Double-counting fears hang over EU’s energy efficiency law


Experts warn about double-counting in annual energy savings as EU member states prepare their plans for the implementation of the newly agreed Energy Efficiency Directive.

Member states are expected in September to present their plans for implementing the directive at national level.

The new directive, agreed in June, is seen as the EU's main tool to meet its goal of cutting 20% energy consumption by 2020, but lawmakers in the European Parliament have already warned that the new law will fall short of that ambition. According to them, it will lead to cuts in energy consumption of only around 15-17% by the end of the decade. 

And experts fear this amount could decrease even more, explaining that it will all depend on how member states calculate the savings.


The main reason for worry relates to double-counting of national measures adopted under the directive.

The pillar of the directive is an obligation on utilities to invest in energy efficiency measures to deliver at least 1.5% cumulative annual energy savings on consumer bills. But member states have fought during the negotiations on the directive to include an exception – or a so-called opt-out – allowing energy companies to achieve this goal through other means. 

One way is to refurbish buildings to decrease their energy use. But this could overlap with another commitment taken by member states – the voluntary long-term strategies for the refurbishment of the existing building stock by 2050.

Adrian Joyce of EuroACE, an organisation representing several manufacturers of energy-efficiency products, said this method of calculating savings comes with its own “risks” as they could be hampered by rushed actions.

“I worry that, because it is under the energy efficiency obligations target, you might get some double-counting between long-term building renovation strategies and energy savings obligation schemes," Joyce told EURACTIV in an interview.

He said the quality of the savings that power utilities will be inclined to make will be less optimal, as they will probably look only for the "easy" measures.

EuroACE fears that rushed investments will create “the famous lock-in effect” whereby household owners implement single measures such as replacing a boiler with a more efficient one, allaying their conscience “for 30 years”. But Joyce said these quick fixes will not capture the long-term potential of improving efficiency.

National plans

Many experts worry that member states will be tempted to recycle existing national energy efficiency programmes and place them under the directive's umbrella, without taking new initiatives.

For example, Britain is likely to integrate the refurbishment of buildings under its planned Green Deal Scheme, which will be fully rolled out this year. And Germany will likely choose an existing and widely popular energy refurbishment programme for homes instead of annual energy savings for energy providers. 

Similarly, France could opt to integrate EU building renovation obligations into its existing national programme. Ireland, for its part, is looking into using energy performance contracting more effectively. And Sweden and Denmark will most likely integrate the new directive into their existing national action plans.

“Countries are likely to use their schemes if they already have good ideas and solutions in place to save energy,” said Brook Riley, of the environmental group Friends of the Earth Europe, which has pressed for a more ambitious European energy-savings law. 

But the exact savings will depend on how the directive is interpreted and the calculations may well differ. “This is going to be a real interpretation battle,” Riley said.

Europe aims to reduce its primary energy use by 20% by 2020, a target which is not legally binding.

The Energy Efficiency Directive was proposed by the European Commission in mid-2011 as part of its effort to reach this objective. The European Parliament and Council, together with the Commission, reached a deal on the proposed directive in June 2012. The directive:

  • Proposes individual measures for each of the sectors that could play a role in reducing energy consumption - apart from transport, which is voluntary - including a controversial obligation on energy companies to achieve 1.5% energy savings per year from their previous year's total consumption.
  • Asks member states to have long-term strategies for the energy-efficient refurbishment of Europe's building stock.
  • Introduces the refurbishment of public buildings, though only those owned by national governments.

The directive is seen as an important step in the future roll-out of smart meters and other energy-efficiency products and services.

  • Sept. 2012: Vote in Parliament plenary.
  • Autumn 2012: Vote in the Council (formality)
  • 1 Jan. 2013: Ireland takes over the EU presidency from Cyprus.
  • 30 April 2013: Member states submit their energy savings national targets, which together must bring the EU on its path to achieve 20% savings by 2020
  • 2014, 2016: European Commission reviews the Energy Efficiency Directive.

Business and Industry

  • Friends of Earth Europe: Website

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