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
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
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.