What is the status of the transposition of Art 25.6(EDD) and its implementation ?
Portugal is not well prepared for transposing EED article 25.6. New legislation and extensive support mechanisms will be needed.
The supply and demand of heating and cooling in general poorly addressed in spatial planning in Portugal without a regulatory framework in place. While some promising examples of local energy planning are emerging, Portuguese municipalities do not have access to a comprehensive support structure to draft heating and cooling plans. Substantial efforts to establish these structures, increase the know-how in local administrations and improve the access to energy-related geodata will be needed.
There is no incentive or obligation for municipalities to draft heating and cooling plans.
Overview of the legal frameworks per governance level
National | Portugal’s main climate and energy objectives are defined in the Portuguese Climate Framework Law approved by Law No. 98/2021, in its 2019 National Energy and Climate Plan 2021-2030 (NECP 2030), and in the updated NECP draft submitted to public consultation in July of 2024. The contributions of the public consultation are under analysis since September of 2024. The draft includes an indicative renewable energy share target for the heating and cooling sector of 63% by 2030. Promoting the development of municipal and regional climate action plans as indicated on the Portuguese Climate Framework is proposed as a new measure (1.6.7) in the draft plan, with previewed implementation between 2022 and 2024. It states that these plans should be aligned with other planning documents, including the local heating and cooling plans indicated in Art 25.6 (EED), and that appropriate support networks should be established. New measure 3.3.2 of the NECP draft states that support should be guaranteed to the municipalities on the definition of the municipal heating and cooling plans under Art 25.6 (EED), fomenting the integration of renewable energies and endowing municipalities with resources and methodologies suitable to the reality of Portuguese cities. This measure, which aims to promote the efficient use of heating and cooling systems, has an estimated implementation date 2023-2027. It states these plans should further involve all relevant stakeholders in the market chain and explore new models that enhance demand aggregation and synergies with heat/cold consumers. |
Local | Most of Portuguese municipalities are signatories of the Covenant of Mayors and adopted Sustainable Energy and Climate Action plans (SECAPs) and Sustainable Energy Action Plans (SEAPs), but very few included heating and cooling decarbonisation measures. The Portuguese Climate Framework Law established as mandatory the elaboration of Municipal Climate Action Plans until February of 2024 for all Portuguese municipalities. These plans should be aligned with Regional Climate Action Plans, intermunicipal plans, climate common policies and existent territorial management tools. So far, a small percentage of the municipalities have developed and approved these plans. Furthermore, municipalities are not obliged to encompass planning measures related to heat or energy for cooling on the scope of these plans. In fact, the only mention to the sector on the Portuguese Environmental Agency (APA) guidelines for the elaboration of the Municipal Climate Action Plans, is the suggestion that the indicator “renewables in Heating and Cooling” from the NECP’s objective “reinforce the focus on renewable energies and reduce the country’s energy dependence” should be adapted to the local level and used as an indicator. |
A very limited support framework and a lack of staffing and expertise for heating and cooling planning.
Decarbonisation of heating and cooling is not a priority in Portuguese national or local policies. Therefore, the support framework for municipalities that would like to voluntarily address the issue is almost non-existent and remains to be developed.
Provided Support
Technical and organisational | 1/5 | There is a very limited technical support for municipalities regarding heating and cooling sector. Municipalities can benefit from the expertise of EU projects when they are involved or rely on the regional and local energy agencies. New measure 1.6.7 of the NECP draft states that a city network and a corresponding technical Support Platform should be established. This platform should guarantee municipalities wide scope support, including in themes such as energy management and definition of investment plans, and promote national and international mobilization and experience sharing. |
Financial | 2/5 | There is no dedicated financial national programme for municipalities regarding heating and cooling sector. Municipalities can apply to the Portugal 2020 fund that opens calls on a great variety of topics (not focused on heating and cooling) but are very limited. Municipalities rely on EU projects and funds for the design phase but not for the implementation phase. |
Staff & skills | 2/5 | Each municipality must have a person or more responsible for energy and climate focusing on all sustainability topics. This is a condition to access Portuguese structural funds. However, municipalities still clearly lack resources and skills for integrated energy planning. Regional energy and climate agencies have strong expertise but are lacking capacities, which hinders them to scale up support. Measure 1.6.7 of the NECP draft states that the Support Platform for cities to be created should also secure the training of municipal technical staff. |
Access to data | 2/5 | The access to data regarding buildings and energy consumption in Portugal is very limited. There is no centralized data and municipalities have to collect door by door the data. |