Energy Efficiency: Member States must follow up on EC proposal for the benefit of SMEs

GRTU was left overall satisfied by the proposal for a directive on energy efficiency unveiled by the European Commission. GRTU particularly appreciated the Commission's call on Member States to establish a favourable framework for technical assistance and targeted information on energy efficiency for SMEs, although this request should have been inserted in the legally binding part of the text rather than in the introductory remarks.

GRTU also welcomed the wording on energy audits for SMEs, which steers clear of imposing compulsory requirements while at the same time promoting awareness raising activities on possible energy savings. Moreover, the association praises the Commission's aims to facilitate SMEs access to the energy services market, to promote the use of small co-generation units and to foster the activities of small energy distributors and small retail energy sales companies. On the negative side, the text does not foresee the involvement of intermediary business organisations in the set up of SME-oriented measures at national level. Moreover, the impact assessment ac-companying the proposal lacks a dedicated ‘SME test', which should have been performed before proposing such an ambitious set of measures.

The target of 20 % primary energy savings by 2020 will not be met if the enormous potential of SMEs in this field remains untapped. Thankfully, the Commission seems to have realised this. Today's proposal could bring Europe very close to its energy efficiency aims if Member States follow suit on its recommendations. In particular, governments should ensure that a favourable framework is established to provide SMEs with technical assistance and targeted information on energy savings. However, this request should be moved from the introduction to the legal provisions of the directive. This would send a stronger political message to Member States and guarantee a concrete follow-up.

The text shows attention to the reality of SMEs also on other aspects. For instance, energy audits will not be compulsory for small and medium-sized companies, but Member States are invited to develop programmes to increase their up-take in SMEs by focusing on concrete examples of how energy management systems could help their business. This is the right approach. Moreover, the Commission plans to facilitate SMEs access to the energy services market and some-how makes the effort to promote some specific categories of SMEs, such as those managing small co-generation units and distributing or selling energy, to help them stay on the market and increase competition in these oligopolistic sectors.

The drawbacks of the proposal lie first of all in the text itself, which does not mention the important role of national SME organisations in working with Member States to set up the favourable framework for SMEs and the specific SME-friendly measures mentioned in the directive. Secondly, and even more importantly, it is quite surprising that the accompanying impact assessment shows that such an ambitious set of measures can be published without a specific ‘SME Test', seeing the impact that the directive will have on small producers, sellers and final users involved in energy efficiency.