National Energy and Climate Plans (NECPs) – A look at the process in Germany, Austria and Luxembourg

Without thorough and inclusive multi-level governance planning, there is little chance the European Union (EU) can reach climate neutrality. Close alignment between national policies and the recommendations of local authorities is a must. A 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 up to 2030. While member states are required to provide a way for local authorities to have their say on these NECPs, most member states ignore this legally mandated obligation. A closer look at the experiences of Climate Alliance members in Austria, Germany and Luxembourg confirms this.

The NECPs require member states to lay out key reforms in areas 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 time the NECPs are up for 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 in ensuring 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 has found that information is often withheld, despite requests to engage, including the draft NECPs themselves. National governments often provide impossibly tight timeframes for comments 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 German Ministry responsible for the NECP and was told that 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 its 2019 NECP was submitted without a consultation process. Climate Alliance Germany has teamed up with a group of German NGOs who are also frustrated by the 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 Germany 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 months ago and properly communicated to the public.” With no response to the letter, an NECP checklist of steps for fair public participation was made available with a press statement on the eve of the NECP deadline.

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

Luxembourg organised an early public consultation platform and both Climate Alliance Luxembourg and Climate Alliance members 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 any guidance on format or structure. A Multilevel Climate and Energy Dialogue has been set up to share information, and while a couple of meetings have been held, the process has been disorganised, with little room 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 from 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 NGO report 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 unacceptable: local authorities and stakeholders must be able to participate meaningfully in the development of NECPs 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 fully aligned with local climate, energy and resilience efforts and needs.

The first draft update of all NECPs was due by 30 June 2023. To date, only eight countries have submitted them to the European Commission. The European Commission is expected to review these drafts and send both general and country-specific recommendations to member states by the end of 2023, but member states that submit their draft updates after October will not be included in the Commission’s assessment. A final revision of the drafts is then due by 30 June 2024.

Climate Alliance calls on member states to organise fair and early public participation processes for the revision of the NECPs and further urges member states to make the drafts fully available so that an honest deliberation can take place on policies that will affect the local level. Climate Alliance will continue to monitor progress and advocate for better public participation processes. The network’s first step following the first draft update deadline: submission of a statement on the Energy Union Governance Regulation calling for better multilevel governance processes in EU and national policy making as well as for the Commission to intervene should member states exclude stakeholders, including local and regional authorities, from mandatory NECP consultations.

**By Noelani Dubeta, Climate Alliance EU Policy Coordinator at n.dubeta(at) June 2023 first published at

What are the national energy and climate plans (NECPs or PNEC in french)?

They are the 10-year plans that set out the new national climate and energy targets, implementation and financing. In other words, they define how each EU country will meet its energy and climate commitments up to 2030 according to the EU’s energy and climate targets for 2030.

According to the European Commission, “the national energy and climate plans (PNECs) were introduced by the Regulation on the governance of the energy union and climate action (EU)2018/1999, agreed as part of the Clean energy for all Europeans package, adopted in 2019”[1].  The PNECS define how the EU countries intend to address: energy efficiency, renewables, reductions of greenhouse gas emissions, interconnections, and research and innovation. According to the European Commission, “This approach requires a coordination across all government departments. It also provides a level of planning that will ease public and private investment.”


NECP in Luxembourg

by Cédric Reichel

The Integrated National Energy and Climate Plan (NECP) is the basis of Luxembourg’s climate and energy policy. It describes the policies and measures that will enable us to achieve our national targets for the reduction of greenhouse gas emissions (-55%). It is therefore a roadmap that will be put into practice through the adoption of regulations, programs and projects in specific sectors between 2020 and 2030.

The final version of the NECP for the period 2021-2030 was adopted by the Council of Government at its meeting on May 20, 2020. As planned, European Union (EU) member states are required to update their national energy and climate plans for the year 2024. A draft update must have been sent to the European Commission before this deadline, at the end of June 2023.

On April 17, 2023, the first draft of the updated Energie- a Klimaplang fir Lëtzebuerg (Integrated National Energy and Climate Plan – NECP[2]) was presented to the public and various stakeholders, including the Platform for Climate Action and Energy Transition and the Klima-Biergerrot. The plan was presented at a joint press conference by Prime Minister Xavier Bettel, Minister for the Environment and Sustainable Development Joëlle Welfring and Minister for the Economy Franz Fayot.

The plan presented includes a total of 197 different measures, mainly in the following six sectors: buildings, transport, industry, agriculture, waste, land use, land-use change and forestry (LULUCF; also: UTCATF, Utilisation des terres, du changement d’affectation des terres et de la foresterie).

A public inquiry was also launched, which ran from April 17 to May 16, 2023.[3] Officially, 23 comments were received from legal entities and 19 from individual citizens. This led to the addition of 4 measures and the strengthening / implementation of 50 measures. Opinions were also taken into account from institutional groups such as the Observatoire de la Politique du climat Luxembourg[4] and the Platform for Climate Action and Transition, which formulated a joint opinion based on more than 14 individual opinions from its members, representing very diverse and divergent interests.

The actual date of submission of the NECP to the European Commission has not been announced, but the deadline of June 30 has been met only by Slovenia, Spain and Croatia.[5] An official opinion on Luxembourg’s draft will not be available until the end of 2023.





[3] (lien désactivé)



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