EEPSo we have been waiting since 2009, and finally, finally, today, on the 8 March 2011 the European Commission at long last published its so-called Energy Efficiency Plan. This is an important document: already this year, both Heads of State and Government and Energy Ministers have highlighted the importance of this Plan in setting out how to close the 200 Mtoe gap to the 20% energy saving target - and therefore in meeting Europe's strategic objectives. Moreover the Low Carbon Roadmap, also published today, made crystal clear how critical the 20% energy saving target is to meeting our 2050 greenhouse gas emission reduction requirements.

Unfortunately, the European Commission - and in particular Mr Oettinger - has failed to rise to this call to arms. The document is extremely weak, mentions much that is already business as usual, and contains very little in the way of hard or concrete measures. Its own impact assessment does not guarantee that it will close the 200 Mtoe gap.

The main firm measures proposed are:

• a binding target for a doubling of the refurbishment rate of public buildings (to a low level)
• new energy efficiency criteria for public procurement
• a requirement on Member States to reduce the legal obstacles that result in split incentives e.g. for building renovations
• enhanced requirements for CHP to be used
• a requirement on Member States to establish energy saving obligation schemes on energy companies
• mandatory energy audits for large companies (but no mention of follow-up)
• an extended Ecodesign workplan
• some soft measures to encourage energy performance contracting and energy services companies, e.g. information compilation.

Some of these are good ideas, but very little detail is given, and a lot looks likely to be left to the discretion of Member States. We have to strongly hope that the legislative reviews of the Energy Services and CHP Directives - due out before the summer - will make some real substance of these proposals.

Unfortunately, these legislative reviews will not immediately become the vehicles for binding targets - which would ensure the right level of commitment, accountability and investor certainty that will enable the 20% target to be delivered. Rather than proposing these now, the Plan instead prefers to 'wait and see' in 2013 whether the indicative national targets and programmes that Member States are to put forward under the Europe 2020 Strategy will do the job. Only then, if it looks like there is still a gap, will the Commission propose binding national targets.

The odd thing is that Member States will already submit these 'Europe 2020' targets by April this year; in fact most of them already have. So far, it looks like they will amount to only around 14% savings, though the diverse format of the submissions makes them hard to aggregate precisely. It is therefore not really obvious why we need to wait another two years to find out that the ambition level is too low.

Finally the Plan's emphasis on the intergovernmental Europe 2020 framework is itself a cause for concern. This is a time when the governance of energy saving needs to be strengthened, by upgrading the existing legal framework of the National Energy Efficiency Action Plans and their indicative targets. Europe 2020 is a purely political framework, and the Plan's implication that it will become the new principal basis for energy savings targets and programmes is precisely a move in the wrong direction - away from a hard legal basis.

It is far from game over: the 20% energy savings target is one we cannot afford to miss, as the Roadmap published today and the current oil price spike make clear. It is just something of a pity that this long-awaited Plan did not put us further along the road to tapping the huge potential that is there and ready for the taking with just a bit more vision, boldness and leadership.

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