1. RES and EE Targets (RED Art. 3)
The Energy transition will not happen without further replacing fossil energy with renewable sources of energy
(RES). However, EU’s ambition to engage this transition is not clear in the proposed revision of the RED. In fact,
the below graph compares the added RES consumption between 2010 and 2020 and what is foreseen by the
European Commission scenario (EUCO30: RES 27% - EE 30%) for the period 2020-2030. By choosing this level
of ambition, policy-makers are imposing a growth decrease to its own RES industry (creating about a million jobs
within its borders!).
EUCO30

A higher RES target and more consistency between energy efficiency and RES targets are needed
to truly engage the energy transition and promote a European innovative industry.
Because energy efficiency (EE) is mostly taking place in the building sector (therefore the H&C sector), the lack
of ambition is exacerbated in the heating and cooling (H&C) sector. The graph below compares additional RES in
the H&C sector between 2004 and 20014 (26 Mtoe) with the forecasted growth between 2020 and 2030 (5 Mtoe).
This data underlines the inaccuracy of the models used by the Commission in representing the sector and its
dynamics. Again, an important growth decrease is foreseen for RES in the H&C sector, which is worrying for
further investments.
Energy efficiency target increases automatically the percentage of RES: this should be factored in the objectives.
Additional energy from renewable sources for heating
and cooling in EU28 (ktoe)
EUCO30
20042014
0
5,000
10,000
15,000
20,000
25,000
30,000 ktoe
Source: National RES progress reports and Commission Impact assessment accompanying the proposal for
a revised Renewable Energy Directive
2. H&C objectives (RED Art. 23)
In the absence of binding RES targets at national level, it is crucial to have an ambitious set of provisions, to secure
investments and growth in RES consumption for the period 2020-2030.
Art. 23 provides that Member States will ‛endeavour to achieve an annual increase of 1% in the share of renewable
energy in the heating and cooling supplyʻ. In order to keep at least the same level of development (additional 26
Mtoe in 2020-30) of new RES-HC and avoid a lost decade for an innovative European industry,

Article 23 of the proposed revised RED should be made binding and more ambitious (at least
1.5%) than the Commission’s initial proposal for those Member States whose share of
renewables in the heat sector is lower than 50%;
Flexibility provisions should be envisaged for those MS performing well in the decarbonisation of their H&C
sector, not to add financial and administrative burden on their good results. The focus of Art. 23 should be put on
MS lagging behind in order to incentivize them to increase their RES share in the H&C sector.
Proposed Amendments:
Article 23
Mainstreaming renewable energy in the heating
and cooling installations
Article 23
Mainstreaming renewable energy in the heating
and cooling installations
European Commission proposal
Proposed amendments
1. In order to facilitate the penetration of renewable
energy in the heating and cooling sector, each
Member State shall endeavour to increase the share
of renewable energy supplied for heating and cooling
by at least 1 percentage point (pp) every year,
expressed in terms of national share of final energy
consumption and calculated according to the
methodology set out in Article 7.
1. In order to facilitate the penetration of renewable
energy in the heating and cooling sector, each Member
State with a share of RES in the heat sector lower
than 50% shall increase the share of renewable
energy supplied for heating and cooling by at least 1,5
percentage point (pp) every year, expressed in terms
of national share of final energy consumption and
calculated according to the methodology set out in
Article 7.
3. The increase set out in paragraph 1 may be
implemented through one or more of the following
options:
(a) physical incorporation of renewable energy in the
energy and energy fuel supplied for heating and
cooling;
(b) direct mitigation measures such as installation of
highly efficient renewable heating and cooling
systems in buildings or renewable energy use for
industrial heating and cooling processes;
(c) indirect mitigation measures covered by tradable
certificates proving compliance with the obligation
through support to indirect mitigation measures,
carried out by another economic operator such as an
independent renewable technology installer or energy
service company - ESCO providing renewable
installation services.
3. The increase set out in paragraph 1 may be
implemented through one or more of the following
options:
(a) physical incorporation of renewable energy in the
energy and energy fuel supplied for heating and
cooling;
(b) direct mitigation measures such as installation of
highly efficient renewable heating and cooling
systems in buildings or renewable energy use for
industrial heating and cooling processes;
(c) indirect mitigation measures covered by tradable
certificates proving compliance with the obligation
through support to indirect mitigation measures,
carried out by another economic operator such as an
independent renewable technology installer or energy
service company - ESCO providing renewable
installation services.
(d) other policy measures with an equivalent effect to
reach the increase set out in paragraph 1 such as
national fiscal measures or other financial
incentives;
3. Financial support for electricity from renewable sources (RED Art.4 to Art. 6)
When it comes to financial support to RES, AEBIOM is of the views that the most efficient way is to reinforce
systems for emission trading and taxation pricing of greenhouse gas emissions and other negative environmental
impacts.
AEBIOM welcomes the European Commission proposal to lay down the general principles of RES financial
support within the RED (Art.4) and to ensure that support granted is not revised in a way that negatively impact
supported projects (Art. 6).
However, since Art 4 objective is to allow Member States to apply support scheme to reach their Union objectives
(including RES targets), it is important to emphasize on the fact that not only electricity from renewable sources
can be supported but all energy from RES can.
In addition, when designing their support schemes from renewable sources, Member States should consider the
specific characteristics of different renewable energy technologies (e.g. cost, size, risk profile, project lead time,
ability to provide system services). This would ensure the most cost effective deployment of a sufficiently broad
portfolio of renewable energies to meet the EU’s renewables targets for 2030 and drive the long-term
decarbonisation objective of the EU economy. In the absence of national binding targets, the RES-D should
establish the right for Member States to design appropriate support mechanisms according to technology
characteristics and national market considerations.
Finally, in order to promote smaller projects and businesses, community groups or farmers, Member States should
be allowed to keep projects under 10 MW outside competitive bidding processes that tends to promote larger
projects.
Proposed Amendments:
Article 4
Financial support for electricity from renewable
sources
Article 4
Financial support for energy from renewable
sources
European Commission proposal
Proposed amendments
1. Subject to State aid rules, in order to reach the
Union target set in Article 3(1), Member States may
apply support schemes. Support schemes for
electricity from renewable sources shall be designed
so as to avoid unnecessary distortions of electricity
markets and ensure that producers take into account
the supply and demand of electricity as well as
possible grid constraints.
2. Support for electricity from renewable sources shall
be designed so as to integrate electricity from
renewable sources in the electricity market and ensure
that renewable energy producers are responding to
market price signals and maximise their market
revenues.
3. Member States shall ensure that support for
renewable electricity is granted in an open,
transparent, competitive, non-discriminatory and
cost-effective manner.
4. Member States shall assess the effectiveness of their
support for electricity from renewable sources at least
every four years. Decisions on the continuation or
prolongation of support and design of new support
shall be based on the results of the assessments.
1. Subject to State aid rules, in order to reach the
Union target set in Article 3(1), Member States may
apply support schemes. When designing their support
schemes, Member States shall take into account the
specific characteristics of different renewable energy
technologies
2. Support for electricity from renewable sources shall
be designed so as to integrate electricity from
renewable sources in the electricity market and ensure
that renewable energy producers are responding to
market price signals and maximise their market
revenues.
3. Support for electricity from renewable sources
shall also be designed so as to promote competition,
reduce costs and improve technologies. To this aim,
except for small scale installations with an installed
capacity of less than 10 MW and for demonstration
projects, support for renewable electricity shall be
granted in open and transparent technology-specific
or technology-neutral tender procedures. Tenders
shall be designed to ensure high project realisation
rates, non-discriminatory participation of small
actors and long-term revenues.
4. Member States shall assess the effectiveness of their
support for electricity from renewable sources at least
every four years. Decisions on the continuation or
prolongation of support and design of new support
shall be based on the results of the assessments.
4. Renewables in buildings (RED Art. 15)
AEBIOM welcomes the proposal of the European Commission extending minimum requirements for renewable
energy in new buildings or buildings undertaking major renovations. In fact, In 2015, minimum requirements were
already in place in 18 Member States1 and are still key to drive costs down and to improve awareness and
1
Sources: Res-legal project (www.res-legal.eu), Ecofys, Overview of Member States information on NZEB, 2014.
knowledge
of
the
construction
sector,
consumers
as
well
as
installers.
Article 15.8 is important because it provides an opportunity to identify the potential of various renewable energy
resources in a "bottom-up" approach, a principle that has guided the Paris Agreement. For the bioenergy sector it
offers an opportunity to demonstrate resources availability from both agricultural land and forestry in all EU
member countries.

Article 15 should be kept as it triggers technology cost-reductions and awareness and allow to
evaluate the availability of biomass per country.
5. Training and information ( RED Art. 18)
The role of professionals (installers, architects, urban planners, etc) has been proved crucial in promoting RES
heating solutions against fossil installations. It is therefore important they are properly trained, qualified or
certified, to ensure a level-playing field for all fuels installations when it comes to professionals’ choices.
A survey made by IEE FROnT project 2 showed that one of the main barrier for end-consumers in the residential,
non-residential and industrial sectors is the lack of awareness. Information on available solutions and related
support schemes should be promoted.
AEBIOM welcomes the European Commission proposal to extend information and training requirements in the
recast RED. Implementation should be strengthened.

Article 18 should be kept as it tackles market barriers and its implementation should be
reinforced to ensure RES deployment in buildings
6. District heating (RED Art 24)
AEBIOM welcomes the introduction of a specific provision on district heating. The primary purpose of this article
should be to ensure a higher share of RES in district heating systems.
The proposal to open grid access to third party is welcome, in order to ensure competition, but heat markets are
local and very different so that it should be left to Member States to establish further rules, taking into account
local conditions and needs.
The proposal to have a direct relationship between external suppliers and customers would demand adjustments
to meet technical conditions such as temperature and pressure and would weaken the optimisation of the network,
leading to higher costs and a loss of competitiveness for district heat.
Proposed amendments:
Article 24
District Heating and Cooling
European Commission proposal
2
Article 24
District Heating and Cooling
Proposed amendments
Survey on End user decision making factors for H&C system choices, http://www.front-rhc.eu/library/
1. Member States shall ensure that district heating and
cooling suppliers provide information to endconsumers on their energy performance and the share
of renewable energy in their systems. Such
information shall be in accordance with standards
used under Directive 2010/31/EU.
2. Member States shall lay down the necessary
measures to allow customers of those district heating
or cooling systems which are not 'efficient district
heating and cooling' within the meaning of Article
2(41) of Directive 2012/27/EU to disconnect from the
system in order to produce heating or cooling from
renewable energy sources themselves, or to switch to
another supplier of heat or cold which has access to
the system referred to in paragraph 4.
3. Member States may restrict the right to disconnect
or switch supplier to customers who can prove that the
planned alternative supply solution for heating or
cooling results in a significantly better energy
performance. The performance assessment of the
alternative supply solution may be based on the
Energy Performance Certificate as defined in
Directive 2010/31/EU.
4. Member States shall lay down the necessary
measures to ensure non-discriminatory access to
district heating or cooling systems for heat or cold
produced from renewable energy sources and for
waste heat or cold. This non-discriminatory access
shall enable direct supply of heating or cooling from
such sources to customers connected to the district
heating or cooling system by suppliers other than the
operator of the district heating or cooling system.
5. An operator of a district heating or cooling system
may refuse access to suppliers where the system lacks
the necessary capacity due to other supplies of waste
heat or cold, of heat or cold from renewable energy
sources or of heat or cold produced by highefficiency cogeneration. Member States shall ensure
that where such a refusal takes place the operator of
the district heating or cooling system provides
relevant information to the competent authority
according to paragraph 9 on measures that would be
necessary to reinforce the system.
6. New district heating or cooling systems may, upon
request, be exempted from the application of
paragraph 4 for a defined period of time. The
competent authority shall decide on such exemption
requests on a case-by-case basis. An exemption shall
only be granted if the new district heating or cooling
system constitutes 'efficient district heating and
(new 1.) Member states shall endeavour to increase
the share of renewable energy in existing district
heating and cooling systems, e.g. biomass, renewable
waste, geothermal and solar thermal energy.
Whenever possible, the production should be done
with high efficiency combined heat and power.
(new 2.) Member states shall endeavour to establish
new district heating and cooling systems, and expand
existing grids, to ensure high efficiency use of
renewable energy sources.
1. Member States shall ensure that district heating and
cooling suppliers provide information to endconsumers on their energy performance and the share
of renewable energy in their systems. Such
information shall be in accordance with standards
used under Directive 2010/31/EU.
2. Member States shall lay down the necessary
measures to allow customers of those district heating
or cooling systems which are not 'efficient district
heating and cooling' within the meaning of Article
2(41) of Directive 2012/27/EU to disconnect from the
system in order to produce heating or cooling from
renewable energy sources themselves, or to switch to
another supplier of heat or cold which has access to
the system referred to in paragraph 4.
3. Member States may restrict the right to disconnect
or switch supplier to customers who can prove that the
planned alternative supply solution for heating or
cooling results in a significantly better energy
performance. The performance assessment of the
alternative supply solution may be based on the
Energy Performance Certificate as defined in
Directive 2010/31/EU.
4. Member States shall lay down the necessary
measures to ensure that there are no regulatory
barriers for DHC operators to buy heat and cold
produced from renewable energy sources and waste
heat and cold when it is economically and technically
feasible for DHC system operators and customers
connected to the district heating and cooling system.
5. An operator of a district heating or cooling system
may refuse access to suppliers where the system lacks
the necessary capacity due to other supplies of waste
heat or cold, of heat or cold from renewable energy
sources or of heat or cold produced by highefficiency cogeneration. Member States shall ensure
that where such a refusal takes place the operator of
the district heating or cooling system provides
relevant information to the competent authority
cooling' within the meaning of Article 2(41) of
Directive 2012/27/EU and if it exploits the potential
for the use of renewable energy sources and of waste
heat or cold identified in the comprehensive
assessment made in accordance with Article 14 of
Directive 2012/27/EU.
7. The right to disconnect or switch supplier may be
exercised by individual customers, by joint
undertakings formed by customers or by parties acting
on the behalf of customers. For multi-apartment
blocks, such disconnection may only be exercised at
whole building level.
8. Member States shall require electricity distribution
system operators to assess at least biennially, in
cooperation with the operators of district heating or
cooling systems in their respective area, the potential
of district heating or cooling systems to provide
balancing and other system services, including
demand response and storing of excess electricity
produced from renewable sources and if the use of the
identified potential would be more resource- and costefficient than alternative solutions.
9. Member States shall designate one or more
independent authorities to ensure that the rights of
consumers and the rules for operating district heating
and cooling systems in accordance with this Article
are clearly defined and enforced.
according to paragraph 9 on measures that would be
necessary to reinforce the system.
6. New district heating or cooling systems may, upon
request, be exempted from the application of
paragraph 4 for a defined period of time. The
competent authority shall decide on such exemption
requests on a case-by-case basis. An exemption shall
only be granted if the new district heating or cooling
system constitutes 'efficient district heating and
cooling' within the meaning of Article 2(41) of
Directive 2012/27/EU and if it exploits the potential
for the use of renewable energy sources and of waste
heat or cold identified in the comprehensive
assessment made in accordance with Article 14 of
Directive 2012/27/EU.
7. The right to disconnect or switch supplier may be
exercised by individual customers, by joint
undertakings formed by customers or by parties acting
on the behalf of customers. For multi-apartment
blocks, such disconnection may only be exercised at
whole building level.
8. Member States shall require electricity distribution
system operators to assess at least biennially, in
cooperation with the operators of district heating or
cooling systems in their respective area, the potential
of district heating or cooling systems to provide
balancing and other system services, including
demand response and storing of excess electricity
produced from renewable sources and if the use of the
identified potential would be more resource- and costefficient than alternative solutions.
9. Member States shall designate one or more
independent authorities to ensure that the rights of
consumers and the rules for operating district heating
and cooling systems in accordance with this Article
are clearly defined and enforced.
7. Sustainability requirements (Art. 26-28)
AEBIOM position on sustainability is developed in a separate position paper.
8. Waste heat
The inclusion of residual heat from thermal power generation in the definition of “waste heat” in the renewable
energy directive implies that such residual heat from a power plant, including based on fossil fuel generation, is a
renewable heat resource to be used in district heating networks. This poses a significant risk of greenwashing with
the requalification as “waste heat” of heat from coal power plants once they are connected to a district heating.
However, waste heat from non-industrial sources such as hospitals, data centres, etc should be included in the
definition of waste heat and should be promoted.
Moreover, it is worth noting that the excess heat from a range of process industries can not only be used directly
to satisfy the installation’s heat demand or external heat demand (through DHC or other applications i.e. drying of
biomass fuels); in fact, it can also be converted in electric power which is then self-consumed or exported to the
grid. This application allows recovering energy in the form of heat, which would be otherwise dissipated in the
atmosphere, while reducing industrial energy costs. Given its benefits in terms of environmental sustainability and
industrial competitiveness, waste heat recovery to power generation should also be promoted.
Proposed amendments:
Article 2 Definitions
European Commission proposal
Article 2 Definitions
Proposed amendments
(y) ‘waste heat or cold’ means heat or cold which is
generated as by-product in industrial or power
generation installations and which would be
dissipated unused in air or water without access to a
district heating or cooling system;
(y) ‘waste heat or cold’ means heat or cold which is
generated as by-product in industrial or power
generation installations processes or non-industrial
sources such as hospitals, data centres and other
buildings and which would be dissipated unused in air
or water without access to a district heating or cooling
system or without being converted in electric power
Annex: Heat Pumps (Annex VII)
Make only efficient heat pumps from ambient air and geothermal eligible towards RES targets
In order to apply the Energy Efficiency First principle also in the RES Directive and to avoid artificial reductions
of the EU renewable energy target, only those efficient heat pumps from ambient heat and geothermal energy and
with a high coefficient of performance (seasonal performance factor > 3) should be accounted towards the
renewable energy target. This will prevent the most inefficient heat pumps produced from outside of the EU from
flooding into the EU markets with no benefits in terms of job creation and local development.
Proposed amendments:
ANNEX VII Accounting of energy from heat
pumps
European Commission proposal
ANNEX VII Accounting of energy from heat
pumps
Proposed amendments
The amount of aerothermal, geothermal or
hydrothermal energy captured by heat pumps to be
considered energy from renewable sources for the
purposes of this Directive, ERES, shall be calculated
in accordance with the following formula:
ERES = Qusable * (1 – 1/SPF)
where
1. Qusable = the estimated total usable heat delivered
by heat pumps fulfilling the criteria referred to in
Article 5(4), implemented as follows: Only heat
pumps for which SPF > 1,15 * 1/η shall be taken
into account,
2. SPF = the estimated average seasonal performance
factor for those heat pumps
3. η is the ratio between total gross production of
electricity and the primary energy consumption
for electricity production and shall be calculated
as an EU average based on Eurostat data.
By 1 January 2013, the Commission shall establish
guidelines on how Member States are to estimate the
values of Qusable and SPF for the different heat
pump technologies and applications, taking into
consideration differences in climatic conditions,
especially very cold climates.
The amount of aerothermal, geothermal or
hydrothermal energy captured by heat pumps to be
considered energy from renewable sources for the
purposes of this Directive, ERES, shall be calculated
in accordance with the following formula:
ERES = Qusable * (1 – 1/SPF)
where
4. Qusable = the estimated total usable heat delivered
by heat pumps fulfilling the criteria referred to in
Article 5(4), implemented as follows: Only heat
pumps for which SPF > 3,
5. SPF = the estimated average seasonal performance
factor for those heat pumps
6. η is the ratio between total gross production of
electricity and the primary energy consumption
for electricity production and shall be calculated
as an EU average based on Eurostat data.
By 1 January 2013, the Commission shall establish
guidelines on how Member States are to estimate the
values of Qusable and SPF for the different heat pump
technologies and applications, taking into
consideration differences in climatic conditions,
especially very cold climates.