- Energy Efficiency First Principle. We welcome the fact that it is enshrined in the EED as a compulsory test in relevant legislative, investment, and planning decisions as long as it always ensures full compliance with the EU’s climate targets, incl. GHG emission reductions. EEFP should be understood as an overarching principle to be applied in conjunction and compliance with other policy objectives in a system approach paying attention to security of supply and the transition to climate neutrality.
- Energy Efficiency Target. We support an upward revision of the target. The target architecture and the enhanced monitoring role of the Commission should go hand in hand with additional support and guidance for Member States to implement the measures needed to reach the higher ambition. We warn caution on the specific level of ambition of targets’ increase, which can be challenging for some to match.
- Energy saving obligations. The energy savings obligation of annual reduction applied to Member States from 2024, (i.e. from 0.8% to 1.5%) is too high. Especially in combination with the necessary tightening of the eligibility of the measures, as detailed by Annex V.
- Primary Energy Factor. We welcome the fact that the EU PEF of 2.1 is proposed as a default number. The PEF value for electricity should be dynamic and forward looking, taking into consideration both the lifespan of the measure and the future energy mix. The possibility of national deviations from the default PEF value is seen positively. It should however be considered as a provision that promotes a downward revision of national PEFs.
- Eligibility of the use of fossil fuel combustion technology for savings obligations. We are supportive of the gradual phase-out of the use of fossil fuels as indicated in Annex V. The deadline of 2024 is premature.