ECOS welcomes the European Commission’s adopted Communication for ‘An EU Strategy on Heating and Cooling’, which seeks to decarbonise the sector, reduce energy imports, and cut costs for households. The Heating and Cooling sector has long since remained an untapped source of potential and the Europe Union should move swiftly towards the realisation of carbon saving goals, taking a long-term perspective that fully values energy efficiency, demand-side resources and climate-friendly alternatives.
Smart Buildings can play a transformative role in improving the security, sustainability and competitiveness of Europe’s energy system, which will require a number of steps to harness their potential. The European Commission correctly identifies automated management of energy demand as a means to enable consumers to participate in Demand Response, which has otherwise proven difficult to achieve in the residential sector. In this regard, actions to incentivise the take-up of interoperable ‘smart building solutions, systems and appliances’ are welcome, but much work remains to be done in the recognition of energy efficiency and demand response as equal partners with supply-side options. Moreover, standardisation will play a crucial role supporting the interoperability of Smart Buildings, notably between Smart Meters, Customer Energy Managers and Smart Appliances. Developments in this area remain problematic, with architectures undecided and data mapping across key interfaces unresolved. The European Commission should carefully consider how to identify and address such issues that would otherwise jeopardise Energy Union objectives.
ECOS supports the European Commission’s initiative to review relevant European standards, with a view to update requirements and harness the energy and climate saving potential of low global warming potential (GWP) refrigerants. Preliminary findings of the EC’s survey on ‘barriers to the uptake of low-GWP alternatives to HFCs related to standards, codes and legislation’ identified several obstacles in European standards that prevent the widespread uptake of low-GWP refrigerants. As demonstrated by a European Commission study on the performance of refrigerants, low-GWP alternatives serve not only to reduce the climatic impact of refrigeration, air conditioning and heat pump (RACHP) systems, but also improve their energy efficiency. Therefore, action to address barriers in standards should be as ambitious as possible, tackling so-called ‘human-comfort’ requirements, restrictive charge size limits for systems below ground and those systems installed without consideration of room size, as well as linking relevant standards with the ATEX Directive to reduce conformance costs of low-GWP system suppliers.
Sustainability of Biomass
ECOS supports the use of renewable, low-carbon fuels as primary energy source for heating and cooling in the EU. Increasing shares of sustainable biomass could make a significant contribution towards the decarbonisation of the heating and cooling sector. However, the European Commission should be mindful of the preventive measures needed to ensure the sustainable use of biomass feedstocks, whose recyclability needs to be guaranteed considering the finite nature of biomass as natural resource. The direct and indirect effects of biomass used for energy applications should also be properly addressed. In this regard, standardisation can contribute to setting sustainability criteria, methods for carbon accounting, and evaluation of direct and indirect land use change.