Additionality – Guidelines

The basics of Additionality are described in Article 7 Guidelines. Future posts will include more information on how countries are dealing with the challenge of generating and proving additional savings to those coming from other legislation.

From the Guidelines:

The additionality requirement needs to be taken into account when determining energy savings for all kinds of policy measure.

The basic principles are: The savings shall be shown to be additional to those that would have occurred in any event without the activity of the obligated, participating or entrusted parties, or implementing public authorities. To determine the savings that can be claimed as additional, Member States shall have regard to how energy use and demand would evolve in the absence of the policy measure  in question by taking into account at least the following factors: energy consumption trends, changes in consumer behaviour, technological progress and changes caused by other measures implemented at Union and national level.

Savings resulting from the implementation of mandatory Union law shall be considered to be savings that would have occurred in any event and thus cannot be claimed as energy savings for the purpose of Article 7(1). This means that, if EU law requires Member States to achieve a certain amount or degree of savings, they can claim only savings above this level — provided that other requirements are fulfilled, e.g. it can be shown and verified that the savings are due to the action/measure in question.

Annex V(2)(a) EED also requires Member States to look at current market developments and establish a baseline scenario. This is particularly important to avoid counting ‘free riders’ which are common in the context of supplier obligations and financial support schemes. For example, if a national support scheme for building renovation supports 100 individual actions in a given year, some of those actions would have happened anyway (without the scheme) and must be deducted. Likewise, when a policy is in place for many years, it is very likely that it has market transformation effects. For example, private stakeholders will take it into account in their own strategies to develop products, services, etc. This means, for example, that the current trends in the market average can be partly due to the effects of policy from previous years. Therefore, if a survey is conducted to assess ‘free-rider’ effects, it is likely that some of these effects today are also spill-over effects from previous years.


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