March 22, 2017
Guest blog post by: Anders Nordstrand, Managing Director, SABO ; Reinhold Lennebo, Managing Director, Fastighetsägarna ; Marie Linder, the chair of Hyresgästföreningen Riksförbundet
It is of highest importance that our energy use decrease – to reduce carbon dioxide emissions and to make the Union less dependent on imported energy. The work that is now done within the EU is therefore welcome.
In Sweden SABO (The Swedish Association of Public Housing Companies), Fastighetsägarna (The Swedish Property Federation) and Hyresgästföreningen (the Swedish union of Tenants) want to contribute to this goal. Sweden already today work successfully with energy efficiency improvements in the housing sector and energy poverty is nonexistent. Unfortunately this work is now threatened by the proposal made by the European Commission in the Energy Efficiency Directive on demands on individual metering and billing of heat without regard to cost-efficiency. We are aware of that such a system may have effect in other member states but Swedish conditions differ from many other countries. Our experience from projects in Sweden show a general increased energy use after introduction of individual heat meters and billing.
In Sweden heating is included in the rent for apartments. The tenants do not themselves have the opportunity to adjust the temperature, instead this is controlled centrally for the building. A guarantee is normally given of a temperature of 20-21 °C in the apartments as it is according to what the Public Health Agency of Sweden stipulates is recommended for a good health. And we are happy to say that the fact that heating is included in the rent means that it exists no energy poverty in Sweden.
Since heat is included in the rent the property owner have a strong incentive to renovate the building for energy efficiency so as to reduce the energy costs as they have to pay them. The property owner can and will take appropriate measures to reduce energy use, for instance insulation in the attic and of the facade, change of windows, introduction of heat recovery and trimming of the heating system. Such measures do not only improve the building itself but also increase indoor comfort for the tenants. If the cost of the actual use of heating is to be metered and billed to the tenant separately, the incentive for the property owner to undertake such investments would be lost. In addition, due to the cold climate, houses in Sweden have well-insulated building envelopes but no insulation separating apartments or floor levels leading heat to transport from one apartment to another within the envelope. Heat transfer makes it difficult to provide desired individual temperatures and energy use for each apartment.
A precondition for individual metering and billing of heating to result in energy savings is that the vast majority of tenants would prefer a lower temperature in their apartments than the 20-21 °C. Studies in Finland show that up to 4 °C lower is required to reach cost-effectiveness. If the tenants do not choose to have a lower temperature the installation of meters would be without effect. Statistics from public housing companies in Sweden using individual metering and billing for heating in 7,865 apartments in total shows that most tenants actually prefer a higher temperature than 20-21 °C. Our conclusion is therefore that the introduction of requirements for individual metering and billing of heat, will lead to the opposite effect to the purpose of the Energy Efficiency Directive. It would lead to increased energy consumption and that is very worrying. Therefore, our proposal is that Article 9 must be revised to retain the flexibility in the national implementation and to ensure that the measures implemented are cost-efficient.
We have the highest respect for the Commissions work with the directive and the goal to save energy is very important for the survival of our planet. That is also the reason why we are concerned about the proposed changes of article 9. Please do not let the Energy Efficiency Directive become an obstacle for Sweden to continue to save energy and please do take into account each Member State’s unique conditions.
We encourage the Council and the European Parliament to retain the flexibility in the national implementation and to ensure that the measures implemented are cost-efficient.