Under the European Green Deal, the Commission has committed to stronger action on climate change. It aims to assess how the EU’s greenhouse gas emissions could responsibly be reduced by at least 50% to 55% by 2030. Energy Efficiency is key to achieving these goals. We welcome European Commission’s proposal to update the Energy Efficiency Directive (EED), however we believe that further improvements to the proposal are needed. In our consultation response we summarised our key points:

1. With EED, Energy Efficiency First has become a guiding principle of the development of electricity infrastructure. However, the efficient use of existing infrastructure in reality is monitored only by assessing the grid losses. currENT promotes that grid efficiency should go beyond grid losses and must cater for cases where higher grid losses are counterbalanced by overall efficiency gain by avoided build-up of infrastructure. Energy Efficiency should not only be about losses but also about the optimised use of existing and future grids. 
2. Implementation of extended measures of energy efficiency are needed. As mentioned above, these measures should encompass not only grid losses but also avoided curtailment of low-cost in-feed. In particular, focusing incentives on decreasing grid losses does not incentivise CAPEX efficiency. Rather, output-based approaches linked with benchmarking of current efficiency are a possible good option. This will ensure “cost effective” energy efficiency from a system perspective.
3. It is important to establish cross-reference through the energy system that is based largely on networks (in particular power networks): no expansion of RES without optimal power networks and sector coupling; no optimized networks without efficiency of such networks. 
4. Create more synergies with the Renewable Energy Directive (RED) as well as the TEN-E Regulation aligning with the Green Deal and decarbonisation goals and measures. 

The update of the EED  by European Commission is planned for June 2021.