Article 2(2) of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources defines ‘ambient energy’ as follows: ‘naturally occurring thermal energy and energy accumulated in the environment with constrained boundaries, which can be stored in the ambient air, excluding in exhaust air, or in surface or sewage water’.

1. Is it correct to surmise that ‘thermal energy and energy accumulated in the environment [...] which can be stored in the ambient air [...] or in surface or sewage water’ (except for energy stored in exhaust air) is considered a renewable energy source according to the directive? Or, are surface or sewage water meant to be excluded from the requirements of and support for renewable energy sources?

2. Is it correct to surmise that if waste heat (ventilated air and waste water) is not considered a source of renewable energy under the directive (i.e it should not be considered a heat source, but only an energy efficiency measure), then the recovery of waste heat should not be considered a form of heat production plant?