Letter to Commissioners - Eurelectric

Brussels, 8 February 2012
Letter addressed to
Commissioner C. Hedegaard
Commissioner G. Oettinger
Commissioner A. Tajani
POLICY COHERENCE: CONFLICTING MESSAGES ON FUNDAMENTAL METHODOLOGY FOR ENERGY-USING
PRODUCTS
Dear Commissioner,
We write regarding the review of the classes of energy-using products covered by the Ecodesign and Energy Labelling
Directives. Our companies are concerned about conflicting messages received, and negative impact on the investment
climate.
In December 2011 the European Commission released the Final Report “Methodology for Ecodesign of Energy-related
Products” (MEErP). According to the project website, it provides the Commission with an update and extension of the
existing methodology for the Ecodesign of Energy-using Products (MEEuP). 1
EURELECTRIC is surprised to see that the MEErP report establishes that renewable energy sources (RES) have had, and
will have, no impact in reducing primary energy use in electricity generation – past, present or future. Accordingly, we
are disappointed that the report therefore proposes to penalise the use of electricity in energy-using products, and in
this way promotes the direct-use of carbon emitting technologies, like petrol or gas in heating.
We now understand that the Commission Services in charge of Ecodesign and Energy Labelling are in the process of
drafting regulations for products that will codify the MEErP report into EU law.
Does this mean that the Commission is of the opinion:
That over the next 30 to 50 years the volume of primary energy needed to generate electricity will remain
substantially unchanging, and thus current EU policies (RES, ETS, IED) will have little or no impact on the power
sector?
That the 2020 RES target in particular will have no impact on primary energy needed, thus having no impact on
improving security of supply? If this is the case, we ask how it is RES can contribute to reducing carbon emissions
in the power sector?
That reducing direct GHG emissions in households and transport “little-by-little” or “step-by-step” by means of
investment cycles taking 10 to 30 years (in the heating sector) will deliver the 2050 objectives?
EURELECTRIC is strongly committed to meeting the EU 2020 climate and energy targets and – with an adequate policy
framework to enable cost-effective investments in low-carbon technologies – committed to the 2050 goals. We
believe that decarbonisation will require a paradigm shift in energy end-use and that, as recently recognised by the
European Environment Agency, electricity has a major role to play. Electricity has no direct carbon emissions at the
point of consumption and its end-user indirect emissions are capped and progressively reducing under the ETS. 2
1 http://ec.europa.eu/enterprise/policies/sustainable-business/ecodesign/methodology/index_en.htm
and www.meerp.eu/index.html
2 “End-user GHG emissions from energy”, Technical Report No 19/2011: www.eea.europa.eu/publications/end-use-energyemissions?utm_source=EEASubscriptions&utm_medium=RSSFeeds&utm_campaign=Generic
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

We therefore urge that, in order for the Commission to deliver on the EU vision, Europe cannot afford to squander
resources by investing in assets (appliances, infrastructures) that will become stranded within a decade. This is
particularly true at a time of financial difficulty for governments, citizens and business.
I propose a meeting between your and our experts to find ways to ensure policy coherency on the role of energyusing
products, starting with the current programme of work on Ecodesign and Energy Labelling.
Yours sincerely,
Hans ten BERGE
Secretary General
Encl : 1 Annex

Annex
On Page 54 of “Methodology for Ecodesign of Energy-related Products - MEErP 2011, Methodology Report, Part 2:
Environmental policies & data”, Final Report 3 , it is stated:
Following initial debates, the fixed efficiency value of 40% actually used in the preparatory studies was a long term
average over the product life of most products (i.e. over the period 2005-2025). The primary energy factor pertaining
to this efficiency is 2.5 (1 kWh electric = 2.5 kWh primary energy).
For the period up to 2030, i.e. when analyzing products with a life less than 20 years, the factor 2.5 still seems a robust
fixed value to be used in preparatory studies. According to PRIMES, the average efficiency of conventional thermal
power plants is progressing only slowly. The share of renewable energy sources and natural gas will increase, but the
increased use of biomass, coal and nuclear energy will reduce this positive effect.
For building components with a product life of 40-50 years, like window frames, insulation panels, etc., the primary
energy conversion factor of 2.4 (efficiency 41.7%) can be assumed.
The above-mentioned three paragraphs contain an impressive amount of imprecise or wrong statements. Specifically:
First paragraph: it is said that 2.5 is based on “long term average”. However, all evidence shows that primary energy
content in electricity has constantly reduced over time. Last data available showed that the EU average was close to
2.5 already in 2009. The impact of 2020 targets (RES, ETS) and other environmental legislation (IED) will impact
furthermore the historical trend. If 2.5 is the long term average, then no additional improvements are expected in
electricity systems.
Second paragraph: references to PRIMES model are all systematically wrong. In particular:
The second sentence “According to… slowly” is technically correct, but it omits to say that the share of
conventional thermal power plants reduces. But electricity is generated not only by these plants: the growing
share of RES, and the impact it will have on reducing primary energy use, is ignored;
The third sentence is wrong in two aspects:
o In any of the scenarios produced by the European Commission since 2002 coal and nuclear share will
grow in the long term;
o The definition of thermal power plants in PRIMES includes natural gas, biomass and coal. The
sentence is therefore irrelevant in arguing for effects compensating the role of RES: the RES share
will grow, the share of conventional power plants will reduce while the overall efficiency of thermal
technologies will remain substantially the same. But as the share reduces, the primary energy
needed reduces as well.
Third paragraph: this reflects the wrong assumption made in the previous two paragraphs, where it is wrongly
assumed that electricity generation is equal to thermal electricity generation.
3 http://www.meerp.eu/downloads/MEErP%20Methodology%20Part%202%20Final.pdf