Letter addressed to: Environment Ministers Energy ... - Eurelectric

Letter addressed to:
Environment Ministers
Energy Ministers
Brussels, 17 April 2013
Subject: Impact of electrification of transport and heating on air quality
Dear Minister,
We write regarding the review of the EU Air Quality Policy and the important role electricity has to
play in the improvement of air quality and health in Europe. Electricity has no emissions at the
point of use and, when used in transport and heating/cooling for instance, can significantly
contribute to improving air quality in cities and urban areas.
The electricity sector has significantly reduced its emissions over the years. Between 1980 and
2009 emissions of SO₂ and NOx were reduced in the EU-27 by around 80% and 57% respectively,
while electricity demand grew by 75%. The implementation of the EU environmental legislation
and the move to a decarbonised power sector will lead to a further decline in emissions from the
power sector. Furthermore the decoupling of electricity generation and emissions means that the
emissions per unit of electricity generated will decline steadily.
The EU electricity sector is strongly committed to reducing carbon emissions and meeting the EU's
climate targets for 2020 and its 2050 climate vision. We are also convinced that electricity will
have to play a much greater role than now to contribute to the decarbonisation of transport and
heating/cooling. This is confirmed by the Commission's Energy Roadmap 2050 and the European
Environment Agency. EURELECTRIC believes that 2013, the 'Year of Air', is a unique opportunity to
show that electricity brings wider benefits in helping the shift towards sustainable transport and
residential sectors: it can not only help to de-carbonise others sectors, it can also help to depollute
them.
EURELECTRIC welcomes the opening of the debates on the EU's policy instruments beyond 2020
both for climate and energy and air quality. Clarity on the 2030 framework and, in particular, on a
CO₂ reduction target are urgently needed to ensure that electricity companies can invest to put
the sector on track for Europe's transition towards a low-carbon energy system. It is crucial that
developments in EU Air Quality policy are assessed in a framework which is consistent with EU
energy and climate policy developments. For these reasons, 2030 is a more appropriate date for
more ambitious emission ceilings as by this date it is expected that the power sector across
Europe will be significantly decarbonised (with co-benefits for air quality emissions).
Union of the Electricity Industry - EURELECTRIC AISBL . Boulevard de l’Impératrice, 66 - bte 2 . B - 1000 Brussels . Belgium
Tel: + 32 2 515 10 00 . Fax: + 32 2 515 10 10 . VAT: BE 0462 679 112 . www.eurelectric.org
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In this context, we welcome initiatives such as the recent proposals on clean transport fuels and
the expected urban mobility package. However, we would like to stress that the current
legislative framework still promotes the direct use of carbon-emitting fuels such as petrol or gas in
heating ahead of electricity, contradicting the direction set in the 2050 Energy Roadmap. The
persistent use of a 2.5 energy efficiency conversion factor for electricity in the EU legislation,
established before climate change became an issue and carbon reduction targets were developed,
does not reflect the evolution of the electricity mix. It results in a lock-in of fossil fuel solutions for
a considerable period and prevents EU citizens benefiting from electrification. Taxation should
also be aligned with Europe sustainability goals. The legislative framework should ensure that
electrification can contribute to the achievement of policy objectives aimed at reducing CO₂, NO₂
(transport/diesel in urban centres) and PM10 (coal/solid fuels for residential heating) emissions in
particular. You will find in Annex references to the main texts which could support electrification
goals.
Looking forward to your reaction and happy to respond to any questions or comments you may
have.
Encl : 1 Annex
Best regards,
Hans ten BERGE
Secretary General
Union of the Electricity Industry - EURELECTRIC AISBL . Boulevard de l’Impératrice, 66 - bte 2 . B - 1000 Brussels . Belgium
Tel: + 32 2 515 10 00 . Fax: + 32 2 515 10 10 . VAT: BE 0462 679 112 . www.eurelectric.org
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Annex
Directive 2012/27/EU on energy efficiency and repealing Directives 2004/8/EC
(cogeneration) and 2006/32/EC (energy end-use efficiency and energy services)
The recently revised directive has kept the primary energy conversion factor introduced in a
footnote to Annex II of the now repealed Directive 2006/32/EC on energy end‐use efficiency
and energy services (Energy Services Directive) as a suggestion for Member States who “[f] or
savings in kWh electricity (…) may apply a default co‐efficient of 2.5 reflecting the estimated
40% average EU generation efficiency (…)”.This would mean that 2.5 kWh of primary energy is
needed to generate 1 kWh of electricity. However, as the efficiency of power stations
improves and the proportion of electricity from renewable sources increases, the average
conversion factor is in reality reduced overtime.
This energy efficiency metric is an historic concept derived from oil crises of last century when
oil represented 27% of OECD generation (1973) as opposed to 2% today (2010) and from a
time where the challenges of climate change were not an issue at all. It assumes all forms of
energy are equal, i.e. 1kWh lignite = 1 kWh PV, and the carbon constraint is ignored. This
reliance on a static, historic looking timeframe leads to anomalies in the treatment of
electricity and even more seriously – it locks in CO₂ and air pollutants-emitting technologies.
To reach the challenging targets for greenhouse gases and air pollutants emissions, energy
end-use must be based on CO₂-free energy carriers such as electricity. Fossil fuels should be
concentrated in large plants where carbon capture and storage can be applied.
Directive 2010/31/EU of 19 May 2010 on the Energy Performance of Buildings (EPBD)
The EPBD requires that Member States define a primary energy conversion factor for
electricity, to be used in assessing a building’s calculated energy performance against the
standards set. The Directive overemphasises primary energy efficiency without any
consideration of the interaction with other energy and environmental policy objectives. This
will seriously inhibit the substitution of electricity for fossil fuel use in heating and contribute
to lock-in CO₂ and air pollutants emissions for energy end-use for the lifecycle of the building.
Emphasis on primary energy is confirmed in supplementing Regulation (EU) n°244/2012
establishing a comparative methodology framework for calculating cost-optimal levels of
minimum energy performance requirements for buildings and building elements, and its
accompanying guidelines.
Directive 2009/125/EC establishing a framework for the setting of Eco design requirements
for energy‐related products
Directive 2010/30/EU on the indication by labelling and standard product information of the
consumption of energy and other resources by energy-related products
Union of the Electricity Industry - EURELECTRIC AISBL . Boulevard de l’Impératrice, 66 - bte 2 . B - 1000 Brussels . Belgium
Tel: + 32 2 515 10 00 . Fax: + 32 2 515 10 10 . VAT: BE 0462 679 112 . www.eurelectric.org

This is illustrated by the latest texts adopted on space and water heaters. When a single scale
is used for appliances which may be powered either by electricity or by alternative energies,
the use of a primary conversion factor of 2.5 discriminates against the use of electric
appliances, as their efficiency is deemed, in effect, to be no more than 40%. While the
maximum output efficiency of electric water heaters is deemed not to exceed 40%, the least
efficient domestic hot water boilers are deemed to have a minimum of 70%. This introduces
discrimination between appliances and energy sources and locks in CO₂ and air pollutants
emissions for the life-cycle of the product. This is particularly detrimental as electrical
appliances, and water heaters in particular, are the most cost‐effective way to integrate
electricity generated from renewable sources through developing controllable demand‐side
measures which can adapt instantaneous demand to the fluctuating supply that is typical of
renewable sources such as wind.
Proposal for a Council Directive amending Directive 2003/96/EC restructuring the
Community framework for the taxation of energy products and electricity COM (2011) 169
EURELECTRIC welcomed this initiative, in particular the introduction of a CO₂ tax for the non-
ETS sectors which would contribute to a level playing field and to an overall least cost
approach to reducing CO₂ emissions. EURELECTRIC supports linking the CO₂ component to the
ETS carbon price and automatically adjust it on a regular basis (e.g. annually) to reflect the
development of the carbon price. We also support the "proportionality principle" foreseen in
the initial proposal and urge policymakers to ensure that negotiations do not lead to a
discrimination against the use of electricity in heating and transport, e.g. in the form of heat
pumps or electric vehicles.