National Energy and Climate Plans – Climate Alliance in action

A look at the process in Germany, Austria and Luxembourg

Without thorough and inclusive multi-level governance planning there is little chance the EU can reach climate neutrality. Close alignment between national policies and the recommendations of local authorities is a must. One key way to foster such alignment is through collaboration on the National Energy and Climate Plans (NECPs) – a strategic reporting tool that defines a country's climate policy through 2030. While Member states are required to provide a way for local authorities to have their say on these NECPs, most Member States are ignoring this legally mandated obligation. A closer look at the experiences of Climate Alliance members in Austria, Germany and Luxembourg confirms this.

Via the NECPs, Member States are required to lay out key reforms on issues such as energy efficiency, renewables and emissions reductions. Collectively, the NECPs demonstrate whether the EU is on track to meet its targets by 2030. This year marks the second NECP review and importantly, Member States are required to provide a way for local authorities to participate in the revision process. The basis for this is found in the Energy Union Governance Regulation, which details the rules that give local authorities a role so that their recommendations are taken into account: each Member State must establish both a consultation process and a multilevel climate and energy dialogue platform “in which local authorities […] are able to actively engage and discuss the different scenarios envisaged for energy and climate policies”. In addition, each EU Member State must ensure that the public “is given early and effective opportunities to participate in the elaboration” of both the draft and final NECPs. Unfortunately, Climate Alliance is finding that information is often withheld despite requests to engage, including the draft NECPs themselves. National governments often provide impossibly tight timeframes for comment and, in more than one instance, opportunities or processes to contribute to this first of two NECP drafting rounds had not been established even weeks before the EU deadline (30 June 2023). 

In Germany, for example, there is currently no consultation process open to the public to have even a look at the draft NECP. Climate Alliance reached out to the responsible German Ministry and was told there would be no process for engagement until the beginning of 2024. This is untenable, especially as the Ministry of Economic Affairs promised future involvement of stakeholders after their 2019 NECP was submitted without a consultation process . Climate Alliance Germany has teamed up with a group of German NGOs also frustrated by situation and has since co-drafted a letter demanding that a public consultation process be provided in compliance with EU law. “The fact that the German government is unwilling to offer an early consultation process for our local authorities to have a say in the climate and energy policies that will impact them only isolates our local authorities and, indeed, keeps all stakeholders in the dark,” comments Julian Thoss, Climate Alliance German National Coordinator, on the matter. “Given the scale and pace of climate action required, an early and fair process should have been put in place and properly communicated to the public months ago.”

In Austria, the Environment Ministry’s ‘Nationale Klimaschutz Kommittee’ is running a consultation of sorts, open to a small group of stakeholders by invitation only. Climate Alliance Austria has taken part to learn about the main challenges of meeting the targets in the draft as well as to ask questions and give statements on what is possible. A timeline of next steps has also been provided. However, pressure from a political party taking the position that reducing emissions may harm economic growth could hamper progress and lead to a watering down of Austria’s NECP.

Luxembourg organised an early public consultation platform and both Climate Alliance Luxembourg as well as Climate Alliance members there are involved. Luxembourg’s draft NECP was presented at a meeting in April, but the short presentation left no room for questions or debate – instead, stakeholders were asked to send in any feedback without guidance on format or structure. A Multilevel Climate and Energy Dialogue has been set up for information sharing and while a couple of meetings have been held, the process has been disorganised with little space for meaningful discussion or follow-up. “At the moment, of course, all [contributions] from the discussion platforms are taken into account and incorporated, but the deadlines are very tight […and our concerns and suggestions] have wide-ranging consequences for the economy, purchasing power, etc., which we cannot assess with this brief insight,” explains Luc Friedrich of the municipality of Mersch, who attended the meetings.  Friedrich is concerned about the consequences of a process that started too late given the complexity of the task but welcomes the increased focus on the exemplary role of the municipalities. Both the State and the municipalities have the financial resources “to be pioneers in the implementation of the NECP”.

A recent report by NGOs confirms “widespread inaction on the part of Member States – with 14 out of 23 EU Member States surveyed failing to even start any form of public consultation on NECPs” . This is not acceptable: local authorities and stakeholders must be able to participate meaningfully in NECP development through early consultation. Removal of the national obstacles that prevent their participation is the only way to ensure that the NECPs reflect local realities and are in full alignment with local climate, energy and resiliency efforts and needs.

The first draft update of all NECPs is due by 30 June 2023. The European Commission is expected to review these drafts and send recommendations to Member States by the end of the year. A final revision of the drafts is then due by 30 June 2024. Climate Alliance calls upon Member States to organise fair and early public participation processes on the revision of the NECPs and further urges Member States to make the drafts fully available so that there can be honest deliberation on policies that will affect the local level.

Are you aware of planned multi-stakeholder dialogues in the framework of the NECPs revision process?  Is your municipality involved and contributing to this process? Would you be interested in joining an EU Policy Working Group open to Climate Alliance members to have exchanges on sweeping EU-wide policy issues as addressed in the NECPs? Get in touch with Noelani Dubeta, Climate Alliance EU Policy Coordinator at n.dubeta(at) with your questions and to signal your interest in an EU Policy Working Group!

written June 2023