Securing the EU’s energy system through efficiency: EBE’s response to the public consultation

The current geopolitical challenges underscore the critical importance of reducing our reliance on imported fossil fuels.

By prioritizing efficient buildings, the EU can lessen its vulnerability to price fluctuations and supply disruptions, strengthening its energy security. Today, roughly 75% of the EU building stock is energy inefficient, and around 75% of our heating and cooling needs are supplied from fossil fuel sources. Tackling energy efficiency in the building sector is essential to deliver a decarbonized and energy-independent Union.

  • At building level, renovations can lower energy demand by up to 80%. For every 1% of energy efficiency improvements, gas imports are reduced by 2,6%. The EU’s fossil fuel import bill is projected to drop by €33 billion by 2030 and €70 billion by 2040 thanks to energy efficiency gains.
  • At system level, efficiency, flexibility, and renewable energy as well as excess recovery technologies flatten demand spikes. A higher renovation rate can cut grid curtailment fourfold and postpone €44.2 billion in network upgrades.

The EU’s energy security framework helped secure access to fossil gas throughout recent crises, which came at a significant cost. According to Bruegel, “since the start of the energy crisis in September 2021, €540 billion has been allocated and earmarked across European countries to shield consumers from the rising energy costs.”

An updated energy security framework should put energy efficiency, renewable energy and flexibility solutions at its core. This would lower energy dependence on unreliable suppliers and improve our system’s resilience while addressing current affordability and energy poverty challenges.

read our response here

Acknowledge the potential of energy efficiency solutions in energy security and recognize these as strategic technologies for energy security.

Energy-efficiency solutions are mature and can be deployed quickly. They must be considered in the EU’s energy security framework as both tools to prevent an energy crisis and a means to strengthen the energy system’s resilience. In comparison, gas supply infrastructures require decades to be put in place, investments, and maintenance costs throughout their service. New investments in this infrastructure would go against the core objectives of the European Green Deal and increase the risk of fossil fuels lock-in in buildings.

Efficient Buildings Europe advises the European Commission to:

  • Apply the EE1st Principle to any additional energy infrastructure project.
  • Include a chapter on progress in energy efficiency and demand-side flexibility in Member States’ monitoring reports.
  • Develop a crisis prevention dimension to the risk preparedness plans, focusing on energy demand reduction and management measures.

Protecting EU citizens by establishing a clear link between delivering zero-emission building stock in Europe by 2050 and energy security

Efficient buildings can maintain comfortable indoor environments with less energy input, even during disruptions. This resilience reduces the need for emergency energy imports or over-reliance on a single energy source, particularly during extreme weather events like heatwaves or cold snaps, which are exacerbated by climate change. Efficient buildings also improve resource efficiency by lowering water consumption and increasing resilience in case of droughts.

They can also better integrate on-site renewable energy systems. Increased reliance on local renewable energy decreases vulnerability to international and regional energy market fluctuations and climate-related disruptions in energy supply.

The European Commission should:

  • Align the preventive plans from the Gas Supply Regulation (Article 8) with the national energy efficiency target and the National Building Renovation Plans.
  • Introduce provisions for public awareness campaigns and education programs on energy efficiency, targeting households and businesses to encourage behaviour change and the adoption of energy-saving technologies.

Guarantee coherence and coordination between EU frameworks for energy security, efficiency and electrification

The EU energy security, electrification, and energy efficiency frameworks should be better coordinated as they positively reinforce each other to deliver a more resilient energy system. Electrification is a primary driver of efficiency, enabling a shift away from fossil fuel dependency. By actively reducing energy demand, energy efficiency supports a more affordable and manageable electrification process. This helps manage the overall energy demand, especially during peak loads.

Recommendations on the Gas Supply Regulation

  • Article 4: The best practices and guidelines shared among the Gas Coordination Group should include short and long-term measures to reduce gas consumption.
  • Article 6: Energy efficiency measures are highlighted as potential alternative measures to security of gas supply requirements for protected consumers. However, their implementation falls on the Member States whereas ‘ensuring gas supply for protected consumers’ is a gas undertakings’ duty. The implementation of energy efficiency measures should fall on the latter as Member States will not be incentivised to take action. This could take the form of specific energy efficiency improvement targets for gas undertakings, to be realised to the benefit of protected consumers.
  • Article 8/Annex VI:
    • Align preventive plans with the national energy efficiency target and the National Building Renovation Plans. In the description of preventive measures, include ‘energy efficiency measures’ (point 5)
    • Apply the Energy Efficiency First as defined in Directive EU/2023/1791 to any additional energy infrastructure project. (Annex VI point 7)
    • Include requirements for Member States to evaluate and implement energy efficiency measures as part of their infrastructure planning. This could involve encouraging retrofits for buildings in grid-congested area.
  • New article: Introduce provisions for public awareness campaigns and education programs on energy efficiency, targeting households and businesses to encourage behaviour change and the adoption of energy-saving technologies.
  • Article 17: the monitoring reports must include a chapter on progress in energy efficiency and demand side flexibility and their impact on energy security.

Recommendations on Risk-preparedness in the Electricity sector Directive

  • The Directive should adopt a similar approach to the Gas Regulation and add a crisis prevention dimension to the risk preparedness plans. The preventive dimension of the plan should incentivise energy demand reduction and management measures.
  • Any long-term investment foreseen as part of the plans should respect the Energy Efficiency First Principle as defined in Directive EU/2023/1791
  • Demand side flexibility should be better integrated in the plans, adding aggregators to the list of relevant stakeholders to consult in the Annex for example.

Use efficiency measures to drive resilience and adaptation to climate change

  • Member States’ preventive strategies should better assess the potential impacts of climate change on energy and water consumption in the building sector and include solutions to address them.

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