The Stockholm Region welcomes the fact that the European Commission is taking measures to ensure that the EU meets its climate and energy targets, and considers that increasing energy efficiency is an important means of meeting those targets and EED is an important step in that direction.

Stockholm Region would however like to emphasize that the point of departure for all EU rules should be that they respect the principles of subsidiarity and proportionality and defend local self-government, that the proposal should not go any further than is necessary, should give scope for flexibility and should be cost-effective.

The Stockholm Region notes that the Commission through the EED proposed a high level of regulation in an area in which Sweden has long applied general economic instruments in a successful manner, not least in the area of the taxation of energy and carbon dioxide which, through the impact they have on prices, provide an incentive for greater energy efficiency.

Stockholm Region would like to stress that the current structure with legally binding EU targets for greenhouse gas emissions along with renewable energy shares and non-binding targets for energy efficiency should be retained even for the period after 2020.

The EU’s efforts to promote greater energy efficiency should be directed at voluntary initiatives, such as the Smart Cities and Communities initiative and the Covenant of Mayors

Stockholm Region continues to oppose that measures on procurement of products and real estate with high energy performance should be mandatory for Local and Regional authorities. The provision is impossible to comply with because many buildings that have been acquired are managed only prior to demolition. Such buildings do not meet the energy performance requirements, and there is no intention of renovating them because the idea is that they should be demolished for major development.

We also continue to oppose the previous proposal in EED regarding the requirement to renovate a certain proportion of publically owned buildings, which might lead to resources being wrongly targeted and to other more appropriate means of improving energy efficiency being pushed aside. Moreover, measures to improve energy efficiency over a small area of a building with high energy requirements might produce better overall results than renovating 3% of the floor area of a building

The Stockholm Region considers that it would be better for energy saving efforts to be driven by property owners rather than by energy companies, as it otherwise might give rise to considerable increases in costs, which in turn will lead to rent increases.

Stockholm Region continues to oppose that measures on procurement of products and real estate with high energy performance should be mandatory for Local and Regional authorities. The provision is impossible to comply with because many buildings that have been acquired are managed only prior to demolition. Such buildings do not meet the energy performance requirements, and there is no intention of renovating them because the idea is that they should be demolished for major development.