Dear colleagues,

Just before the summer, the European Commission published a new Proposal for a Directive on energy efficiency that proposes among others, as already announced in the Energy Efficiency Action Plan in Spring, series of new provisions on energy efficiency targets, smart metering systems and energy service companies.

This topic has already been widely discussed within UIPI and its European Affairs Committee. During the summer, with the agreement of the EAC , the UIPI decided for the first time to join forces with 5 other organisations representing the all range of the real estate sector to prepare a common position on this topic and act together at EU level to promote our position. We believe that common action is an added-value that will give us more chances to influence the legislative process.

The directive proposes:
- No binding energy efficiency targets yet for 2020, but a two-steps approach with an analysis in 2013 of national energy efficiency action plans to evaluate the capacity of member states to reach the 2020 targets. If the measures taken at national level appear to be too limited to reach the 20% targets by 2020, the Commission will impose binding targets,
- A 3% renovation/year obligation ONLY for the public sector,
- A series of energy savings obligations for energy distributors,
- A roll-out of individual smart meters for final customers for electricity and natural gas (as planned in the directives on internal markets for energy in 2009), district heating or cooling and district-supplied domestic hot water,
- Promotion of energy service companies.

In our common position we stress among others that:
- Precision are needed for the definition of what is an energy distributor and energy sale companies, in order to make sure that landlords who pass on energy or resell energy to their tenants are not included in this definition and subjects to the obligations that are proposed for the distributor/retailer.
- The cost for the installation of smart meters can in some countries be the responsibility of owners and landlords (even if the Commission affirms that in most countries this would be the responsibility of energy distributors), so they should not be obliged to install this smart meters when it is not cost-effective and technically feasible. We could not oppose the full installation of smart meters altogether.
- The auditing obligation for big enterprise (does not concern UIPI members) is too frequent,
- The proposition made by the Commission to promote high efficiency cogeneration and efficient district heating and cooling systems should take into consideration the competition aspects in order to make sure that these systems (often previously state owned) do not distort free competition between energy providers to the detriment of the interests of the consumer, in particular to avoid monopole situations like in Sweden,
- The obligatory imposition at EU level of spatial planning requirements concerning residential zoning is too interventionist and prescriptive. There must be no compulsion on planners, owners and developers to choose between CHP or renewables, etc., according to location.
- There has been a lot of trouble between energy service companies and their clients. Reasons were weak contractual arrangements, unfair share between energy service companies (ESCO) and client and guarantees which in the end could not be exercised. The provision under the Directive of penalties for ESCOs when the (guaranteed) energy savings are not met could protect customers of those services and will prevent part of the problems.

The summary of the position will be soon translated in Polish, Italian and Portuguese. Any other translations, especially French and German are welcome.

YOUR PARTICIPATION IS NEEDED!!!!!!
The UIPI invites you to contact now your government authorities in charge of the issue and promote our position. Their input in the Council will be crucial and it is our change to promote our propositions. Some member states are already conducting consultations on the topic and they will all welcome your input. Please keep me inform of your action at national level. The Green party got the set of rapporteur on this topic in the European Parliament committee in charge and they are likely to make even more demanding propositions of amendments. Therefore acting at EU level is not enough. May I remind you that member states also play an important part in the adoption of a directive.
 

 EED_ELO EPF