The European Union is very focused on energy. Its recent Energy Union framework set out a series of strategic targets designed both to integrate the region's energy production and reduce its consumption.

Regarding the latter, improved energy efficiency is seen as a key platform. In light of the G-7's declared intention to ultimately stop depending on fossil fuels for energy, this element has arguably taken on even more of a significance.

With this in mind, the European Commission has been considering the detail of how it achieves this, and has declared its intention to propose a Heating and Cooling Strategy by the end of the year.

Not surprisingly, the HVACR industry in Europe is keen to play a part in shaping this strategy before it comes to fruition — probably mindful of the way in which the early stages of the F-Gas Regulation were drafted by policymakers before the industry experts could get a look in.

First out of the blocks is EPEE, the European Partnership for Energy and Environment, which is a fancy title for what is effectively the industry voice of the cooling manufacturers and refrigerant producers. EPEE's position paper makes clear that it believes that a holistic approach is essential to ensuring that heating and cooling play their rightful part in any energy efficiency argument. It is particularly keen that cooling gets its voice heard alongside that of heating:

It says: "The future EU Heating & Cooling Strategy is of crucial importance, since it focuses on the largest energy consuming sector in Europe, namely the heating and cooling of buildings. As a key actor in this field, EPEE is eager to play its part in making Europe’s 'sustainable and secure energy system' a reality."

EPEE outlines four key points:

  1. A holistic approach ensuring the effective use of energy
  2. Consumer awareness and investments into energy efficient solutions
  3. Enforcing existing EU legislation
  4. An equal focus on heating and cooling

Summarized, the thrust of EPEE's position can be boiled down to "cooling has a greater role to play in the energy mix than it is given credit for."

The first element is to take a holistic approach. Epee says: "The increasing amount of renewable energy sources results in a fluctuating electricity supply. A flexible response of cooling applications can add necessary and valuable flexibility to this emerging energy scenario. To release the potentials of a large 'virtual power plant' capacity in the cooling market, a strong focus is needed to develop attractive market models including taxation to ensure innovation on top of the existing basic cooling technologies."

One of EPEE's contentious issue is the Ecodesign Directive, which, while homing in on energy use in specific product areas, is a prime candidate for a more holistic approach, it believes. It stresses even the most energy efficient products will not result in significant energy savings if the wrong type of equipment is chosen for a building, or if the heating and cooling system has not been planned to operate in the most effective way.

"For example, it is still current practice to over-size equipment in order to prevent technical problems during peak loads. In most cases, such over-sizing is not required and often leads to increased investment costs as well as an inefficient use of energy."

It recommends: "The Heating & Cooling Strategy should emphasise the importance of a holistic approach to planning and installing HVAC-R equipment in buildings, rather than focusing solely on continuously increasing the energy efficiency of products."

The second recommendation is to raise awareness and investment into energy efficient solutions, which it believes is under-promoted.

"More work is needed to unlock the potential…To reduce energy consumption, we need to increase demand for energy efficient heating and cooling. However, there is currently a lack of awareness amongst consumers about the benefits of energy efficiency, in particular at building level. Public procurement and building certificates can play a crucial role in that context by raising awareness both at consumer and government levels."

The third recommendation covers another bugbear for the cooling industry in Europe — enforcement of the laws that we have in place already. It is no surprise that one of EPEE’s key emphases covers the enforcement of current regulations.

"Energy efficiency regulation is complex to implement and enforce. However, existing regulation could do a lot to increase demand for energy efficiency and thereby reduce consumption. In that respect, correct energy modelling, including the use of appropriate statistics, is of crucial importance as the potential of heating and cooling solutions is still underestimated."

It notes that both the Energy Performance of Buildings Directive and the 2012 Energy Efficiency Directive provide an excellent framework to achieve significant energy savings, but, it criticizes the enforcement for being "still weak and patchy."

It concludes, with as much authority as it dares muster: "Member States need to prioritise the complete and timely implementation of these directives, as well as effective control in the markets. There is also an urgent need to improve market surveillance across the EU to ensure that Member States and the private sector comply with their obligations, for example with regard to energy efficiency rules for equipment as set by the Ecodesign Directive."

But perhaps its most significant proposal is that the European Commission should have an equal focus on both heating and cooling — an area that EPEE believes marks a critical oversight from the EC, at least as far as its current strategy goes.

EPEE criticizes the EC for what it calls "a rather restrictive approach" by focusing mainly on the heating sector, and largely on the supply side. For example, there was much discussion about district heating, while cooling needs were not considered at all.

EPEE is forthright in its recommendation for the EC to put cooling where it deserves to be — center stage. "The Heating & Cooling Strategy needs to be as much about heating as about cooling, focussing both on cooling needs and efficient solutions."

The European cooling industry has made its presence felt. It remains to be seen whether the European Commission takes up the challenge and looks to legislate in such a way that the cooling efficiencies are seen as significant as those for heating.