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34 | THE PERFECT FIT REGULATORY ASSISTANCE PROJECT Table 2. Criteria for ‘efficient heating and cooling system’ as set out in proposed recast EED Share of low carbon heat Option 1: >50% renewable energy or 50% waste heat Option 2: >75% cogenerated heat Option 3: >50% renewable and waste heat combined Option 1: >50% renewable energy or 50% waste heat Option 2: >80% cogenerated heat or at least a combination of such thermal energy going into the network where the share of renewable energy is at least 5% and the total share of renewable energy, waste heat or high-efficiency cogenerated heat is at least 50% >50% renewable energy and waste heat, where the share of renewable energy is at least 20% >75% renewable energy and waste heat, where the share of renewa- ble energy is at least 40% Only renewable energy and waste heat, where the share of renewable energy is at least 60% Source: European Commission. (2021c). Proposal for a Directive of the European Parliament and of the Council on energy efficiency (recast). Subject to acceptance of the EED district heating proposals, it will become more attractive to deploy large-scale heat pumps as part of district heating systems as they would help to comply with the requirements for a rising share of renewable energy sources. What should the EU do to make the policy proposals better? Maintaining and potentially strengthening the energy-efficiency targets will be important in order for energy-efficient technologies such as heat pumps to be given increasing support by national policy makers. No longer counting savings from fossil fuel combustion technologies is another important element that, if kept, would steer Member States towards clean heating technologies rather than more fossil fuel-based heating systems.40 The current definition of efficient district heating is problematic as it allows maintaining and even expanding heat generation from fossil gas. The use of biomass even if unsustainable is not restricted under the current plans. An improved definition of district heating would ensure that gas and biomass use for district heating is limited. 40 Thomas, S. (2021). Ensuring the EED energy savings obligation is Fit for 55. Regulatory Assistance Project. https://www.raponline.org/knowledge-center/ ensuring-the-eed-energy-savings-obligation-is-fit-for-55/ Until 31 December 2025 From 1 January 2026 From 1 January 2035 From 1 January 2045 From 1 January 2050PDF Image | RAP Perfect Fit Heat Pump
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