COMMISSION STAFF WORKING PAPER National Energy Efficiency Action Plans (NEEAPs): update on implementation   Accompanying document to the   COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS   Energy Efficiency Plan 2011   COM(2011) 109 final
Date: 2011-03-08
Institutions: European Commission
Subjects: consumer, energy consumption, energy policy, energy saving, energy transport, financial aid, innovation

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EUROPEAN COMMISSION 

Brussels, 8.3.2011 
SEC(2011) 276 final 

COMMISSION STAFF WORKING PAPER 

National Energy Efficiency Action Plans (NEEAPs): 
update on implementation 

Accompanying document to the 

COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN 
PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL 
COMMITTEE AND THE COMMITTEE OF THE REGIONS 

Energy Efficiency Plan 2011 

COM(2011) 109 final 

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   EN 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
NATIONAL ENERGY EFFICIENCY ACTION PLANS (NEEAPS): 
UPDATE ON IMPLEMENTATION 

1. 

POLICY OBJECTIVES 

Directive  2006/32/EC  on  Energy  End-Use  Efficiency  and  Energy  Services  introduced  an 
obligation for Member States to submit National Energy Efficiency Action Plans (NEEAPs). 
The  Plans  are  intended  to  describe  national  strategies  and  measures  to  achieve  the  energy 
saving targets established by Member States according to the provisions of the Directive. The 
NEEAPs  aim  at  achieving  significant  energy  savings  in  end-use  sectors.  For  the  purpose  of 
their first NEEAPs, each Member State adopted an overall national indicative savings target 
to be achieved by 2016 and an intermediate target for 2010. 

Council conclusions in March 2007 stated that: “The European Council: stresses the need to 
increase energy efficiency in the EU so as to achieve the objective of saving 20% of the EU's 
energy consumption compared to projections for 2020, as estimated by the Commission in its 
Green Paper on Energy Efficiency, and to make good use of their National Energy Efficiency 
Action Plans for this purpose.”  

The  purpose  of  the  first  NEEAP  was  to  indicate  specific  measures  that  Member  States 
intended  to  implement  in  order  to  ensure  that  their  national  energy  saving  targets  are 
achieved. The NEEAPs also had the role of showing how in practice Member States intend to 
comply  with  the  Directive's  provisions  on  the  exemplary  role  of  the  public  sector,  the 
provision  of  information  and  advice  on  energy  efficiency  to  end  users,  obligations  for  the 
energy  sector  to  contribute  to  energy  saving,  etc.  The  Commission  presented  its 
comprehensive assessment of the first NEEAPs in the form of a Staff Working Paper in July 
2009 (SEC889/2009)1. 

2. 

LEGAL BASIS FOR NEEAPS 

Originally, the legal base for NEEAPs was set in Directive 2006/32/EC. The Directive in its 
Article 14 specifies that: 

•  Member States shall submit to the Commission the following NEEAPs: 

–  a first NEEAP not later than 30 June 2007; 

–  a second NEEAP not later than 30 June 2011; 

–  a third NEEAP not later than 30 June 2014. 

•  NEEAPs shall describe the energy efficiency improvement measures planned to reach the 
targets  set  out  in  the  Directive's  Article  4(1)  and  (2),  as  well  as  to  comply  with  the 
provisions  on  the  exemplary  role  of  the  public  sector  and  provision  of  information  and 
advice to final customers set out in Articles 5(1) and 7(2) respectively. 

1 

Synthesis of the complete assessment of all 27 National Energy Efficiency Action Plans as required by 
Directive 2006/32/EC on energy end-use efficiency and energy services: “Moving Forward Together on 
Saving Energy”, Commission Staff Working Document SEC(2009) 889. 

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•  The second and third NEEAPs shall: 

–  include a thorough analysis and evaluation of the preceding EEAP; 

–  include the final results with regard to the fulfilment of the energy savings targets 

set out in Article 4(1) and (2); 

–  include  plans  for  -  and  information  on  the  anticipated  effects  of  -  additional 
measures which address any existing or expected shortfall vis-à-vis the target; 

–  in  accordance  with  Article  15(4),  use  and  gradually  increase  the  use  of 
harmonised efficiency indicators and benchmarks, both for the evaluation of past 
measures and estimated effects of planned future measures; 

–  be based on available data, supplemented with estimates. 

However, in June 2010 the recast Directive on the Energy Performance of Buildings (EPBD, 
2010/31/EU)  created  a  link  between  NEEAPs  and  the  reporting  required  under  the  EPBD. 
The  recast  Directive  provides  for  Member  States  to  report  on  lists  of  measures  and 
instruments  to  promote  the  objectives  of  the  recast  Directive  (Article  10),  measures 
undertaken  instead  of  establishing  an  inspection  regime  for  heating  or  air-conditioning 
systems (Articles 14 and 15) and possibly also their national plans for increasing the number 
of nearly-zero energy buildings (Article 9). This reporting is to be included in the second and 
following NEEAPs in order to reduce the administrative burden related to the reporting. The 
reporting schedules for  the  above  provisions in the recast EPBD have also been  adjusted to 
the NEEAP frequency. 

3. 

RESULTS (ANALYSIS OF THE FIRST NEEAPS) 

When  the  notification  deadline  expired  (30  June  2007),  the  Commission  had  received 
NEEAPs from only two Member States – Finland and the UK. Another fifteen Member State 
Plans  were  notified  and  included  in  the  first  assessment  -  Austria,  Bulgaria,  the  Czech 
Republic,  Cyprus,  Denmark,  Estonia,  Germany,  Ireland,  Italy,  Lithuania,  Malta,  the 
Netherlands,  Poland,  Romania,  and  Spain.  The  27th  NEEAP  was  notified  on  6  June  2008, 
almost a year after the initial transposition deadline. With delays in translation, the individual 
assessments of all the 27 NEEAPs were concluded only in early December 2008. 

Many  Member  States have recognised that with an  integrated approach these national plans 
can become the key tool not only for the effective implementation of Directive 2006/32/EC, 
but  also  for  the  real  push  to  achieving  energy  savings  which  go  beyond  the  particular 
obligations arising from the current EU legislation on end-use energy efficiency. It has been 
found  that  NEEAPs  have  a  great  potential  to help  with  focussing  and  streamlining  Member 
States' policy, legal and support actions aimed at saving energy in a cost-effective way, thus 
reducing  emissions  of  greenhouse  gases,  increasing  the  competitiveness  of  industry  and 
improving the energy security of the EU. 

However,  it  is  also  clear  that  NEEAPs  can  become  effective  only  when  they  stand  for  real 
action:  they  should  set  a  quantitative,  measurable  target  with  a  time  schedule  and  concrete 
steps on who is doing what and the budgetary and human resources available.  

Following  the  assessment  of  the  NEEAPs,  the  Commission  has  communicated  its 
observations to each Member States. Bilateral meetings have been held with several Member 

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States  which  requested  clarifications.  Several  Member  States  indicated  their  willingness  to 
improve  their  first  NEEAPs  (e.g.  add/improve  measures  for  important  areas/sectors  not 
sufficiently covered in their current plans, provide further details of planned actions, etc). In 
2009 Lithuania and Hungary significantly improved and resubmitted their first NEEAP. 

The  Commission's  analysis  of  the  first  NEEAPs  showed  that  Member  States  intended  to 
launch  a  diversity  of  policy  packages  and  measures  targeting  different  end-use  sectors.  A 
number  of  Member  States  introduced  ambitious  national  indicative  energy  savings  targets 
(e.g.  Cyprus,  Lithuania,  Italy,  UK  and  Ireland).  Some  NEEAPs  demonstrated  coherent 
strategies backed by institutional and financial provisions.  

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2016  target  in  final  energy 
savings  as  indicated  in  first 
NEEAP 

Comment 

MS 

value 

unit 

80400 

TJ 

% 

9% 

AT 

BE 

BE-
BRU 

27515 

GWh 

9% 

From the synthesis Plan2 

2199 

GWh 

2929 GWh was reported in the separate regional EEAP 

BE-Wa 

8358 

GWh 

10478 GWh reported in the separate regional EEAP 

BE-Fla 

16959 

GWh 

Same  target  reported  in  the  separate  regional  EEAP  and 
the synthesis Plan 

BG 

CY 

CZ 

7291 

GWh 

9% 

185000 

toe 

10% 

19842 

GWh 

9% 

DK 

ND 

Annual  9.6  PJ  saving  of  total  final  energy  consumption 
(2008-2013) 

This  is  with  factor  1  for  electricity,  with  taking  into 
account  factor  2.5  the  planned  measures  are  expected  to 
bring 1080 PJ 

EE 

FI 

FR 

DE 

GR 

HU 

IE 

IT 

LV 

LT 

LU 

7.65 

PJ 

9% 

17800 

GWh 

9% 

12 

Mtoe 

9% 

833 

PJ 

9% 

18659 

GWh 

9% 

15955 

GWh 

9% 

13117 

GWh 

9% 

126327  GWh 

9.6% 

3483 

GWh 

9% 

400 

ktoe 

11% 

1582 

GWh 

9% 

MT 

378 

GWh 

9% 

2 

Belgium originally submitted 3 regional Plans for Wallonia, Flanders and Brussels Capital, which had 
targets expressed in different units. This was later revised and a umbrella Plan was adopted, where the 
targets  have  been  standardized  and  recalculated.  Therefore,  the  targets  for  each  region  have  slightly 
changed – see comments. 

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2016  target  in  final  energy 
savings  as  indicated  in  first 
NEEAP 

Comment 

MS 

value 

unit 

NL 

51190 

GWh 

192.4 

PJ 

% 

9% 

9% 

PL 

PT 

RO 

SK 

SI 

ES 

SE 

UK 

1.792 

Mtoe 

9.8% 

This saving is for 2015 (final energy), no target indicated 
for 2016 

2800 

ktoe 

13.5% 

37215 

TJ 

9% 

4261 

GWh 

9% 

ND 

Goal of 11% final energy savings by 2012 (equals 24776 
ktoe primary energy) 

32.3 

TWh 

Min 9% 

This corresponds to 41.1 TWh primary energy 

136.5 

TWh 

9% 

"Expected  savings"  are  272.7  TWh  (18%),  to  which  UK 
does not commit officially 

In  contrast,  a  number  of  first  NEEAPs  show  a  scattering  of  fragmented  energy  efficiency 
measures.  A  few  NEEAPs  have  also  shown  a  considerable  gap  between  the  political 
commitment  to  energy  efficiency  and  the  measures  adopted  or  planned  as  well  as  the 
resources allocated for preparing them. 

All  NEEAPs  address  the  buildings  sector,  especially  residential  buildings.  Many  include 
promising  regulatory,  financial  and  information  tools  and  initiatives  for  refurbishment  of 
existing  buildings.  Some  Member  States  declare  ambitious  strengthening  of  building  codes 
and support passive  or  low-energy housing. Some NEEAPs establish a link between energy 
efficiency support and social policy especially as regards social housing (e.g. the NEEAPs of 
Greece, Slovenia and UK as well as the regional Action Plans of the Walloon and Brussels-
Capital regions). 

A  number  of  NEEAPs  include  measures  in  the  tertiary,  transport  and  industrial  sectors 
although  in  some  Member  States  measures  addressing  these  sectors  are  weak  or  missing. 
Despite  the  importance  of  transport  in  end-use  energy  consumption,  strong  energy  saving 
measures addressing that sector are present only in about half of the NEEAPs.  

Measures to save energy in agriculture are absent from most Action Plans. 

Copies  of  the  first  NEEAPs  from  all  EU-27  Member  States  are  downloadable  at: 
http://ec.europa.eu/energy/efficiency/end-use_en.htm  

The  synthesis  of  the  Commission's  assessment  of  the  first  NEEAPs  and  its  assessments  of 
individual NEEAPs for each Member State are available at: 

http://ec.europa.eu/energy/efficiency/doc/sec_2009_0889.pdf  

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4. 

IMPLEMENTATION OF THE FIRST NEEAPS 

In order to improve the quality of the implementation of NEEAPs, ongoing since mid-2008, 
the  Commission  has  facilitated  bi-annual  exchanges  between  relevant  policy-makers  and 
national agencies from EU-27 + Croatia through a 'Concerted Action'. This activity has been 
particularly  important  for  sharing  information  on  the  practical  implementation  of  various 
types of energy efficiency measures included in the first NEEAP. 

From the information collected from Member States via questionnaires at the end of 2010 it is 
clear that most of the national measures so far implemented under the NEEAPs have focused 
on  improving  the  energy  performance  of  buildings  (public  and  private  services  as  well  as 
residential).  The  number  of  measures  implemented  to  trigger  energy  savings  in  the  industry 
(non-ETS)  and  industrial  buildings  sectors  have  also  been  relatively  high.  Coverage  of  the 
measures to be implemented in the transport sector and in agriculture has been the lowest. 

Some  interesting  measures  were  mentioned  under  the  target  group  ‘Other’.  Those  included 
school children’s training and education (FI), financial instruments and smart metering in the 
field of energy research (DE), non-tradable energy efficiency obligations for the energy sector 
(IE) and voluntary agreements with housing co-operatives (NL). 

Although  big  variations  in  coverage  between  sectors  can  be  observed,  absolute  differences 
might not be so large – measure types, and the relation between EU-wide and national policy 
instruments, might be interpreted differently in different Member States. For example, quite a 
number  of  Member  States  did  not  report  that  they  have  any  taxes  applied  in  the  transport 
sector  or  any  regulation  or  standards  applying  to  cars.  Probably  these  MS  did  not  take  into 
account fuel excises that should be applied according to Directive 2003/96/EC on taxation of 
energy products and electricity or Regulation EC/443/2009 on setting emission performance 
standards for new passenger cars. 

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Based  on  practical  experience  in  the  implementation  of  policy  measures,  national  policy 
officials from all EU-27 and Croatia indicated different levels of importance and effectiveness 
of measures. 

The feedback from the Member States pointed out that in practice, the importance of different 
measure types will vary from sector to sector and the results should be taken only as a broad-
brush  assessment.  The  answers  should  be  seen  as  an  estimation  of  the  cost-effectiveness  of 
different  measures,  how  well  they  complement  other  measures  etc.  Some  measures  may  be 
less  important  in  achieving  the  target  on  the  basis  that  they  do  not  have  a  distinct  savings 
estimate at this stage (e.g. information campaigns, training and education, ESCOs), however 
they are nevertheless considered important underpinning measures e.g. in facilitating uptake 
of available programmes promoting EE etc.  

In  general,  from  informal  exchanges  with  the  Member  States  it  is  clear  that  the 
implementation  of  the  NEEAPs  can  not  only  generate  major  additional  energy  savings  but 
also  contribute  to  the  improvement  of  energy  security,  climate  protection  and  the 
improvement  of  the  economic  situation  especially  for  small  businesses  and  the  creation  of 
new  jobs.  Several  Member  States  (e.g.  Lithuania)  indicate  that  they  have  included  some 
elements  of  their  NEEAPs  in  their  national  economic  recovery  plans  (mostly  related  to 
improving energy efficiency of buildings). 

The Commission's exchanges with Member States have also shown that the first NEEAP can 
only  be  taken  as  a  starting  point  for  monitoring  national  energy  policy  measures  and  that 
Member States intend to improve this monitoring in the second NEEAPs.  

5. 

SECOND NEEAPS  

With the second NEEAPs, due by 30 June 2011, Member States are obliged to report on the 
strategy, if necessary a revised strategy based on planned and implemented energy efficiency 

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measures to achieve the indicative national energy saving targets, combined with calculated 
and/or estimated achieved energy savings in 2010 and to revisit the projection of savings in 
2016. 

The Energy Services Directive obliges Member States to report and evaluate a set of measures 
that  contribute  to  the  2016  self-set  targets  for  final  energy  savings.  In  addition,  the  second 
NEEAP  could  already  be  now  used  for  reporting  on  all  energy  savings,  including  energy 
savings achieved through measures addressing supply and transmission/distribution of energy 
and measures addressing ETS industries.  

The  Commission  has  launched  several  support  structures  for  the  preparation  of  the  second 
NEEAPs,  including  training  workshops,  on-line  and  telephone  helpdesk  and  a  NEEAP 
template.  The  common  NEEAP  template  (distributed  to  the  Member  States  in  November 
2010)  has  integrated  modules  to  encourage  additional  reporting  of  –  for  instance  –  savings 
from supply side measures or improvement of distribution. Formal reporting obligations from 
the recast of Directive on the Energy Performance of Buildings (2010/31/EU) have also been 
incorporated. 

The  Commission  organised  two  training  workshops  for  officials  from  all  EU-27  as  well  as 
other interested countries (Croatia and Norway) on the preparation of the second NEEAPs in 
October and November 2010. 

In  the  second  part  of  2010,  following  discussion  with  Member  States  representatives  in  the 
Concerted  Action  on  Energy  Services  Directive,  it  was  concluded  that  the  second  NEEAP 
should ideally become a fully comprehensive policy document and as such the key reference 
publication for national energy efficiency policy. 

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