Missed deadlines and missed goals: why have local authorities been underestimated in the NECP writing process?

Three days after the deadline, only four out of the twenty-seven member countries have submitted their NECP final versions.


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Publication date

July 3, 2024

In this troubled time following the European elections, let’s not forget that the deadline for the final submission of the National Energy and Climate Plan (NECP) by each Member State (MS) was on 30 June 2024. One year after submitting their last draft of NECPs, MS should now have implemented the recommendations provided by the European Commission in their NECP final version. 

On the due date, only four countries out of the twenty-seven member countries have submitted their NECPs (Denmark, Finland, Sweden and the Netherlands). 

Why can we say that we saw it coming? 

Over the past years, we sent multiple reminders about the importance of local stakeholders’ engagement. So did the Commission in its assessments. 

Member States must comply with the Governance Regulation, actively involving local authorities and other relevant stakeholders in the NECP updating process. In January 2024, the Commission published its assessment, highlighting that only a few Member States had managed to involve stakeholders in the NECP process to a significant extent. Article 11 which focuses on the necessity of setting up continuous multilevel climate and energy dialogues, hasn’t been fully implemented as MS mostly organised consultations rather than proper dialogues. 

Local and regional authorities are important for the implementation of energy and climate policies. However, very few Member States demonstrate concrete evidence of how they involve them in the process of preparing the draft updated NECP and even fewer are building on an established multilevel dialogue for this process”.  European Commission Assessment, 18 December 2023

The Commission stressed the significance of viewing NECP writing beyond a “tick-the-box” exercise, urging a genuine opportunity for stakeholders to align plans with on-the-ground realities. This assessment confirms the multiple alarms that we have been sending over the past years regarding the NECP writing process. Indeed, in 2020, we already expressed our concern regarding cities’ involvement in our first NECP analysis. We reiterated this alarming conclusion in an article in 2022 and on a paper and as a member of the Power Coalition in Spring 2024. 

What conclusions can we share after the 30 June 2024 deadline?  

Most of the conclusions presented in this article come from the discussions happening within the LIFE NECPlatform project. This project supports six Member States – Bulgaria, Croatia, France, Italy, Portugal and Romania – in implementing Article 11 in their NECP writing process and none of them have submitted their NECPs by the deadline.  

> Croatia is still an example of a successful multilevel collaboration. It managed to connect with various stakeholders (ministries, local authorities, energy agencies…) and to involve them in collaborative work to improve their NECP to reach the ambitions set by the Commission. Even if being late in submitting its NECP, we can foresee a true implementation of Article 11 and deep connections with multilevel stakeholders in the NECP writing process.  

> In Portugal, the Commission assessment was positive about the involvement of various stakeholders. The main limit Portugal is facing is time as the various consultation stages are happening more slowly than planned. Just like for Croatia, it seems that the quality of the NECP processes will meet Article 11 requirements. 

> Even if France was late in submitting its revised version of NECP (in November 2023 instead of June 2023) stakeholders have been involved through various consultations and dialogues in the NECP drafting process. However, due to the multiple political troubles that France has been facing since early 2024, we can expect an important delay in its submission and the involvement of stakeholders over the past few months is still to be demonstrated.  

> In Romania, Italy and Bulgaria, the Commission’s last assessment was critical of the involvement of different stakeholders in the revision of the NECP. The three countries have accelerated and held various dialogues over the last six months. However, it is unclear how they will influence the final version of the NECP. Romania has even expressed its willingness to implement multi-level dialogues in the long term. However, it is not certain that this will be sufficient to meet the Commission’s requirements for this new version of the NECP. 

How can these experiences benefit others? 

Over the past few months, these six countries have made consequent efforts to set up dialogue platforms, that should last beyond the NECP writing process. From September 2024, the experience gained by these countries will be made available to other Member States through a replication programme. All interested countries can join the programme and six will benefit from financial support, mainly to participate in workshops and events*. Other valuable resources such as guidelines and policy briefs will be available to all. 


The final updated NECPs will have to be submitted in 2029, while the next NECPRs** should be submitted by countries in March 2025. This reporting, due by Member States every two years and gathering data about the implementation and achievements of the National Energy and Climate Plans, covers the five dimensions of the Energy Union. 

The second half of the year will see the election of a new Commission Presidency and new Commissioners, who should be mindful of the key role of multi-level dialogue in climate and energy policies as they step into their new positions. 


*the application form will open in the fall 2024. However, if you are interested do not hesitate to write an email to giulia@ieecp.org

**NECPR: This reporting, due by Member States every two years and gathering data about the implementation and achievements of the National Energy and Climate Plans, covers the five dimensions of the Energy Union.