EED Recast Should not Block the Development of Efficient, Decarbonised Solutions

16 February 2022

The proposal to “recast” (ie, rewrite) the Energy Efficiency Directive (EED), presented by the European Commission in July 2021, is currently being examined by the European Parliament and Council. In that context, EUGINE calls on the co-legislators to correct some of the shortcomings of the Commission proposal, most notably the sidelining of efficient solutions such as combined heat-and-power (CHP).

In our proposal, we recommend including a definition of “sustainable cogeneration” into the text, to account for the capability of our technology to run on renewable and low-carbon gases, including hydrogen and hydrogen blends. In addition, we call for sustainable cogeneration to be promoted specifically in district heating.

In addition, we also call on policymakers to again include the efficient co-generation of heat and power with natural gas in the energy savings obligation. While CHP plants running on natural gas today should be shifted to operation with clean gases as soon as possible, the fact of excluding CHP from accounting towards the energy savings obligation hampers cost-efficient and simple solutions such as the coal-to-gas switch and disincentivises the installation of combined-heat-and-power units.

Finally, we also regret the repeated references to the EU Taxonomy. The taxonomy should not be made into an instrument to categorise all economic activities nor be used as a baseline for purposes other than directing financial flows towards environmentally sustainable activities.

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