Eurogas is the association representing the European gas wholesale, retail and distribution sectors. Founded in 1990, its members are 43 companies and associations from 22 countries.

Eurogas supports the Commission’s approach of limiting the review to specific Articles. The 2012 Energy Efficiency Directive only came into force in 2014 and has not yet been completely transposed by all Member States.

The actual delivery of energy efficiency gains is even more complex. Given that it is often based on individual circumstances, tailored solutions are necessary. Legislation which is overly prescriptive or limiting can make it very difficult to deliver projects. The over-arching objective as stated by the European Council1 is the reduction of greenhouse gas emissions. This should not be lost out of sight.

The proposal appears to favour energy efficiency measures via energy sources, such as electricity over natural gas, through a lower Primary Energy Factor, which is the means to compare the two. At the same time, no safeguards are proposed to counter the risk of perverse effects, i.e. that highly inefficient direct heating (e.g. electric radiators) is used or gas as a heating fuel is replaced with electricity based on coal, which is already the case. The result could very well be a decrease in efficiency and an increase in greenhouse gas emissions.

The “Eurogas views on the Energy Efficiency Directive and the Energy Performance of Buildings Directive” paper sets out how the proposals can be amended to prevent undesired effects, to increase the range of options and to make the achievement of greenhouse gas emissions reductions through energy efficiency more cost-efficient.

Read the full paper here. http://www.eurogas.org/uploads/media/16PP462_-_Eurogas_views_on_EED_and_EPBD.pdf