The Eye of Every Storm: Policy Entrepreneurs to Strengthen the Role of Energy Efficiency in EU Climate Policy
Authors: von Malmborg Fredrik 
Published: September 2024

BackgroundContextualising the narrative on energy efficiency as the first fuel in the clean energy transition, the energy efficiency first principle (EE1) was introduced in EU energy and climate policy with the Energy Union communication in 2015 and made nonbinding with the EU Governance Regulation in 2018. In 2023, the EU legislators made EE1 legally binding to apply in policy, planning and investment decisions exceeding 100 million euros each and 175 million euros in the transport sector across all sectors that affect the energy system. Understanding the process through which new legislation is developed and adopted is important for understanding the policy itself, why it was designed in the way it was. Understanding the contextualisation of EE1 is particularly important since it introduced a paradigm shift in EU energy and climate policy. Better knowledge of the process of transformative policy change is important for policy and governance towards a clean energy transition for climate neutrality.ResultsApplying the multiple streams framework as a theoretical lens for analysing policy processes, this paper determines the policy process and the agency of policy entrepreneurs to make EE1 legally binding, from problem formulation to final adoption. Based on qualitative text analysis of policy documents, position papers and reports from EU negotiations, combined with interviews of key actors, the study shows how non-profit and non-governmental organisations such as the Regulatory Assistance Project (RAP), the European Climate Foundation (ECF) and the Energy Efficiency Financial Institutions Group (EEFIG), as well as the European Commission and the rotating Council Presidency, were critical policy entrepreneurs for coupling the problem, policy and politics streams. RAP together with ECF and EEFIG considered the unequal treatment of energy supply and energy demand in energy policy to hamper efficient use of the energy system and suggested the EE1 principle to overcome this problem. Using a broad set of strategies related to cultural-institutional entrepreneurship, such as attention- and support seeking strategies, linking strategies, relational management strategies, and arena strategies, they persuaded the European Commission to propose legislation on EE1. But the initial framing was too technical. for decision-makers to understand. The coupling of the problem&ndash;policy package to politics was performed once a policy window was opened by external and internal events such as the Paris Agreement on climate change, the entering office of the Ursula von der Leyen European Commission in late 2019, and the energy crisis in Europe following Russia&rsquo;s second war on Ukraine. Climate change and security of supply were problems that decision-makers could understand. ConclusionsIt is concluded that coalition-building is important for policy entrepreneurs to gain broad acceptance for their policy proposals. In addition, timing is of great importance for policy entrepreneurs being able to couple a package of problems and policy solutions to the political stream. Political decision-makers must be receptive to the problem and its policy solution. This happens when a policy window of opportunity is opened. In this case, the policy entrepreneurs proposed a solution to what they perceived of as a problem almost seven years before the politics stream was mature and receptive. This led policy entrepreneurs to use &lsquo;salami tactics&rsquo; to sequentially introduce policy change whit bits and pieces of the proposed policy instrument being implemented over a long period. It also highlights the need for endurance of policy entrepreneurs.But the study also raises ethical issues that policy entrepreneurship may not only be positive to democratic governance for the clean and just energy transition. The agency of policy entrepreneurs is often technocratic and non-transparent, and they take the role of political decision-makers but with no formal decision-making power, reducing possibilities to claim accountability, legitimacy and justice.