The energy efficiency directive - 2011/0172 (COD)
Fortum supports energy efficiency and believes that more efficient use of energy sources is of great importance. Energy efficiency has a primary role in achieving a low-carbon society and Fortum is actively working towards this goal. Fortum has a favourable view of the merger of the old CHP Directive and the old Energy Service Directive (ESD), as it strengthens the awareness of CHP and brings a more holistic dimension to the energy efficiency policy. Fortum has asked for a common heating and cooling strategy for the EU, but sees the new Directive as an important step forward within the heating and cooling plans drafted by the Member States. Fortum welcomes the Directive, as district heating and cooling (DHC) is acknowledged as an important technology in achieving a more energy-efficient society.
Fortum is, however, against an EU obligation to introduce mandatory savings targets allocated to distributors or electricity retailers through energy-savings obligation schemes. It is the energy users who must be directly motivated to create their own energy savings. The energy provider, of course, must be involved in offering tools and information to get consumers to make conscious decisions regarding their energy consumption. Furthermore, whenever considering such targets, early actions in each Member State must be taken into account.
Summary of Fortum's views
It is important to take into account the interdependency of energy efficiency and other climate and energy policy targets especially those of renewable energy sources and CO2 emissions in order to avoid conflicting incentives and requirements.
Fortum is against of setting mandatory energy savings obligation schemes for distributors or suppliers of energy and making them responsible for savings among their customers. Distributors and suppliers must provide their customers tools and information with the help of which customers can make conscious decisions with regard to their energy consumption.
Measuring heat in each separate apartment is neither reliable nor cost-efficient.
There must be a distinction between information and billing. It should be possible to agree with customers on a less-frequent billing cycle than once a month.
Fortum supports the idea of national plans for heating and cooling, and the support proposed for combined heat and power (CHP) production. Promotion of CHP, however, must be carried out in a market oriented manner; CHP obligation when building new power plants or renewing old ones will, if the heat in the region is already produced with CHP, lead only to increased costs and no efficiency improvements.
The EU should give guidance for national regulators on how to reward smart grid investments.
It is important to allow the use of different conversion factors, when justified, as electricity can be produced with renewables and without any CO2 emissions.