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currENT Feedback on Commission Proposal COM(2021) 559 for a recast Directive on Energy Efficiency

Fit for 55 Package

November 2021

Europe needs dramatically increased power system capability and flexibility in the coming decades to accommodate renewables. This must be provided for by increased interconnection, innovative grid infrastructure and far better utilisation of existing, planned and future electricity grids, e.g. by deploying new grid enhancing technology.

Neither the Commission’s proposal for a recast Energy Efficiency Directive (EED) nor any other element of the Fit for 55 Package, adequately addresses the need to rapidly and dramatically change the way we operate our existing electricity grids and how we apply new, innovative grid technology. Such solutions as dynamic line rating, modular power flow technology, and superconducting cable systems can play a crucial role in addressing the grid-barriers and inefficiencies in energy transmission that are already becoming apparent as we move towards an energy system, increasingly dependent on variable solar and wind power.

currENT strongly supports the Commission’s proposal to providing a solid legal basis for applying the ‘Energy Efficiency First Principle’ (EEF Principle) to energy efficiency improvements and energy network operation, planning and investment decisions.

The point-to-point approach to grid development, based on existing (HVDC) grid technology, will not deliver the Green Deal. Without innovation in network technology, and greater cross-border coordination, Europe will fail to deliver on its Paris Agreement commitment and achieve cost-effective and energy-efficient transition to decarbonisation before 2050.

We must apply grid enhancing technology to utilise existing grids more efficiently, while planning for less obtrusive and more environmentally friendly transmission and distribution technology. Innovative grid technology such as dynamic line rating, modular power flow technology, and superconducting cable systems are needed to unlock the current transmission backlog, overcome planning obstacles and address current technology deficiencies (e.g. low power intensities and high losses).

currENT supports the Commission’s proposal to clarify and enhance the role of National Energy Regulators in implementing the Energy Efficiency First Principle in the planning, development, investment and operation of gas, and electricity transmission and distribution networks.

The Commission proposal correctly recognises that “energy losses in energy transformation, transmission and distribution can be significant”. It also stresses the need for a uniform definition of energy losses within the Union, making it difficult to benchmark performance and compare networks and operators.

In this context, it is very difficult to understand why the Commission proposes to delete Article 15 (2a) in the existing directive which obliges the Commission to put forward “a common methodology in order to encourage network operators to reduce losses, implement a cost-efficient and energy-efficient infrastructure investment programme and properly account for the energy efficiency and flexibility of the grid”. The fact that the methodology was due almost a year ago is no reason to discard it. CurrENT proposes that the text be reinstated, possibly with another due date.

While references to the EEF Principle correctly is given appropriate attention in the Commission’s proposal, more attention could be given in the recast EED to the application of the ‘’Do No Significant Harm` principle.

currENT suggests that a reference is added in the articles of the recast Directive to the ‘Do No Significant Harm’ principle in a way that ensures that the Principle is applied to all gas, electricity transmission and distribution network planning, development and investment decisions.


The complete response can be accessed here.