The public consultation on the proposal for the partial transposition of Directive (EU) 2023/1791 regarding Energy Efficiency concluded last Friday.
Today, in a statement, Zero expressed that although the measure shows significant improvements, it falls short of the requisite level of ambition. They highlighted the necessity for binding targets and stable funding to properly translate the European directive into national practice.
Zero stated, “The legislation requires significant reinforcement: it’s essential to implement mandatory methodologies, binding targets, effective monitoring mechanisms, and a stable financing model. Energy efficiency remains the most powerful tool to reduce consumption, emissions, and energy bills and should form the foundation of Portugal’s climate and social policy.”
The directive mandates a collective reduction of 49.3% in final energy consumption by 2030, based on projections from 2020. To achieve this, Portugal is expected to have an annual final energy savings rate of 1.49% and to annually renew 3% of the usable area of central administration buildings.
According to Zero, while the draft decree-law generally mentions these objectives, it lacks the necessary tools for their achievement, such as intermediate targets, mandatory analysis methodologies, multi-annual implementation plans, and a financial model.
Zero noted that the implementation of the ‘efficiency first’ principle, central to the directive, remains inadequate.
The directive requires member states to prove in all significant public investments that more efficient alternatives were evaluated and justified.
“In the public sector, the absence of an execution plan prevents Portugal from demonstrating its capability to meet the annual 3% renovation rate and the required savings effort. In the private sector, mandatory audits still fail to ensure the implementation of measures with an economic return of less than five years, which, according to the European Commission, could jeopardize 30% to 50% of the identified real savings potential,” the statement reads.
Zero also noted that the legislation fails to revisit targets for reducing energy poverty, which affects 20% to 25% of Portuguese families during winter and around 17% in summer.
Additionally, local heating and cooling plans exhibit significant shortcomings, according to Zero, who believe that “the legislation does not define minimum criteria, decarbonization timelines, or guidelines to ensure comparability and technical quality among municipalities, leaving room for deep asymmetries and loss of efficiency at the territorial level.”
The ambiguity regarding financing is one of the document’s most critical gaps, Zero remarked, stating that the proposal vaguely refers to existing instruments and European funds without establishing a robust national pillar.
In November, the European Commission warned Portugal and 25 other EU countries about the need to correctly transpose the community rules enhancing energy efficiency into national legislation, two years after their adoption.
The European executive stated that only the Czech Republic has correctly transposed this European directive adopted in 2023.
