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The important issues of energy efficiency and the development of renewable energies must, in principle, be considered separately. The ‘energy efficiency first’ principle must not overstretch the energy efficiency targets in order to achieve the climate objectives.

Filed in German · English published by the European Commission

Deutsche Umwelthilfe (DUH) would like to stress that currently, the EED, like the other elements of the Clean Energy for All package, are inconsistent with the ambition of the Paris Agreement, as action in the next 10 years will be decisive in reaching the 1.5°C objective. We fully support the initiative to revise the EED and stresses that the ambition level needs to increase significantly.

The FGW is committed to ensuring that the efficient use of energy is of the utmost importance with the increasing share of renewable energy sources. However, energy efficiency should not only be seen as an absolute savings target, but should also take into account, for example, the increased need for flexibility due to an increasing share of renewable energy.

Filed in German · English published by the European Commission

Strengthening of the Energy Efficiency Directive DUH is calling for the adoption of a binding energy efficiency target of at least 45 % in the year 2030 (compared to the EU Reference Scenario 2007 or of at least 20 % in 2030 compared to the EU reference scenario 2020). This will help to achieve the 1.5°C target of the Paris Agreement, improve the energy security of the EU, create jobs, and reduce pollution.

The Austrian gas and district heating industry supports the objective of net-zero greenhouse gas emissions by 2050 and sees the period up to 2030 as an important intermediate step. In this context, the EU Energy Taxation Directive (ETD) can be an effective, market-based instrument to give appropriate price signals to energy consumers and thus achieve a targeted change in consumption patterns in line with climate…

Filed in German · English published by the European Commission

Environmental Action Germany (Deutsche Umwelthilfe, DUH) notes that the many tax exemptions in the Energy Taxation have led to a very disparate and complex energy tax landscape in Europe, which also hinders the integration of the internal energy market.

The recent publication of the 2030 Climate Plan by the European Commission increased the overall GHG emissions reduction target for 2030 from -40% up to -55% (vs 1990 level). The long-term reduction goal for 2050 remains unchanged, but the new plan asks for an acceleration across multiple sectors in the next decade.

The car CO2 standards represent the primary EU policy instrument driving the transition to zero-emission road transport. Current standards are not in line with the Paris Agreement, and several elements of the regulation limit its effectiveness. These shortcomings must now be addressed, and the overall ambition significantly increased to set road transport on a rapid path to zero emissions within the next few years.

DUH welcomes the opportunity to submit feedback on the European Commission (EC) proposal for revised car CO2 standards. Road transport emissions have been rising over the last 30 years. Without fast and significant reductions in passenger car emissions, the EU won’t be able to meet its own climate targets, let alone the 1.5°C limit.

The Austrian gas industry has been making a significant contribution to methane emission reduction for decades. In principle, a uniform "monitoring and reporting" system is positively recognized. However, it must be ensured that no blanket measures are taken, e.g. a general reduction of methane emissions by a fixed percentage without taking the initial situation into account.

Deutsche Umwelthilfe / Environmental Action Germany welcomes the opportunity to comment on the initiative at this stage. Regulating methane emissions in the oil, gas and coal sectors is indeed a powerful tool and necessary in mitigating GHG emissions and meeting climate targets.

Environmental Action Germany (DUH e.V.) welcomes the Methane Regulation proposal as it will for the first time impose binding rules regarding methane leakage on operators of energy infrastructure within the EU. Particularly positive are the new provisions on Measurement, Reporting and Verification (MRV) of methane emissions, regular inspections by regulatory agencies, as well as the requirement of quarterly Leak…