Commerce and Industry 

France  

Organisation 

Assemblée permanente des chambres de métiers 
(APCM 

France  

Organisation 

Banque Populaire 

France  

Organisation 

Bosch Thermotechnology 

France  

Organisation 

ELM Leblanc (groupe BOSCH) 

France  

Organisation 

ERDF -  Electricité Réseau Distribution France 

France  

Organisation 

Fédération Française du Bâtiment 

France  

Organisation 

Fédération Nationale des Travaux Publics (FNTP) 

France  

Organisation 

GIMELEC 

France  

Organisation 

L'Union sociale pour l'Habitat 

France  

Organisation 

MEDEF 

France  

Organisation 

Ministère en charge du développement durable 

France  

Organisation 

Regional Chamber of Commerce and Industry Lorraine 

France  

Organisation 

 EDF 

France 

Organisation 

France  

Organisation 

France  

Citizen 

Germany  

Organisation 

B.A.U.M. e.V. 

Germany  

Organisation 

Bayerisches Staatsministerium für Umwelt 

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Germany  

Organisation 

BDEW German Association of Energy and Water Indust 

Germany  

Organisation 

Bundesarchitektenkammer 

Germany  

Organisation 

Bundesverband Großhandel, Außenhandel, Dienstleist 

Germany  

Organisation 

Deutscher Industrie- und Handelskammertag DIHK e.V 

Germany  

Organisation 

DGUF - Reg.-Nr. 82277911427-06 

Germany  

Organisation 

erdgas mobil GmbH 

Germany  

Organisation 

Federation of German Industries (BDI) 

Germany  

Organisation 

FMI Fachverband Mineralwoleindustrie e.V. 

Germany  

Organisation 

German Association of the Automotive Industry 

Germany  

Organisation 

German Engineering Federation (VDMA) 

Germany  

Organisation 

IHK Halle-Dessau 

 Germany 

Organisation 

Landis+Gyr Ag 

Germany  

Organisation 

Industrieverband Polyurethan-Hartschaum e. V: 

Germany  

Organisation 

Max Weishaupt GmbH, D-88475 Schwendi 

Germany  

Organisation 

RWE AG 

Germany  

Organisation 

Schulze Darup & Partner architects 

Germany  

Organisation 

Stadtwerke München GmbH 

Germany  

Organisation 

Verbraucherzentrale Bundesverband 

 Germany 

Organisation 

Wienerberger AG 

Germany  

Organisation 

Vereinigung der Landesdenkmalpfleger in Deutschlan 

Germany  

Organisation 

Viessmann Werke GmbG & Co. KG 

Germany  

Organisation 

Viessmann Werke GmbH & Co. KG 

Germany  

Organisation 

VKU e.V. und ASEW GbR  

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Germany  

Organisation 

Wuppertal Institute 

Germany  

Organisation 

Zentralverband des Deutschen Handwerks 

Germany  

Citizen 

Germany  

Organisation 

Germany  

Organisation 

Germany  

Citizen 

Germany  

Citizen 

Greece  

Organisation 

test 

Hungary  

Organisation 

Hungarian Real Estate Association Management HAREM 

Hungary  

Organisation 

National Office of Cultural Heritage 

Hungary  

Organisation 

Ireland  

Citizen 

Italy  

Italy  

Italy  

Italy  

 Italy 

Italy  

Italy  

Italy  

Italy  

Organisation 

3Effegi S.r.l. 

Organisation 

Centro Studi Galileo 

Organisation 

Confcommercio - Imprese per l'Italia 

Organisation 

Edison spa 

Organisation 

ENI SpA 

Organisation 

Municipality of Bologna 

Organisation 

PIRELLI REAL ESTATE 

Citizen 

Organisation 

Lithuania  

Citizen 

Luxembourg  

Organisation 

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Malta  

Citizen 

Netherlands  

Organisation 

Bouwend Nederland 

Netherlands  

Organisation 

Netherlands  

Organisation 

Netherlands  

Organisation 

Netherlands  

Citizen 

Netherlands  

Organisation 

Netherlands  

Organisation 

Netherlands  

Organisation 

Netherlands  

Organisation 

Netherlands  

Organisation 

Netherlands  

Citizen 

Poland  

Organisation 

Verband für Wärmelieferung e.V. 

Poland  

Organisation 

Portugal  

Organisation 

EFRIARC - Assoc.Port.Eng.Frio Ind. Ar Condicionado 

Portugal  

Organisation 

Portuguese Natural Gas Vehicle Association 

Romania  

Citizen 

Romania  

Citizen 

Romania  

Citizen 

Romania  

Citizen 

Romania  

Citizen 

Slovakia  

Organisation 

Association of Service Users 

Slovakia  

Citizen 

EN 

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   EN 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
Slovenia  

Organisation 

Elektro Ljubljana d.d. 

Slovenia  

Organisation 

Focus Association for Sustainable Development 

Slovenia  

Organisation 

Lokalni pospeševalni center Pivka 

Slovenia  

Organisation 

Organisation 

Organisation 

ZOJA 

CEDEC  

CELMA 

Organisation 

EnBW Energie Baden-Württemberg AG 

Organisation 

Eurofuel (The European Heating Oil Association) 

Organisation 

EUROGAS 

Organisation 

Lubrizol  

Organisation 

UPEI (Union of European Petroleum Independents) 

Some EU Member 
States (for 
organisations only) 

Some EU Member 
States (for 
organisations only) 

Some EU Member 
States (for 
organisations only) 

Some EU Member 
States (for 
organisations only) 

Some EU Member 
States (for 
organisations only) 

Some EU Member 
States (for 
organisations only) 

Some EU Member 
States (for 
organisations only) 

Spain  

Organisation 

Cantabria Trade Federation 

Spain  

Organisation 

FENIE 

 Spain 

Organisation 

IBERDROLA 

Spain  

Organisation 

Minsiterio de Industria, Turismo y Comercio 

Spain  

Organisation 

Saint-Gobain Cristalería S.A. 

Spain  

Organisation 

UNION FENOSA comercial 

Spain  

Organisation 

Spain  

Citizen 

Spain  

Citizen 

 Sweden 

Organisation 

Telefonaktiebolaget LM Ericsson 

Sweden  

Organisation 

5665831886-97 (Svensk Energi, Swedenergy AB) 

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Sweden  

Organisation 

Stadskansliet, City Hall 

Sweden  

Organisation 

Swedish Society for Nature Conservation 

Sweden  

Citizen 

United Kingdom 

Organisation 

Confederation of British Industry (CBI) 

United Kingdom 

Organisation 

Department of Energy and Climate Change (UK) 

United Kingdom 

Organisation 

Energy Action Scotland (EAS) 

United Kingdom 

Organisation 

Kingspan Insulation Limited 

United Kingdom 

Organisation 

Local Govt Assn (for England and Wales) 

United Kingdom 

Citizen 

United Kingdom 

Citizen 

United Kingdom 

Citizen 

United Kingdom 

Citizen 

Organisation 

ACEA 

Organisation 

AGFW e.V. 

Organisation 

Alstom Power 

Organisation 

Greenpeace 

Organisation 

HELIO International 

Organisation 

International Union of Tenants (IUT) www.iut.nu 

Organisation 

Royal Institution of Chartered Surveyors (RICS) 

Organisation 

Organisation 

Organisation 

shecco 

SHV GAS 

AREA 

Organisation 

Applied Materials 

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Organisation 

Better Place 

Organisation 

Energy Efficiency Industrial Forum 

Organisation 

Eurocities 

Organisation 

Organisation 

EN 

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Annex 2: On-line public consultation  

Public Consultation on the Evaluation and Revision of the 
Action Plan for Energy Efficiency [COM(2006) 545] 

Useful links - Background documents  

The Heads of States and Governments have endorsed an ambitious European Energy policy which 
seeks to enable the European Union to reduce greenhouse gases by at least 20 %, to reduce energy 
consumption by 20 % and increase to 20 % the share of renewable energies in energy consumption 
by 2020.  

The Action Plan for Energy Efficiency (EEAP) of 2006 was prepared and adopted with a view to 
intensify the process of realising the substantial cost-effective energy savings potential and the 
above-mentioned target on energy consumption reduction. The Plan's running time is until 2012. A 
major mid-term review to evaluate its effectiveness and results was scheduled to take place in 
2009.  

This internet consultation will support this evaluation and revision. It aims to collect views from 
interested parties on the effectiveness and results of the Action Plan so far, and on how best the 
EU may identify and initiate improved policy actions and measures which contribute to a 
maximum extent to the EU's energy saving targets.  

The Commission will publish the results, which may also contain some of the individual replies (if 
no specific request for confidentiality is made) at 
http://ec.europa.eu/energy/efficiency/consultations/2009_08_03_eeap_en.htm 

The public consultation will last 8 weeks. The closing date is 3 August 2009. 

Please note that:  

• Replies in free text questions are limited, in most cases, to maximum 4000 characters (spaces 
included).  
• The session time is limited to 1 hour 30 min, which means that you should submit your reply 
within this allotted time. If you exceed this timeframe, your replies will be lost.  
• If your replies need to be co-ordinated internally, we suggest that you print the blank 
questionnaire and draft your reply off-line (e.g. in a word processor of your choice) and then 
enter the answers online (you can of course simply "copy/paste" text already prepared).  
• After you have clicked on "submit", you should see a confirmation page stating that your reply 
has been recorded. If this is not the case, and if the survey page is re-loaded instead, please 
check that you have filled in all compulsory questions correctly and you have not exceeded the 
maximum number of characters for free text questions. In this case, an error message appears 
next to the question for which something is wrong or missing.  
• The answers to the questions can be provided in any of the official languages of the European 
Union; where possible, answers in a commonly known language are encouraged in order to 
simplify the processing of replies, if possible in the Commission working languages (i. e. English, 
French or German).  
• The respondents are strongly encouraged, if possible, to support their answers with quantitative 
and qualitative arguments and reference to other information sources.  

EN 

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Profile of the respondent 

Your profile (compulsory)  

Citizen 

Organisation 

Region (compulsory)  

European Union 

Europe outside European Union 

International 

Other 

Austria  

Belgium  

Bulgaria  

Cyprus  

Greece  

Portugal  

Hungary  

Romania  

Ireland  

Slovakia  

Italy  

Slovenia  

Czech Republic  

Latvia  

Spain  

Denmark  

Lithuania  

Sweden  

Estonia  

Finland  

France  

Luxembourg  

United Kingdom 

Malta  

EU as a whole (for organisations only) 

Netherlands  

Some EU Member States (for organisations only) 

Germany  

Poland  

Albania 

Andorra 

Armenia 

Azerbaijan 

Belarus 

Georgia 

Iceland 

San Marino 

Serbia 

Liechtenstein 

Switzerland 

Moldova 

Monaco 

Turkey 

Ukraine 

Bosnia and Herzegovina 

Montenegro 

Vatican City State 

Croatia 

Former Yugoslav Republic of Macedonia 

Norway 

Russia 

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Would you like your reply to be published online? (compulsory)  

Yes 

No 

 Organisation name (optional)  

 Organization type (compulsory)  

Member States or public body (national/regional/local), 

European institution or body 

incl. Regulators 

Industry and private sector, incl. their associations, excl. 

Small and Medium Size Enterprises 

SMEs 

(SMEs) 

Consumer organization 

Financing organization 

Non-governmental organization 

Energy utility 

University/ education/research institute 

Energy Efficiency Agency (national, 

regional, local) 

OTHER 

 What type of activities are addressed by your organization (multiple choice 

question) (compulsory)  

Energy Efficiency services in the residential 

Energy Efficiency services in the tertiary and industry 

sector 

sectors 

Construction 

Transport sector 

Other 

Energy-using products and appliances 

Energy production, supply, transmission or distribution 

EN 

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 Briefly describe the nature of your involvement in energy efficiency (optional)  

1. General questions 
In the context of this evaluation and the preparation of the envisaged new Energy Efficiency 
Action Plan, the Commission is open to re-evaluate its present legislation and policy portfolio. 

1.1. The Action Plan for Energy Efficiency of 2006 identified 6 key areas and proposed 10 priority 
actions (out of a total of 85 actions and measures). Which of the actions and measures of the 2006 
EEAP should be continued / redefined / discontinued, and why ? (Max. 4000 characters) (optional)  

1.2. Which new challenges have emerged since 2006 and should be addressed in the new Action Plan 
for Energy Efficiency? (Max. 4000 characters) (optional)  

2. Specific questions 
Please provide an answer to each of the following questions and, if possible, justify it by 
quantifying the environmental, social and economic impacts. 

2.1. The existing Energy Performance of Buildings Directive (2002/91/EC) and its recast, as well as 
other relevant legal acts, go a long way for introducing ambitious but realizable energy performance 

EN 

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requirements for buildings and increase consumers' awareness. However, much more can be 
done. (compulsory)  

Yes 

No 

No opinion 

 How do you assess the need for moving towards a requirement that all new buildings have low 

or zero energy consumption and carbon emissions after certain date? (Max. 4000 
characters) (optional)  

 How do you assess the need for introducing an EU level measures concerning training of 

architects, builders and installers? (Max. 4000 characters) (optional)  

 What other measures at EU level need to be undertaken? (Max. 4000 characters) (optional)  

2.2. Sustainable transport and energy consumption of cars is currently addressed in the Greening 
transport package (COM(2008)433), the Regulation on Emission performance standards for new 
passenger cars (COM(2007)0856), the proposed Directive on labelling of tyres (COM(2008)0779), the 
proposal on greening car taxation (COM(2005)261) and the 'Green Cars' initiative. The Commission is 
also working on a proposal on light commercial vehicles and a revision of CO2/cars labelling. Do you 
consider that additional measures at EU level need to be undertaken? (compulsory)  

Yes 

No 

No opinion 

 In your view what should these measures be? (Max. 4000 characters) (optional)  

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2.3. The Eco-Design (2005/32/EC) and Energy Labelling (92/75/EEC) framework Directives are 
significant steps as regard to product policy. A number of implementing measures have been already 
or are soon to be adopted and the ongoing amendments of the two Directives provide for their more 
ambitious and wider application. Do you consider that additional measures can be taken forward in 
order to increase the impact of these instruments? (compulsory)  

Yes 

No 

No opinion 

 In your view what should these measures be? (Max. 4000 characters) (optional)  

2.4. Lack of access to appropriate financing is an important bottleneck for making a real step 
forward in our ambitions on energy saving. Innovative financing instruments are now being 
developed by institutions such as EIB, EBRD, national promotional banks and private banks in 
particular in association with the Covenant of Majors initiative. Demonstration projects of the 
application of energy efficient technologies in a competitive manner, e.g. 'smart cities', could also 
be considered. Do you think other financing measures at EU level are needed? (compulsory)  

Yes 

No 

No opinion 

 What best mechanisms and ways forward where the EU value added can be substantial would 

you recommend? (Max. 4000 characters) (optional)  

2.5. Well targeted fiscal incentives could be a driver for energy efficiency investments and 
innovation. The EU has already taken measures to make it easy for Member States to allow for more 
advantageous VAT rates for some labour-intensive services, such as renovation and repairing of 

EN 

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private dwellings. Do you consider that additional measures at EU level need to be undertaken to 
shape consumer choices? (compulsory)  

Yes 

No 

No opinion 

 In your view what these measures should be? (Max. 4000 characters) (optional)  

2.6. Education and training on energy efficiency are vital ingredient of a successful energy 
efficiency policy. These were already mentioned above regarding buildings but the challenge is 
much broader. Do you consider that measures/actions at EU level to catalyze training at school and 
university level should be undertaken? (compulsory)  

Yes 

No 

No opinion 

 In your view what should these measures be as regards different target groups? (Max. 4000 

characters) (optional)  

2.7. Awareness of final consumers on energy savings possibilities and their benefits is still low. This 
in particular concerns domestic consumers and SMEs. Some actions to target different groups are 
already undertaken at national and EU level. For example, the Sustainable Energy Europe Campaign 
is focusing on grouping social stakeholders and market actors to undertake joint action. Do you 
think that further communication action at EU level is needed? (compulsory)  

Yes 

No 

No opinion 

 Which would be the content of such a communication strategy as regards each of the target 

groups concerned? (Max. 4000 characters) (optional)  

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2.8. Furthermore, small and medium size companies (SMEs) are the backbone of EU's economy as 
they make up more than 99% of all firms and employ 67% of the EU's workforce but may need more 
support for implementing energy saving measures. Do you consider that specific measures to target 
SMEs are necessary? (compulsory)  

Yes 

No 

No opinion 

 In your view what should these measures be? (Max. 4000 characters) (optional)  

2.9. Public sector should lead by providing best practice examples. Positive progresses have been 
made under the voluntary Green public procurement policy and the proposals for mandatory 
procurement of energy efficient products in the framework of the recast of the Energy Labelling 
Directive. The leading role of public authorities has also been emphasized under the recast of 
Energy Performance of Buildings Directive proposal. Do you consider that further actions at EU level 
should be undertaken? (compulsory)  

Yes 

No 

No opinion 

 What further actions would you suggest at EU level? (Max. 4000 characters) (optional)  

2.10. The role of energy utilities can be substantial but at present they have insufficiently 
developed a market for energy efficiency services. Ways to create adequate framework conditions 
for this market to take-up in liberalized electricity and natural gas markets should be sought, 
possibly in cooperation with the Regulators. Do you consider that actions at EU level should be 
undertaken? (compulsory)  

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Yes 

No 

No opinion 

 In your view what should these measures be? (Max. 4000 characters) (optional)  

2.11. Energy efficiency offers significant market opportunities. Do you consider that specific 
measures at EU level should be adopted to provide incentives for companies to enter these markets, 
in particularly as regards SMEs? (compulsory)  

Yes 

No 

No opinion 

 In your view what should these measures be? (Max. 4000 characters) (optional)  

2.12. In relation to the above question do you consider that there is a need for the introduction of a 
EU-wide White Certificate scheme? (optional)  

Yes 

No 

No opinion 

 How do you think this EU-wide scheme should be designed and what should the role of energy 

utilities be? (Max. 4000 characters) (optional)  

2.13. The Directive on energy end-use efficiency and energy services (2006/32/EC) already provides 
for national indicative energy savings target which differs from the ones for renewables and for the 
greenhouse gas emissions. Giving the increasing priority for ensuring that investment in energy 
consumption reduction are made in all Member States do you consider that a move towards binding 
targets is needed? (compulsory)  

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Yes 

No 

No opinion 

 How should these binding targets be set up and at what level? (Max. 4000 characters) (optional)  

2.14. Measurement and verification of energy savings is essential aspect for monitoring the results 
of any measures introduced at national and EU level. Although some targeted measures are being 
implemented, do you consider that more systematic and harmonized approach at EU level is 
needed? (compulsory)  

Yes 

No 

No opinion 

 In your view what should these measures be? (Max. 4000 characters) (optional)  

2.15. Energy efficiency should become a vector of international co-operation and a subject of 
international financing programmes, in particular regarding EU neighbouring countries. Do you agree 
with statement? (compulsory)  

Yes 

No 

No opinion 

 In your view what should these measures be? (Max. 4000 characters) (optional)  

3. Other remarks 

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3.1. Please add your additional remarks in the section below. (Max. 5000 characters) (optional)  

SUBMIT 

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Annex 3: Background document on the on-line public 
consultation 

EUROPEAN COMMISSION 
DIRECTORATE-GENERAL FOR ENERGY AND TRANSPORT 

DIRECTORATE D - New and Renewable Energy Sources, Energy Efficiency & Innovation 
Energy Efficiency 

Background Information Paper for the 

Public Consultation on the  

Evaluation and Revision of the  

Action Plan for Energy Efficiency (COM (2006) 545) 

Note: 

This background paper is being circulated for consultation to all parties concerned by 
the Action Plan for Energy Efficiency (EEAP). 

The sole purpose of the consultation is to contribute to the debate, collect relevant 
information and help the Commission develop its thinking in this area. 

This document does not necessarily reflect the views of the Commission of the European 
Communities, and should not be interpreted as a commitment by the Commission to any 
official initiative in this area. 

Parties concerned are invited to submit their comments no later than  
3 August 2009 by means of an online questionnaire, available at: 

http://ec.europa.eu/energy/efficiency/consultations/2009_08_03_eeap_en.htm 

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1. INTRODUCTION 

The European Community aims to promote energy efficiency and energy saving as it is the 
most  cost-effective  way  of  reducing  energy  consumption  while  maintaining  an  equivalent 
level  of  economic  activity.  This  supports  broader  Community  objectives  in  the  areas  of 
security of supply, climate change mitigation and improving competitiveness.  

On  19  October  2006  the  Commission  adopted  the  Action  Plan  for  Energy  Efficiency: 
Realising  the  Potential  (EEAP)8.  It  gave  an  outline  for  a  coherent  framework  of  legislation, 
policies and measures with a view to save a substantial part of the 20% of EU annual primary 
energy  consumption  by  2020.  It  proposed  a  selection  of  cost-effective  energy  efficiency 
improvement initiatives to be put in place and implemented until 2012. 

As  announced  in  the  Plan,  the  Commission  will  evaluate  it  in  2009  and  prepare  a  revised 
Action Plan, as requested by the European Council.  

This  document  initiates  the  Public  Consultation  that  precedes  the  preparation  of  the  revised 
Plan  and  allows  stakeholders  and  interested  parties  to  express  their  views  and  opinions  on 
issues they believe should be covered by the new Action Plan for Energy Efficiency. 

2.  THE  ACTION  PLAN  FOR  ENERGY  EFFICIENCY  AND  EU  POLICY 
OBJECTIVES 

The full implementation of the EEAP can offer significant reductions in energy consumption 
and  is  therefore  an  important  tool  towards  achieving  the  ambitious  20/20/20%  targets  for 
energy  consumption  and  greenhouse  gas  emission  reductions,  and  an  increased  share  of 
renewables by 2020, as endorsed by the Heads  of  State and  Governments during the spring 
2007 European Council9. 

The EEAP will lead to achieving the above objectives in a cost-effective manner as it will:  

(i)  increase  independence  from  energy  imports  which  will  contribute  to  the  EU 
security of supply objectives; 

(ii) contribute to EU economic growth and job creation;  

(iii) contribute to the reduction of greenhouse gas emissions and of the harmful impact 
of energy generation on the environment; and 

(iv) improve living conditions and comfort for citizens. 

The implementation of actions and measures of the Action Plan sector is therefore of prime 
importance for realizing the strategic objectives of the European Energy Policy. 

Moreover,  on  the  basis  of  Directive  2006/32/EC  on  energy  end-use  efficiency  and  energy 
services,  each  EU  Member  State  has  prepared  its  National  Energy  Efficiency  Action  Plan 
which  describes  the  energy  efficiency  improvement  measures  planned  at  national  level  to 
achieve the energy savings target of the directive, to be reached by way of energy services and 
other energy efficiency improvement measures. The Commission is currently assessing these 
plans. A Commission staff working document is to be published in mid-2009 and will present 

8 
9 

COM(2006) 545. 
7224/1/07, REV 1. 

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the results of this assessment. The national Plans are expected to also contribute significantly 
to the EU's energy saving targets and are complementary to the EEAP. 

The  EEAP  and  the  National  Plans  are  two  of  the  five  pillars  to  the  EU's  specific  energy 
efficiency policy.  The other three pillars are i) the legal framework notably for the building 
sector  and  energy  consuming  products,  ii)  flanking  policy  instruments  such  as  targeted 
financing and the provision of information and networks, and iii) international collaboration. 
The  Commission  stresses  that  the  full  implementation  and  enforcement  of  the  existing  and 
future  regulatory  frameworks  is  essential  and  the  Commission  will  continue  to  pursue  - 
through  legal  means  -  proper  transposition  and  application  of  Community  law  affecting 
energy efficiency. 

3. THE MAIN ELEMENTS OF THE ACTION PLAN FOR ENERGY EFFICIENCY 

The Action Plan outlines a framework of policies and measures with a view to intensify the 
process  of  realising  the  over  20%  estimated  savings  potential  in  EU  annual  primary  energy 
consumption  by  2020.  The  Plan  lists  a  range  of  cost-effective  measures  proposing  priority 
actions to be initiated immediately, and others to be initiated over the Plan's implementation 
period. 

The  Action  Plan  intends  to  mobilise  the  general  public  and  policy-makers  at  all  levels  of 
government, together with market actors, and to provide EU citizens with the globally most 
energy-efficient  infrastructure,  buildings,  appliances,  processes,  transport  means  and  energy 
systems. Given the importance of the human factor in reducing energy consumption, the Plan 
also  encourages  consumers  to  use  energy  in  the  most  rational  manner  possible  as  energy 
efficiency is also about informed choice by individuals. 

The current EEAP identifies six key areas with the highest potential for energy saving: 

•  energy performance requirements for products, buildings and services 

•  energy transformation 

•  transport 

•  financing and pricing 

•  energy behaviour 

•  international partnerships 

The current Plan also proposes 85 actions and measures to be taken at EU and national level. 
Among them, ten priority actions have been identified: 

•  appliance and equipment labelling and minimum energy performance standards 

•  adoption of building performance requirements and very low energy buildings 

•  making power generation and distribution more efficient 

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•  achieving fuel efficiency of cars  

•  facilitating appropriate financing of energy efficiency investments for SME's and 

Energy Services Companies 

•  coherent use of taxation 

•  energy efficiency in built-up areas 

•  raising energy efficiency awareness 

•  fostering energy efficiency worldwide 

•  spurring energy efficiency in the new Member States 

4.  CURRENT  IMPLEMENTATION  OF  THE  ACTION  PLAN  FOR  ENERGY 
EFFICIENCY 

The implementation of the Action Plan is ongoing and will continue till 2012. The measures 
set forth in the Action Plan and its annex are expected to produce effects between 2006 and 
2012  and  many  of  them  already  between  2006  and  2009.  That  is  why  the  mid-term  review 
takes place this year, during the implementation period of the Action Plan. 

One third of the actions of the Action Plan have been completed. The remainder are ongoing 
and still need active commitment both at EU and national level. 

5. WHY THE ACTION PLAN FOR ENERGY EFFICIENCY NEEDS EVALUATION 
AND REVISION? 

There  are  strong  indications  that  with  on-going  actions  the  EU  will  not  be  able  to  reach  its 
saving  objective  for  2020.  In  its  Communication  'Energy  efficiency:  delivering  the  20% 
target'  (COM(2008)  772  final),  the  Commission  provided  a  quantitative  evaluation  of  the 
expected  impact  of  specific  energy  efficiency  legislation  and  measures  when  fully 
implemented.  First  hand  information  on  the  involvement  and  the  implementation  as  well  as 
other indicators suggested that the energy saving potential is not being realised fast enough: 
they  would  achieve  energy  savings  of  about  13%  by  2020  if  properly  implemented  by 
Member States. Even if this represents a major achievement, it falls short of what is needed. 
For this reason, all pillars of the EU's energy efficiency policy - including the EEAP - need to 
be reinforced. 

Recent studies indicate that the opportunities for energy savings are significant: the estimated 
energy  consumption  reduction  potential  in  2020  is  19%  for  industry,  20%  for  transport  and 
30% for the households and services sector.10 

There are a number of reasons why our energy saving potential is not exploited to the full: 

10 

Study  on  Energy  Savings  Potentials  in  EU  Member  States,  Candidate  Countries  and  EEA  Countries. 
Fraunhofer ISI et al; preliminary results.  

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• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

• 

Energy saving and efficiency is by its nature a result from numerous small actions at the 
final consumption level.  

The  Member  States  are  formally  implementing  the  current  EU  legislation.    However, 
more needs to be done to reap all benefits available. 

The  diversity  of  the  27  Member  States  is  even  more  evident  on  energy  efficiency 
policies  than  in  other  energy  policy  issues.  The  climatic  conditions,  consumers' 
possibilities to act, economic circumstances vary from one corner of Europe to another.  

Energy saving actions are needed at all levels of government including, but not only, the 
EU level.  

Consumers,  companies  and  households  are  the  final  decision  makers.  Consumer 
awareness on the benefits of energy saving, though on the increase, is still too low. In 
parallel,  the  political  decision  makers  are  not  eager  to  touch  upon  delicate  behaviour-
related issues. 

The financing of the energy saving investments is complex because of the small scale of 
the  individual  actions.  Unlike  other  areas,  such  as  renewable  energy  generation  and 
transport, financial incentives for households have been rather limited. Further, even if 
funding is available, the missing organisational and administrative structures have been 
preventing its use.  

Energy  prices  and  the  environmental  benefits  have  so  far  been  the  main  drivers  for 
energy saving. However, price do not yet fully internalise the environmental, social and 
economic  benefits  of  higher  energy  efficiency  (esp.  there  are  benefits  from  energy 
security not valued on markets).  

Job  creation  benefits  are  equally  important  to  justify  new  activities  in  the  deepening 
economic downturn in Europe. Concerns about security of supply add to the urgency of 
action. 

A  specific  problem  in  energy  saving  is  target  setting.  A  concrete,  verified  target  has 
proved  to  be  successful  in  many  sector  policies.  In  energy  saving,  the  results  are 
difficult to measure. 

Energy  efficiency  in  energy  production  and  supply:  a  dynamic  market  for  energy 
services  has not yet fully developed,  despite incentives created by the energy services 
directive  for  utilities to invest in energy efficiency and to  promote an energy efficient 
behaviour of their customers 

In many Member States architects, builders and installers have not received training or 
have not certified their skills in order to implement energy efficiency practices.  

The above list is not exhaustive but provides indications and avenues on how more energy can 
be saved and the actions to be taken to make that happen. Of course, additional challenges and 
avenues can be identified and proposed. 

In its Energy Efficiency Package of November 2008, the Commission presented the over-all 
policy  lines  and  first  rough  estimations  on  the  expected  impacts  of  the  current  policy 

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portfolio. In this context, the Commission also made a number of proposals to strengthen the 
legal  framework  for  energy  efficiency.11  The  impact  assessments  that  accompany  these 
proposals show the significant potential impact thereof and will serve as an important source 
of information for the evaluation of the EEAP. 

6. ISSUES FOR CONSIDERATION IN THE CONTEXT OF THE PREPARATION OF 
A NEW ENERGY EFFICIENCY ACTION PLAN  

A brief but not exhaustive overview of some of the challenges arising out of implementation 
of the present Action Plan is set out in the previous sections. The new EEAP will start from 
analysis of the successes and failures of the current one. The Commission will carry out this 
evaluation in particular on the basis of the observations and comments made by third parties 
under this Public Consultation. 

The list of priority issues that will be discussed in the new Action Plan for Energy Efficiency 
are the following: 

(1) 

(2) 

(3) 

The existing Energy Performance of Buildings Directive (2002/91/EC) and its recast, 
as  well  as  other  relevant  legal  acts,  go  a  long  way  for  introducing  ambitious  but 
realizable  energy  performance  requirements  for  buildings  and  increase  consumers' 
awareness.  However,  much  more  can  be  done.  For  example,  measures  on  how  to 
stimulate  rapid  uptake  of  training  of  architects,  builders  and  installers  need  to  be 
considered.  Further  discussion  is  also  needed  on  whether  EU  should  move  towards 
fixing  agreed  date  for  all  new  build  to  be  very  low  or  zero  energy  and  carbon  and 
adopt a roadmap towards this. 

Sustainable  transport  and  energy  consumption  of  cars  is  currently  addressed  in  the 
Greening transport package12, the Regulation on Emission performance standards for 
new  passenger  cars13,  the  proposed  Directive  on  labelling  of  tyres14,  the  proposal  on 
greening  car  taxation15  and  the  'Green  Cars'  initiative.  The  Commission  is  also 
working  on  a  proposal  on  light  commercial  vehicles16  and  a  revision  of  CO2/cars 
labelling.  Comments  are  needed  as  to  whether  additional  measures  need  to  be 
undertaken.  

The  Eco-Design  (2005/32/EC)  and  Energy  Labelling  (92/75/EEC)  framework 
Directives  are  significant  steps  with  regard  to  product  policy.  A  number  of 
implementing measures have been already or are soon to be adopted and the ongoing 
amendments  of  the  two  Directives  provide  for  their  more  ambitious  and  wider 
application. Suggestions should be made as to how these can be taken forward in order 
to increase their impact.  

(4) 

Lack  of  access  to  appropriate  financing  is  an  important  bottleneck  for  making  a  real 
step forward in our ambitions on energy saving. Innovative financing instruments are 
now being developed by institutions such as EIB, EBRD, national promotional banks 

11 
12 
13 
14 
15 
16 

See the European Commission's website for details. 
COM(2008) 433. 
COM(2007) 856. 
COM(2008) 779. 
COM(2005) 261. 
http://ec.europa.eu/environment/air/transport/co2/co2_home.htm 

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(5) 

(6) 

(7) 

(8) 

(9) 

and private banks in particular in association with the Covenant of Majors initiative. 
Demonstration  projects  of  the  application  of  energy  efficient  technologies  in  a 
competitive  manner,  e.g.  'smart  cities',  could  also  be  considered.  Comments  on  the 
best mechanisms and ways forward are needed.  

Furthermore,  well  targeted  fiscal  incentives  could  be  important  drivers  for  energy 
efficiency investments and innovation. The EU has already taken measures to make it 
easy for Member States to allow for more advantageous VAT rates for some labour-
intensive  services,  such  as  renovation  and  repairing  of  private  dwellings  and  is 
considering  further  how  energy  taxation  and  other  taxes  can  play  a  role  in  synergy 
with the EU ETS to achieve EU climate and energy objectives steps on products and 
other  services.  Comments  on  whether  additional  measures  need  to  be  undertaken  to 
change consumption patterns are needed. 

Education  and  training  on  energy  efficiency  are  vital  ingredients  of  a  successful 
energy efficiency policy. These were already mentioned above regarding buildings but 
the  challenge  is  much  broader.  Measures  on  ways  to  catalyze  training  at  school  and 
university level need to be identified and discussed. 

Awareness of final consumers on energy savings possibilities and their benefits is still 
low.  This  in  particular  concerns  domestic  consumers  and  SMEs.  Some  actions  to 
target different groups are already undertaken at national and EU level. For example, 
the Sustainable Energy Europe Campaign is focusing on grouping social stakeholders 
and  market  actors  to  undertake  joint  action.  Further  consideration  of  the  appropriate 
level and means to better engage these groups is needed. 

Furthermore,  small  and  medium  size  companies  (SMEs)  are  the  backbone  of  EU's 
economy  as  they  make  up  more  than  99%  of  all  firms  and  employ  67%  of  the  EU's 
workforce. Consideration should be given as to the best means to provide them with 
more support for implementing energy saving measures. 

Public  sector  should  lead  by  providing  best  practice  examples.  Positive  progresses 
have  been  made  under  the  voluntary  Green  public  procurement  policy  and  the 
proposals for mandatory procurement of energy efficient products in the framework of 
the recast of the Energy Labelling Directive. The leading role of public authorities has 
also been emphasized under the recast of Energy Performance of Buildings Directive 
proposal but further measures should be envisaged. 

(10)  The  role  of  energy  utilities  can  be  substantial  but  at  present  they  have  insufficiently 
developed a market for energy efficiency services. Ways to create adequate framework 
conditions for this market to take-up in a liberalized electricity and natural gas markets 
should  be  sought,  possibly  in  cooperation  with  the  Regulators.  Further  questions  on 
how  these  framework  conditions  can  best  be  created,  for  example  through  possible 
EU-wide white certificate scheme, would also need to be considered. 

(11)  Energy  efficiency  offers  significant  market  opportunities.  Measures  to  provide 
incentives for companies to enter these markets need to be considered, in particularly 
as regards SMEs.  

(12)  The Directive on energy end-use efficiency and energy services (2006/32/EC) already 
provides for national indicative energy savings target which differs from the ones for 

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renewables  and  for  greenhouse  gas  emissions.  Giving  the  increasing  priority  for 
ensuring  that  investment  in  energy  consumption  reduction  are  made  in  all  Member 
States  the  question  arises  as  to  whether  it  is  the  time  now  to  move  towards  binding 
"energy efficiency" targets. 

(13)  Measurement  and  verification  of  energy  savings  is  a  challenging  but  very  important 
aspect for monitoring the results of any measures introduced at national and EU level. 
Some  targeted  measures  are  being  implemented  but  whether  a  more  systematic  and 
harmonized approach is needed should be considered. 

(14)  Energy efficiency should become a vector of international co-operation and a subject 
of  international  financing  programmes,  in  particular  regarding  EU  neighbouring 
countries.  Measures to this effect need to be identified and discussed. 

Specific questions highlighting these issues are included in the online questionnaire, available 
at: http://ec.europa.eu/yourvoice/index_en.htm  

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