Category: Energy efficiency


The schedule for further procedure as regards new energy efficiency Directive is following:

24/11/2011   Council: debate or examination expected,

24/01/2012   EP: report scheduled for adoption in committee, 1st or single reading,

17/04/2012   EP plenary sitting (indicative date).


The EESC opinion issued on 26 October 2011 doesn’t, however, positively feed into the resolution of the main dilemmas undermining the initiative concerned.



According to the OEIL website ( the Proposal for a Directive of the European Parliament and of the Council on energy efficiency and repealing Directives 2004/8/EC and 2006/32/EC {SEC(2011) 779 final} {SEC(2011) 780 final} (COM(2011) 370 final) published by the European Commission on 22 June 2011 is currently awaiting Parliament 1st reading.


In the meantime the European Economic and Social Committee released an opinion (the source: on the said Proposal. The Committee adopted the opinion concerned at plenary session held on 26 and 27 October 2011 by 165 votes to 1 with 6 abstentions. In its opinion the Committee, inter alia, called on the Commission to ask Member States to consider increased and possibly binding measures for their entire building stock and appealed for a target figure of this kind to be set, together with appropriate financing and flanking measures and incentives (point 1.13 of the EESC opinion)


The Committee also felt that it would be appropriate to define "small and medium-sized enterprises" – this is in the context of the Article 7(1) of the Commission’s Proposal, which stipulates that Member States should encourage small and medium-sized enterprises, in particular, to undergo energy audits (point 5.3 of the EESC opinion).


Another recommendation of the EESC is to examine to what extent and under what conditions the benchmarking tools for emissions of CO2 and other polluting gases (BREF documents drawn up by the IPTS in Seville to support the former IPPC Directive and the 2010 so-called IED Directive on industrial emissions, and also used for the ETS and including energy efficiency benchmarks), could be used in the same way in the directive being the subject of the Commission’s Proposal (point 5.4.1.  EESC opinion).


The EESC opinion contains, however, very little consideration to what seems to be the most far-reaching initiative of the Proposal that is Article 10(6) which stipulates that Member States should ensure that, whenever an existing electricity generation installation with a total rated thermal input exceeding 20 MW is substantially refurbished or when, in accordance with Article 21 of Directive 2010/75/EC, its permit is updated, conversion to allow its operation as a high-efficiency cogeneration installation is set as a condition in the new or updated permit or licence, provided that the installation is sited in a location where the waste heat can be used by heat demand points.

This mandatory conversion of power plants into cogeneration plants will undoubtedly have the most vital impact on the power generation sector and the EESC opinion seems not to perceive this aspect of the Proposal.


EESC opinion seems also to concentrate excessively on the public sector obligations and the shape of the energy audits regime and does not put sufficient weight on another subject of greatest concern of the industry, being obligatory authorisation criteria that ensure that installations are located in sites close to heat demand points and that all new electricity generation installations and existing installations that are substantially refurbished are equipped with high-efficiency CHP units (Member States should, however, be able to lay down conditions for exemption from this obligation where certain conditions are met).


It is interesting that EESC opinion does not reflect the German Bundesrat (Federal Council) stance which, in its session on 14 October 2011, voiced strong criticism concerning the European Commission’s proposal. According to the publication ‘Bundesrat Critical of Commission Proposal for Energy Efficiency Directive’ (source: German Energy Blog - the Federal Council asked the government to make every effort to ensure that the Proposal will be fundamentally reworked.


Pursuant to the above-mentioned source, the Bundesrat also ‘warned that the proposals had wide-ranging effects for enterprises and public authorities. As its implementation entailed investments worth billions of Euros, without it being clear where the funding should come from, the proposal was not acceptable in the current form, the Federal Council said. Besides the Bundesrat demanded that the competitiveness notably of small and medium-sized enterprises must not be endangered and consumer protection aspects be accorded greater attention’.

All the above considerations indicate that the new energy efficiency draft Directive has yet a long way to go to become a binding law.