COGEN Europe, the European Association for the Promotion of Cogeneration, supports the European Commission in developing a post-2020 Renewable Energy Strategy, where energy efficiency plays a key role in reinforcing renewable energies and easing the sustainability dimension of energy usage.

While the Commission’s Communication “Renewable Energy: a major player in the European energy market”, COM (2012) 271, touches upon some important points, such as power network adequacy, renewable electricity support schemes, possible renewable energy regimes for 2030, COGEN Europe believes that several relevant issues raised by the Stakeholder Consultation fail to be mentioned in the Communication.

Missing elements in EU’s renewable energy strategy

More specifically, COGEN Europe draws the Commission’s attention to the following aspects, which should be addressed at the EU level more effectively:

1. The complementarity of renewables and energy efficiency policies must be clearer

As the Energy Roadmap 2050 shows, energy efficiency is one of the “no-regrets options” to play a crucial role in all decarbonisation pathways to 2050.

It is therefore important to draw the link between renewable energy and energy efficiency and recognize the pivotal role that energy efficiency can play in: addressing the flexibility and capacity constraints linked to a liberalised electricity market and a higher share of renewables in the power mix; easing the sustainability dimension of energy usage.

Building on the above, COGEN Europe believes that the Commission should investigate how to incentivise, through for example well-designed heat and electricity markets, the building and operation of flexible power plants and CHP units in particular. In addition, the key principle that the use of any fuel source should be as energy efficient as possible must be better featured in Commission papers. In what regards bio-energies, the introduction of sustainability criteria at EU level is deemed as an important step.

2. Renewables in heat supply are not addressed

A major energy efficiency opportunity exists in an integrated approach to energy supply involving a view covering both heat and electricity demand and supply. Such an approach opens up new opportunities for innovative and highly efficient solutions.

COGEN Europe thinks that the Communication fails to address the untapped potential of renewable energy sources in the heat supply, despite the fact that heat demand for a wide range of applications makes up nearly half of the energy demand in the EU today. In addition, and according to the Impact Assessment of the Energy Roadmap 2050, heat consumption of industrial sites is forecast to strongly increase by 2050. This evolution of itself calls for establishing a decarbonising pathway for heat consistent with EU’s climate and energy security goals.

Given that the supply of renewable heat and cooling also contributes to EU’s renewable energy target in the Renewable Energy Sources Directive (2009/28/EC), the Commission should consider enhancing this framework.

It should be noted that while heat markets are local by nature and lack of a considered policy approach at EU level is a serious omission. COGEN Europe advocates for a more thorough analysis promoted at EU level and that Europe explore the policy options for better market design.

3. Promotion of distributed generation and local solutions should not be overlooked

One of the assumptions in the Energy Roadmap 2050 and the Commission’s recent Renewable Energy Communication Impact Assessment is that Europe will experience a shift from small-scale to large-scale renewable energy. COGEN Europe stresses that for heat in particular, decision makers must recognise that different heat “grades” are required by customers and that local solutions will continue to prevail in the future. In the case of electricity, more advanced and smart distributed generation systems will not only help in balancing and supporting the electricity systems but will also reduce and/or delay the need for infrastructure and minimise electricity transport losses.

While the European Union has started to assess the possible post-2020 renewable energy policy, COGEN Europe urges the European Commission to strive for an integrated approach to energy - electricity and heat - supply in the EU.

COGEN Europe - the European Association for the Promotion of Cogeneration

Avenue des Arts 3-4-5, 1210 Brussels, Belgium

Tel: +32 2 772 82 90 • Fax: +32 2 772 50 44 • Email: info@cogeneurope.eu • Website: www.cogeneurope.eu