Double Counting | Energy Efficiency Directive Article 7 | Energy Efficiency Directive | ENSPOL | Energy Saving Policies and Energy Efficiency Obligation Schemes | article7eed.eu

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Double counting

In order for Member States (MS) to meet the requirements of the Energy Efficiency Directive (EED), energy companies need to achieve yearly energy savings of 1.5% of annual sales to final consumers. This can be done by obligated parties carrying out measures to help final consumers improve energy efficiency. As an alternative, or in addition, MS have the option to take other policy measures to achieve energy savings among final consumers. However, it is important that regardless of the approach chosen to implement Article 7, Article 7(12) specifies that there will be no double counting of the impact of measures and it must be clear which of the achieved savings are to be attributed to each of the measures. The method to ensure this is decided is at a national level and must be reported in accordance with Annex V, part 4 point (f) on calculations methodology. 

Avoiding double counting

Databases: Some MS have set up or intend to set up a database to identify possible double counting. The aim of these databases is to collect the necessary information on implemented measures in order to enable them to monitor, control and verify energy savings. An example of this is in the UK, where they already have a comprehensive database which they use to eliminate double counting. When double counting is detected it is the supplier’s responsibility to resolve the issue.

Many MS have more than one database in place, containing information on policy measures and energy efficiency measures. An option would be to consolidate these databases or interlink them so that all the information on implemented energy efficiency measures is stored in one central database with the information being administered by one independent body to help avoid double counting. The issue of data protection needs to be considered when creating a database.

Electric meters: Some MS have chosen an electric meter number to avoid double counting. Their approach is that end users only have one assignable meter.

However, experience in countries has shown that there is a danger of bypassing, since some end users have more than one meter within one housing unit housing thus making double counting undetectable.

Signature system: Another solution is that suppliers request a signature from consumers, confirming that they give the saving to one party only. However, this system has its faults, and it still occurs that some measures are being filed in by more parties. In this case it is handled on a “first come, first serve” basis. Savings are being counted only once and attributed to only one actor and avoiding double counting, how ever there are issues with making this system fair and accounting for who takes credit for the action.

It is recommended to use more than one variable to check against double counting.

Sources and further reference:

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