Review: HT26: Week 4 – The fairness factor: Winning public support for Europe’s energy transition
by Anya WahalView the associated event for this review
Assessing participation, cost distribution, and opportunities to strengthen Appliance Efficiency Policies
As the European Union (EU) undergoes an energy transition aimed at achieving carbon neutrality by 2050, the question of who benefits from and who bears the cost of this transition is of chief importance. In a recent seminar on a rainy day in Oxford, Fiona Brocklehurst, an independent sustainable energy consultant at Ballarat Consulting, examined whether Europe’s approach to regulating household appliances, such as washing machines, distributes benefits equitably. In direct response to the challenges associated with Europe’s energy transition, Brocklehurst opened the seminar with a powerful premise: fairness is not just a moral ideal but often also a political necessity. Brocklehurst jokingly drew from her own childhood and being a younger sibling when discussing the idea of fairness as intrinsic. She also drew on an argument from Friends of the Earth positing that if a climate plan is being perceived as unfair, it will ultimately fail.[TF1]
Considering the importance of fairness in energy policy, Brocklehurst then turns to EU appliance policy as a case study, describing how the Ecodesign Directive setting of Minimum Energy Performance Standards (MEPS) in combination with energy labelling ensures dynamic improvement of the market. These policies are important primarily because they are incredibly effective, saving massive amounts of energy while being cost-effective. Importantly, they regulate many consumer products, including dishwashers, washing machines, and more, meaning that they impact almost every household, even if people are unaware of it. Having consumer representation in policy design, therefore, is of the utmost importance.
In structuring her analysis, Brocklehurst deploys a framework which draws from three main types of energy justice: procedural, distributional, and recognitional. Beginning with procedural justice, she identifies various stages of policy development, including the development of test standards. During this phase, consumer interests are represented by ANEC, a European NGO focused on representing the European consumer interest in the creation of technical standards as well as BEUC, a pan-European consumer organisation. Instrumental to their functioning, both ANEC and BEUC receive support from the European Commission to function. Even with this representation, however, [TF2] challenges remain, such as the fact that preparatory studies, which represent the best opportunity to influence regulations, are not publicly announced and near impossible to find. Although a “Have Your Say” channel exists that allows individuals to provide feedback on draft regulations, the process as a whole remains relatively opaque. Ultimately, the lack of transparency in the process can undermine citizen participation.
Turning to distributional justice, Brocklehurst then examines MEPS, especially highlighting that although standards intend to benefit all consumers, in practice, the story is often more nuanced. For example, one study on washing machines in the United States (Porter et al. 2022) found that low-income households ended up paying more per kg for washing and drying due to disconnects between the efficiency and model prices of washing machines. Brocklehurst suspects this same pattern exists in the EU where commercial washing machines and dryers, used primarily by lower-income households, can still lack MEPS or energy labels. Similarly, a different study (Porter et al. 2024) found that low-income households in the United States were also likely to pay more for heating and cooling or experience inadequate heating and cooling. While Brocklehurst acknowledged that this particular pattern likely does not exist in the EU due to regulation differences, she also drew upon the study to underscore just how important these equity differences can be.
Building upon that idea, Brocklehurst describes recognitional justice as one of the most difficult aspects to analyse, finding only two examples in the energy efficiency literature. The lack of research in this area raises the question of which groups might be disadvantaged by current energy policies.
Each of the three types of justice Brocklehurst highlights, and the gaps in research they reveal, led to three key recommendations. First, she called for more research to generate evidence on the effect of EU MEPS and energy labels on the market. Second, she recommended changes to EU procedures, including considering possible distributional effects of product coverage, making processes for developing and revising regulations more transparent, and publicising preparatory studies. Third, she proposed introducing MEPS and energy labels for secondhand goods, especially considering distributional effects because these goods are often bought by low-income consumers.
The resulting question and answer portion of the talk was, of course, lively, given the timeliness of the topic and the many questions Brocklehurst’s presentation raised. One audience member, for example, inquired about the slow pace of regulatory change, after which Brocklehurst acknowledged the tension between urgency and practicality due to the minimum two-year lag between completion and implementation. Another raised the procedural justice implications of Brexit, leading Brocklehurst to emphasize that appliance regulation often remains unclear due to lack of sufficient political attention. Other questions explored the salience of these policies considering rising electricity demand, the complications of regulating non-European products, and the possible efficiency gains for certain product categories. Such questions only emphasised just how valuable Brocklehurst’s seminar was as a reminder that the success of energy policies depends not just on effectiveness but also on fairness. By bringing to light the relationship between energy justice and appliance regulation, Brocklehurst highlights how better procedural transparency and research can improve outcomes for European energy customers.