CLC’s statement on the Government’s communication to Parliament on the Commission’s proposal for recasting the Energy Efficiency Directive of the European Parliament and of the Council

27.10.2021

The Finnish Parliament’s Commerce Committee has requested Climate Leadership Coalition (CLC) for a written expert statement on the Government’s communication to Parliament on the Commission’s proposal for recasting the Energy Efficiency Directive of the European Parliament and of the Council (U 48/2021 vp). CLC thanks the Commerce Committee for the opportunity to provide a statement on the Union Communication concerning the Commission’s proposal for recasting the Energy Efficiency Directive of the European Parliament and of the Council.

Statement

We consider that the Government’s Union communication raises just the right issues. It is good that the proposal for a directive promotes the supply of energy services. Selling energy services – heating, cooling, lighting, etc. –instead of energy would give energy suppliers an incentive to improve energy efficiency and facilitate materials recycling at customer sites.

Whereas energy efficiency is basically the goal pursued, we do not consider the best approach is to set an absolute target for the maximum consumption of energy as a whole. The Government communication illustrates the challenges that Finland would face were a binding target to be set for end and primary energy as a whole.

In our opinion, the goal is also at least partly incompatible with the growing role of the hydrogen economy pursued in the EU and may restrict the cost-effective use of emission-free energy for the production of hydrogen and its derivatives. The climate transformation of our societies and also the EU’s Green Deal rely heavily both directly and indirectly on the electrification required for the production of hydrogen and its derivatives. Hydrogen and its derivatives constitute the most significant potential to reduce greenhouse gas emissions in, for example, steel, cement and fertiliser production as well as in heavy-duty transport. However, increasing hydrogen production means a significant increase in the use of electricity.

We believe that EU countries should make maximum use of the potential of clean energy by taking advantage of geographical production conditions.

Setting a binding target for primary energy would give investors an unclear signal and could slow development in the sector.

More information: Jouni Keronen, CEO, Climate Leadership Coalition, jouni.keronen@clc.fi, p. +358 50 4534881 and Juha Turkki, Development Director, Climate Leadership Coalition, juha.turkki@clc.fi, p. +358 45 3461925