Ensure energy directives lead to real and effective energy savings

Substantial parts of EU energy legislation are being reviewed this year, aiming to improve efficiency, cut emissions, increase supply security and save money. But a number of requirements must be met before this can happen, write Marie Linder and Kurt Eliasson.

Marie Linder is the chair of the Swedish Union of Tenants and Kurt Eliasson is the CEO of SABO, the Swedish Association of Public Housing Companies.

The European Commission is currently producing a proposed revision of the Energy Performance of Buildings Directive (EPBD). This includes such things as energy performance certificates and nearly zero-energy buildings. The Commission will also submit proposed revisions of the Energy Efficiency Directive (EED), including, among other things, requirements for individual metering and billing and energy audits.

We need to introduce a new article in EPBD, incorporating a requirement for the verification of the energy performance of buildings, in order to have legislation that really promotes energy efficiency improvements. Actual performance is often poorer than the estimates calculated for newly-built houses and may also be worse than the statutory level. Verification would consequently ensure that new buildings actually achieve the energy performance prescribed by law. Each member state should formulate details of how to implement verification. Requirements that prescribe nearly zero-energy buildings would be ineffective without verification, with the risk of higher energy costs for consumers, an increase in the need for imported energy and an increase in carbon dioxide emissions.

Furthermore, we are aware that there is a need to retain the flexibility and subsidiarity regarding cost efficiency currently included in EED. It is self-evident that the directive should provide scope for national adjustments considering the significant variations between EU countries in terms of climate, energy systems, business models and building technology solutions. This particularly applies to Article 9 EED on metering. The individual metering and billing of heating in Sweden is not cost effective, nor does it result in energy savings. The reason is that the temperature of Swedish apartments is controlled centrally at 20 to 21 degrees to minimise energy use and the temperature cannot be increased by residents. Furthermore, heating is included in the rent which means property owners can achieve economies of scale and lower costs that benefit consumers by improving energy efficiency of buildings. The improvement of energy efficiency of heating in Swedish apartment blocks would cease if individual metering and billing became compulsory for heating, as property owners would not benefit from any savings if residents were paying for the heating bills.

The third piece of the jigsaw for assured energy efficiency improvements is for legislation to avoid a duplication of the requirement for energy performance certificates and energy audits. There is thus a need to supplement Article 8 EED on energy audits and energy management systems. Almost all of the energy for housing and property undertakings is used in the buildings they own, and there is a requirement for energy performance certificates for buildings. The Energy Audit Act has another requirement aimed at the same thing, which is unreasonable.

We now urge DG ENERGY to ensure verification of the energy performance of buildings contained in EPBD, retain the reservation for cost efficiency contained in Article 9 EED, and supplement Article 8 EED.