COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS United in delivering the Energy Union and Climate Action - Setting the foundations for a successful clean energy transition
Date: 2019-06-18
Institutions: Directorate-General for Energy, European Commission
Subjects: EU Member State, EU energy policy, electrical energy, energy efficiency, energy grid, greenhouse gas, innovation, reduction of gas emissions, renewable energy, self-sufficiency in energy

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 18.6.2019  COM(2019) 285 final  COMMUNICATION FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT, THE COUNCIL, THE EUROPEAN ECONOMIC AND SOCIAL COMMITTEE AND THE COMMITTEE OF THE REGIONS United in delivering the Energy Union and Climate Action - Setting the foundations for a successful clean energy transition {SWD(2019) 212 final} - {SWD(2019) 213 final}  
 
 
1.  INTRODUCTION  –  THE  ROLE  OF  INTEGRATED  NATIONAL  ENERGY 

AND CLIMATE PLANS 

The European Union is determined to deliver on its commitments to reduce  greenhouse 
gas  emissions  and  to  provide  secure,  affordable  and  sustainable  energy  for  its  citizens. 
We  are  the  first  major  economy  to  put  in  place  a  legally  binding  framework  to  deliver 
and go beyond what we promised under the Paris Agreement. Based on the proposals of 
the Commission, we have adopted an ambitious legislative framework for 2030, putting 
in place an Energy Union with a forward-looking climate action. We have set ambitious 
targets  for  2030  for  greenhouse  gas  emissions  reduction,  renewable  energy  and  energy 
efficiency,  which  will  require  sustained  and  combined  efforts  to  be  reached.  This 
represents  an  important  step  in  the  long-term  clean  energy  transition  in  a  2050 
perspective,  as  presented  in  the  long-term  strategy1.  These  targets  are  not  ceilings  but 
rather floors and with the right incentives they can even be surpassed.  

The  EU  Governance  Regulation2  has  created  a  unique  system  of  energy  and  climate 
governance  ensuring  that  the  Union  and  its  Member  States  can  plan  together  and  fulfil 
collectively  these  2030  targets,  as  well  as  ensure  a  transition  to  a  climate  neutral 
economy that is  fair  and cost-effective  for all. The Sibiu Declaration3 reaffirmed at  the 
highest  level  the  Union’s  commitment  to  be  a  responsible  global  leader  on  climate 
change,  while  protecting  our  citizens,  preserving  our  environment  and  upholding  the 
principle of fairness. 

Figure 1: 2030 framework for climate and energy 

For the first time, all Member States have prepared draft integrated National Energy and 
Climate Plans (NECPs)4. They have worked to break silos – across policies and sectors, 
across government departments, with stakeholders and the public, and cross-border – to 
define a pathway to 2030 goals. There are still gaps, but this is only the first step of many 
before  2030  and  we  will  learn  from  it.  Building  on  the  excellent  spirit  of  cooperation 
over  the  past  three  years,  the  Commission  will  continue  to  work  constructively  and 
intensively  with  Member  States  to  finalise  and  then  to  implement  their  national  plans. 
The Recommendations for the final plans that accompany this Communication will guide 

1 COM(2018) 773 final. 
2 Regulation (EU) 2018/1999 of the European Parliament and of the Council of 11 December 2018 on the 
Governance of the Energy Union and Climate Action. 
3 Sibiu Declaration, Informal meeting of heads of state or government, Sibiu, Romania 9 May 2019. 
4  As  required  by  Article  9  of  the  Regulation  (EU)  2018/1999  of  the  European  Parliament  and  of  the 
Council of 11 December 2018 on the Governance of the Energy Union and Climate Action. 

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this  work  in  a  continued  spirit  of  collaboration.  In  the  2020 State  of  the Energy  Union 
report  the  Commission  will  take  stock  of  the  final  plans  and  confirm  whether  they  are 
consistent with the Union’s 2030 targets or whether further efforts might be needed. The 
governance  process  also  provides  an  opportunity  to  update  the  plans  in  2024  to  reflect 
experience and to take advantage of new opportunities for the remainder of the decade.  

The NECPs play a key role in our governance system to ensure that we join forces and 
deliver on our objectives together. They should provide as much clarity and predictability 
as possible for the business and finance sector to stimulate necessary private investments. 
They will also facilitate Member States’ programming of funding and investments in the 
next multi-annual financial framework 2021-2027.  

This  Communication analyses the draft NECPs  and looks at their  aggregated effects  in 
reaching the EU Energy Union objectives and 2030 targets. It complements the detailed 
analyses at national5 and European level6, and the specific Recommendations addressed 
to each Member State.7 Together these will help Member States finalise their NECPs by 
the end of 2019. Implementing the Recommendations will involve an on-going iterative 
dialogue  leading  to  finalisation  of  the  NECPs.  Ultimately  the  process  aims  at 
contributing to the modernisation of the Union economy in line with the long term goal 
of climate neutrality.  

The  Commission  will  work  with  Member  States  to  help  them  take  due  account8  of  the 
Recommendations in a spirit of solidarity between Member States and the Union but also 
among Member States.  

2.  ASSESSMENT OF THE DRAFT INTEGRATED NATIONAL ENERGY AND 

CLIMATE PLANS 

2.1. EU-wide assessment for the 2030 renewable energy, energy efficiency and 

greenhouse gas targets and electricity interconnections  

The  Union’s  2030  renewables  and  energy  efficiency  targets  have  been  expressed  and 
agreed at EU level without underpinning binding targets at national levels. Instead, new 
working  methods  and  new  instruments  have  been  established  to  enable  the  collective 
achievement  of  the  objectives  of  the  Energy  Union.  As  a  first  step  in  this  process,  the 
Governance Regulation requires Member States to include in their draft NECPs national 

5  SWD(2019)  211;  SWD(2019)  225;  SWD(2019)  214;  SWD(2019)  275;  SWD(2019)  229;  SWD(2019) 
277; SWD(2019) 230; SWD(2019) 261; SWD(2019) 262; SWD(2019) 263; SWD(2019) 224; SWD(2019) 
264; SWD(2019) 223; SWD(2019) 265; SWD(2019) 228; SWD(2019) 266; SWD(2019) 267; SWD(2019) 
268; SWD(2019) 227; SWD(2019) 226; SWD(2019) 281; SWD(2019) 272; SWD(2019) 273; SWD(2019) 
271; SWD(2019) 274; SWD(2019) 276; SWD(2019) 278; SWD(2019) 279. 
6 SWD(2019) 212. 
7 C(2019) 4401; C(2019)  4402;  C(2019)  4403;  C(2019)  4404;  C(2019)  4405;  C(2019)  4406;  C(2019) 
4407; C(2019) 4408; C(2019) 4409; C(2019) 4410; C(2019) 4411; C(2019) 4412; C(2019) 4413; C(2019) 
4414; C(2019) 4415; C(2019) 4416; C(2019) 4417; C(2019) 4418; C(2019) 4419; C(2019) 4420; C(2019) 
4421; C(2019) 4422; C(2019) 4423; C(2019) 4424; C(2019) 4425; C(2019) 4426; C(2019) 4427; C(2019) 
4428. 
8 In accordance to Article 34 of the Governance Regulation, in case of an ambition gap, the Commission 
shall as appropriate issue recommendations to Member States to ensure the achievement of the objectives 
of the Energy Union. The Member State concerned shall take due account of the recommendations. 

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contributions  that  are  sufficient  for  the  collective  achievement  of  the  Union’s  2030 
targets. As a second step, the Commission is to assess and promote a sufficient level of 
collective “ambition” in view of those Union targets. 

2.1.1.  Renewable energy 

The  Union  should  retain  and  reinforce  its  world  leadership  in  renewables.  This  is  not 
only a matter of security of supply  and  responsible climate change policy.  It  is  also  an 
industrial policy imperative to fully exploit the green growth potential.  

Almost  all  Member  States  have  submitted  their  contributions  to  the  Union  renewable 
energy  target.  About  a  third  of  Member  States  submitted  ambitious  contributions,  with 
Denmark,  Estonia,  Spain,  Lithuania  and  Portugal  putting  forward  significantly  high 
contributions9.  

However, there is still a gap for the EU28. Under current draft plans, instead of at least 
32%, the share of renewable energy would reach between 30.4% and 31.9% in 2030 at 
Union level10.  

Consequently,  the  Recommendations  call  on  several  Member  States  to  reconsider 
their  level  of  ambition  to  ensure  that  this  identified  EU  “ambition”  gap  is  closed 
with  the  submission  of  the  final  NECPs.  Increasing  national  contributions  as 
appropriate - while ambitious Member States maintain their contributions as included in 
the draft NECPs - is crucial to allow for a balanced and cost-effective achievement of the 
Union-level  target, paving  the  way  for the  creation  of  a  true  European  market  for 
renewable energy. This would allow the Union as a whole to exploit fully its potential for 
the cost-effective deployment of renewable energy, to contribute to reducing air pollution 
and fossil fuel import dependency, and to benefit from a leading position in the energy 
transition process.  

9 In accordance with Article 31 of the Governance Regulation, the Commission's recommendations on the 
Member States’ renewable ambitions are based on the formula set out in Annex II of the Regulation, which 
is  based  on  the  objective  criteria  listed  in  Article  5,  whilst  having  due  regard  to  relevant  circumstances 
affecting renewable energy deployment as indicated by the Member States. The methodology followed by 
the  Commission  to  assess  renewable  energy  contributions  is  further  detailed  in  Section  II  of  the 
SWD(2019) 212. 
10 In addition to the gap identified for the EU28, the overall level to be achieved in 2030 remains highly 
dependent  on  the  contribution  of  the  ambitious  Member  States  and  on  the  gross  final  consumption  of 
energy. 

3 

 
 
 
                                                           
Figure  2:  National  renewables  contributions  (Source:  EU  Commission  calculations 
based on information from the draft NECPs). 

2.1.2.  Energy efficiency 

The Energy Union strategy is based on the “energy efficiency first” principle. However, 
the 2020 energy efficiency targets are at risk as a result of increased energy consumption 
in recent years. Based on the national contributions put forward in the draft NECPs, only 
a few Member States have proposed a sufficient  level  of contributions for 2030. Those 
are notably Italy, Luxembourg and Spain (both primary energy consumption and final 
energy  consumption),  Netherlands  (for  primary  energy  consumption)  and  France  (for 
final  energy  consumption).  Some  Member  States  still  need  to  submit  a  national 
contribution. 

As  a  consequence,  the  aggregate  assessment  shows  a  substantial  gap with  the  Union 
target levels of primary and final energy consumption of at least 32.5 % by 203011. 
For  primary  energy  consumption,  the  gap  ranges  from  118  to  43  Mtoe  (with  the 
considerable  range  depending  on  whether  more  conservative  or  more  ambitious 
assumptions  are  made  for  the  countries  which  have  not  submitted  a  national 
contribution),  which  correspond  to  attaining  26.3  %  to  30.2  %,  while  for  final  energy 
consumption  the  gap  ranges  from  85  to  26  Mtoe,  which  corresponds  to  attaining 
26.5% to 30.7 %. 

11  The  methodology  followed  by  the  Commission  to  assess  energy  efficiency  contributions  is  further 
detailed in Section III of the SWD(2019) 212. 

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Figure 3: Collective gap for energy efficiency contributions in primary and final energy 
consumption. (Source: EU Commission calculations based on information from the draft 
NECPs). 

Against this background, all Member States whose contributions are assessed as not 
sufficient at this stage are recommended to review them and consider increasing the 
level of ambition, so that the identified “ambition gap” is closed with the submission of 
the final NECPs. 

2.1.3.  Greenhouse gas emissions  

The  Union  has  communicated  a  nationally  determined  contribution  under  the  Paris 
Agreement  of  at  least  40%  domestic  greenhouse  gas  emission  reductions  by  2030 
compared to 1990. Thanks to the adoption of all the Energy Union legislation proposed 
by the Commission under the mandate of President Juncker, the Union has been the first 
major  world  economy  to  translate  its  Paris  Agreement  contribution  into  concrete 
legislation. The effective implementation of all climate, energy and clean mobility targets 
laid down in Union law could even lead to greenhouse gas reductions of around -45% in 
2030 compared to 1990. 

Based  on  the  planned  measures  or  stated  ambitions  for  national  greenhouse  gas 
reductions included in the draft NECPs, and on the basis of conservative assumptions for 
the  countries  which  have  submitted  neither  of  the  two,  the  overall  greenhouse  gas 
reduction for the Union is estimated to be already in line with the -40% greenhouse gas 
emission  reduction  target  for  2030  compared  to  1990.  This  represents  significant 
progress compared to previous reductions which Member States projected.  

5 

 
 
 
The Effort Sharing Regulation12 mandates Union-wide reductions in sectors not covered 
by the EU Emission Trading System (ETS) of -30% compared to 2005. Member States’ 
national  targets  range  from  0  to  -40%,  and  they  have  significant  flexibility  on  how  to 
achieve  them,  e.g.  transfers  between  Member  States  or  using  a  certain  amount  of 
additional  emission  removals  in  the  land  use  sector.  Spain,  Luxembourg  and  Sweden 
have set more ambitious national targets in the sectors outside the EU ETS13. 

An  aggregation  of  the  national  measures  currently  planned  in  these  sectors 
provided  in  the  draft  NECPs  shows  that  the  Union  could  already  achieve  a  -28% 
emission reduction in non-ETS sectors (see Figure 4, excluding the land use, land use 
change and forestry sector). This represents significant progress compared to projections 
reported  in  the  EU  2018  Climate  Action  Progress  Report14,  i.e.  -21%  reduction  with 
existing  measures,  -23%  reduction  with  planned  measures.  However,  to  fill  the 
remaining  Union-wide  gap  of  2  percentage  points,  Member  States  will  need  to 
identify additional measures in the final NECPs.  

Figure  4:  Member  States’  2030  Effort  Sharing  targets  and  greenhouse  gas  emissions 
with  existing  and  planned  measures  (Source:  Commission  calculations  based  on 
information from the draft NECPs). 

These  considerations  are  based  on  the  assumption  that  all  Member  States  will  comply 
with the “no debit” rule for the land use, land use change and forestry sector i.e. that 

12 Regulation (EU) 2018/842 of the European Parliament and of the Council of 30 May 2018 on binding 
annual greenhouse gas emission reductions by Member States from 2021 to 2030 contributing to climate 
action to meet commitments under the Paris Agreement and amending Regulation (EU) No 525/2013 OJ L 
156, 19.6.2018, p. 26–42. 
13 The non-ETS sectors include, for example, transport, buildings, agriculture, waste. 
14 COM/2018/716 final. 

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emissions do not exceed removals. If this sector creates net emissions, these would need 
to be compensated by using allocations from the effort sharing sectors.  

2.1.4.  Electricity interconnections 

Interconnections  between  national  markets  represent  the  hardware  for  completing  the 
Union internal electricity market, ensuring security of supply, reaping the full potential of 
renewable energy sources, and facilitating sector coupling and integration. 

Five Member States (Czechia, Germany, Greece, Spain and Portugal) clearly refer to 
the electricity  interconnectivity level  they  are  aiming for in  2030 in  their draft NECPs. 
Several  other  Member  States  (Belgium,  Bulgaria,  France,  Lithuania,  Luxembourg, 
Malta,  Netherlands,  Slovakia,  Finland  and  Sweden)  indicate  a  projected  level  of 
electricity interconnectivity in 2030. The draft NECPs often reflects the process laid-out 
by the trans-European energy network (TEN-E) Regulation in identifying and supporting 
at European level the realisation of infrastructure Projects of Common Interest, which are 
necessary  for  reaching  the  interconnectivity  objectives  of  the  Governance  Regulation. 
The 4th list of Projects of Common Interest – to be adopted in October 2019 based on an 
objective  and  inclusive  process  at  European  level  –  will  aim  at  tackling  the  remaining 
bottlenecks in the internal energy market, for instance between the Iberian peninsula and 
the rest of Europe or in South Eastern Europe.  

their 

should 

indicate 

interconnection 

When  finalising  their  NECPs,  Member  States  that  are  currently  below  15%  of 
electricity 
electricity 
interconnectivity in 2030. Member States already above this threshold should consider 
their  level  of  interconnectivity  foreseen  by  2030  in  the  context  of  maintaining  the 
adequacy  of  their  electricity  system  vis-à-vis  the  expected  significant  development  of 
renewable  energy15.  The  final  NECPs  should  make  the  link  between  the  expected 
infrastructure developments and the necessary steps to ensure that these interconnectors 
are  available  to  the  market  for  cross-border  electricity  trade  in  line  with  relevant 
legislation.  

target 

for 

2.2. Main findings for each of the five dimensions of the draft NECPs 

2.2.1 Decarbonisation (greenhouse gases and renewable energy) 

A) Greenhouse gas emissions and removals 

Several draft NECPs would benefit from providing further details on the strategy to 
be  followed  for  reaching  the  non-ETS  targets  over  the  entire  period  2021-2030, 
including  estimates  for  the  emission  reduction  trajectory  based  on  latest  data  and  the 
intended  use  of  flexibilities,  as  already  done  for  example  by  Ireland  and  Latvia. 
Through  the  possibility  to  transfer  emission  allocations  between  Member  States16, 

15 In both cases, the forthcoming 10-Year Network Development Plan (TYNDP) and Projects of Common 
Interest selection processes have to be taken into account. 
16 Article 5 of Regulation (EU) 2018/842 of the European Parliament and of the Council of 30 May 2018 
on binding annual greenhouse gas emission reductions by Member States from 2021 to 2030 contributing 

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several  Member  States  have  the  opportunity  to  mobilise  financing  from  other  Member 
States  to  modernise  their  economy  e.g.  through  investing  in  energy  efficiency  of 
buildings or by fully realising their cost effective potential of renewable energy in non-
ETS  sectors.  This  enhanced  bilateral  cooperation  among  Member  States  will  allow  the 
Union to achieve its ambitious 2030 objectives in a cost efficient manner.  

Transport is responsible for around a quarter of greenhouse gas emissions in the Union 
and  is  the  largest  sector  by  emissions  under  the  Member  States’  non-ETS  targets.  It 
therefore  needs  to  be  at  the  centre  of  the  NECPs.  Most  Member  States  set  out 
emission  reduction  measures  in  the  transport  sector.  Some  Member  States  already 
combine  quantified  emission  reduction  objectives  with  planned  measures.  The  final 
NECPs  will  give  Member  States  the  opportunity  to  develop  an  even  more  integrated 
approach  for  the  transport  sector.  In  their  final  plans,  Member  States  should  be  more 
concrete  and  a  number  of  them  still  need  to  quantify  the  expected  impacts. 
Electromobility  is  often  among  the  objectives  pursued,  but  measures  are  often  not 
described  in  a  very  detailed  manner.  Planning  and  investing  in  the  corresponding 
alternative fuel  infrastructure will be crucial for cars, vans  and lorries manufacturers to 
achieve  the  CO2  emission  performance  standards  for  2025  and  2030  and  to  reduce  the 
fuel  bills  of  drivers  and  transport  operators.  Effective  coordination  on  the  rollout  of 
intelligent  transport  systems  needs  to  be  guaranteed.  The  NECPs  should  also  be  an 
opportunity  for  some  Member  States  to  specify  steps  to  restructure  taxation  so  as  to 
contribute to our policy objectives in the transport sector.  

Good practice examples – policies and measures in the transport sector 

The  Austrian  and  Spanish  draft  NECPs  provide  good  examples  of  how  to  combine 
quantified  emission  reduction  objectives  for  the  transport  sector  with  the  underpinning 
policies  and  measures  to  achieve  them.  For  instance,  Italy  provides  considerable  detail 
on the planned measures and goes beyond the mandatory renewable target for transport. 
While a number of Member States have set indicative electromobility targets,  Slovenia 
underpins  this  with  concrete  measures  including  a  quantification  of  the  charging 
infrastructure required.  

European buildings are responsible for 40% of energy consumption and around 15% of 
greenhouse gas emissions. The draft NECPs cover this sector mainly in the context of its 
role in achieving the energy efficiency and renewable energy contributions. The potential 
of  efficiency  measures  that  would  achieve  cost-efficient  emission  reductions,  while 
reducing  energy  bills  for  households  and  increasing  employment  in  the  construction 
sector could be exploited more rapidly in some Member States.  

Under Union legislation adopted in May 201817, EU Member States have to ensure that 
greenhouse gas emissions from land use, land use change or forestry (LULUCF) are 

to  climate  action  to  meet  commitments  under  the  Paris  Agreement  and  amending  Regulation  (EU)  No 
525/2013, OJ L 156, 19.6.2018, p. 26–42. 
17 Regulation (EU) 2018/841 - Inclusion of greenhouse gas emissions and removals from land use, land use 
change  and  forestry  in  the  2030  climate  and  energy  framework,  and  amending  Regulation  (EU)  No 
525/2013 and Decision No 529/2013/EU. 

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offset by at least an equivalent removal of CO₂ from the atmosphere in the period 2021 
to 2030. With an additional removal potential in accounted terms corresponding to 2% of 
greenhouse  gas  emissions,  LULUCF  will  have  to  make  an  increasing  contribution  to 
achieving  the  Union  climate  targets  in  the  coming  decades,  e.g.  through  enhanced 
sequestration of CO2 from the atmosphere while increasing production and efficient use 
of  biomass  for  a  broad  range  of  uses  with  due  account  given  to  biodiversity  and  air 
quality concerns. Denmark and France are examples of Member States which provide a 
strategy  or  specific  information  on  the  policies  and  measures,  e.g.  to  support  private 
afforestation  on  agricultural  land,  that  can,  in  a  sustainable  way,  enhance  carbon  sinks 
while promoting the bioeconomy and that can provide additional incentives for farmers 
and  foresters  to  improve  land  management  and  sustainable  increase  in  productivity. 
Otherwise, the related information is limited in the draft NECPs. In addition, it will only 
be possible to assess fully whether emissions exceed removals if Member States provide 
more  detailed  information  on  LULUCF  accounting  and  the  use  of  flexibilities.  This 
information is provided to some extent by Czechia, Denmark and Ireland. 

A  key  element  in  this  regard  is  the  establishment  of  transparent  and  accurate  Forest 
Reference Levels to account properly for the emissions or removals of CO2 from forest 
management.  National  Forestry  Accounting  Plans  are  the  tool  for  doing  for  this,  and 
Member  States  should  revise  them  by  31  December  2019  based  on  the  technical 
recommendations presented with this Communication18. This will enable them to be used 
fully  and  consistently  in  the  final  NECPs,  in  particular  with  a  view  to  the  planning  of 
flexibility towards effort sharing sectors. 

The relevance of other sectors such as agriculture, waste and industry, for emissions 
from  sectors not  covered by the EU ETS,  varies across Member States. This  should be 
reflected  in  the  planning  of  policies  and  measures,  as  Ireland  does,  for  example,  for 
agriculture.  For  the  agriculture  sector,  the  Commission  proposal  for  the  Common 
Agricultural  Policy  (CAP)  post-2020  enhances  the  level  of  climate  and  environmental 
ambition, with at least 40% of the overall financial envelope of the CAP expected to be 
climate-relevant.  In  addition,  the  Commission  proposed  ‘eco-schemes’  which  will 
provide  Member  States  with  the  opportunity  to  support  on  a  wide  scale  mitigation  and 
adaptation actions better tailored to specific local needs. The Commission proposal also 
establishes  that  the  Member  States,  in  the  design  of  their  CAP  Strategic  Plans,  should 
take into account  the national  environmental and climate planning tools  in  relevant  EU 
legislative instruments, including the NECPs. In this sense, it will be crucial for the final 
NECPs  to  provide  concrete  indications  of  planned  emission  reduction  measures  in  the 
agriculture  and  forestry  sectors  that  the  CAP  could  support,  e.g.  through  support  for 
testing farm carbon schemes. 

18  In  parallel  with  the  draft  NECPs,  Member  States  submitted  National  Forestry  Accounting  Plans 
(NFAPs),  including  their  national  Forest  Reference  Level.  In  April  2019,  an  expert  group  comprised  of 
technical  specialists  from  Member  States,  NGOs  and  research  organisations,  among  others,  made  a  first 
assessment of the NFAPs. The resulting technical recommendations (SWD(2019) 213) reflect the generally 
high  quality  of  the  submitted  plans  while  pointing  to  some  country-specific  approaches  that  will  require 
further careful analysis.  

9 

 
 
                                                           
For the power sector, which is responsible for around 25% of greenhouse gas emissions, 
Member  States’  decarbonisation  policies  focus  on  the  increased  use  of  renewable 
electricity and on the phase out of coal from electricity generation.  

Towards a phase out of coal in Europe?  

Several Member States introduce or confirm ambitious objectives and timelines to phase 
out coal for electricity generation. France intends to do so by 2022. Italy and Ireland by 
2025.  Denmark,  Spain,  Netherlands,  Portugal  and  Finland,  by  2030.  Germany  has 
also  indicated  that  it  will  set  an  end  date  for  coal  based  electricity.  Member  States 
actively phasing out coal are invited to provide further indications on how they intend to 
pursue these  goals  and  whether they plan to  make use of the option to  cancel  EU ETS 
allowances.  Measures  to  assist  workers  and  families  affected  by  coal  phase  out  should 
also be addressed.  

The  decarbonisation  of  industry,  which  is  responsible  for  around  15%  greenhouse  gas 
emissions, is much less addressed in the draft NECPs compared to the energy sector. In 
these industrial sectors, technology development  and innovation  will have to  accelerate 
during  the  coming  decade  to  reduce  the  carbon  footprint  of  the  industry.  Governments 
will have to play a role in this process, e.g. by applying state aid rules accordingly. The 
earlier Member States make clear their intentions, the earlier industry will be able to tap 
into best available techniques, electrification options and new technological opportunities 
that can help reducing greenhouse gas emissions.  

Many  Member  States  with  climate  adaptation  goals  have  included  them  in  the  draft 
plans, and some have indicated new goals. Several Member States cover adaptation goals 
and measures in some detail. The Irish, Lithuanian, Polish, Slovak and Slovenian draft 
NECPs are examples  of  good practice on how to cover  adaptation  goals  and measures. 
Only  few  Member  States  provide  details  on  adaptation  to  adverse  effects  of  climate 
change related to the security of the Union's energy supply.  

B) Renewable energy 

The Union  reached a 17.5 % renewable  energy share in  2017, but  the pace of increase 
has  slowed  since  2014.  It  is  crucial  to  redouble  efforts  to  reach  the  2030  target.  The 
NECPs  need  to  substantiate  fully  Member  States’  contributions  to  the  2030  collective 
target and underpin them with robust policies and measures. 

Heating  and  cooling  currently  accounts  for  50%  of  the  Union’s  annual  energy 
consumption. The share of renewables in this reached 19.5 % in 2017, and has increased 
by only 6 percentage points in  the last ten  years. The NECPs should reflect  the  annual 
increase of the renewable energy share in the heating and cooling sector provided for in 
Directive  (EU)  2018/2001  and  the  role  of  waste  heat  and  cold  to  make  the  sector 
contribute cost-effectively to the overall renewables share.  

The  same  applies  to  the  transport  sector,  where  Member  States  must  require  fuel 
suppliers to supply a minimum of 14% of the energy consumed in road and rail transport 

10 

 
 
 
by 2030 as renewable energy. This will provide the industry with certainty about future 
market demand. 

Identifying renewable energy potential - good methodology examples:  

Looking  at  the  national  objectives  section,  the  Czech,  Irish  and  Italian  draft  NECPs 
provide good examples of completeness of the objectives and trajectories which need to 
be  included  in  the  final  plans.  Czechia  and  Ireland  include  the  contributions  of  each 
sector and the respective technologies on a yearly basis and in absolute values. Ireland is 
one of the very few Member States that also includes trajectories for bioenergy demand 
and biomass supply by feedstock and provides renewable heat by renewable technology 
contributions  split  for  industry,  residential  and  the  tertiary  sector.  Czechia  provides  a 
sensitivity  analysis  of  how  the  overall  renewable  contribution  could  fluctuate  due  to 
economic growth and energy demand. Italy includes a breakdown of the transport target 
taking into account the applicable multipliers for each technology.  

The  final  plans  should  provide  robust  information  on  policies  and  measures  which 
support  the  timely  achievement  of  the  proposed  objectives  and  contributions  for 
renewable  energy.  Policies  and  measures  need  to  demonstrate  that  the  proposed 
objectives and contributions can be achieved, notably in view of the first reference point 
set  for  2022.  Member  States  should  provide  detailed  information  on  their  support 
schemes  including  detailed  auction  schedules  for  renewable  energy  and  their  evolution 
over  the  2021-2030  period.  Support  schemes  should  support  investor  confidence  and 
decrease the cost of developing renewables over the long term. To provide guidance to 
market  players  and  attract  new  investments  in  renewable  generation,  Member  States 
should spell out in greater detail in the main policies and measures, elements such as (i) 
expected results, (ii) indicative timeline, (iii) source and amount of budget required.  

Information  on  measures 
to  promote  self-consumption  and  renewable  energy 
communities, as well as provisions facilitating the uptake of power purchase agreements 
and  planned  auctions  are  key  to  boost  citizens’  buy-in  of  the  energy  transition,  attract 
private  investment  and  facilitate  cost-effective  achievement  of  targets.  Furthermore, 
simplifying  administrative  procedures,  such  as  facilitating  the  introduction  of  contact 
points  or  having  swift  procedures  in  place  for  repowering,  will  be  crucial  for  the 
deployment of renewables in the next decade. 

By  2021,  a  new  Renewable  Energy  Financing  mechanism19  will  be  put  in  place  to 
support renewable energy deployment across the Union.  

2.2.2. Energy Efficiency 

The  final  plans  need  to  be  more  robust  and  indicate  clearer  energy  consumption 
trajectories.  Better  defining  the  overall  national  policy  framework  underpinning  the 
national  contributions  is  key  for  ensuring  credibility  of  the  proposed  level  of  ambition, 

19 In accordance with Article 33 of the Governance Regulation, the mechanism will have the double aim of 
covering  any  potential  gap  to  the  indicative  Union  trajectory  for  renewables  and  contributing  to  the 
enabling framework under the recast Renewable Energy Directive.  

11 

 
 
                                                           
identification  of  gaps  and  best  practice.  A  more  detailed  explanation  of  the  scale, 
timeframe and expected energy savings of the planned policies and measures is needed.  

This  applies  in  particular  to  the  implementation  of  the  energy  savings  obligation 
and the long-term renovation strategy. All Member States should include in their final 
NECP  the  information  required  by  Annex  III  of  the  Governance  Regulation  (energy 
efficiency  obligation  schemes  and  alternative  policy  measures  under  Article  7  of  the 
Energy  Efficiency  Directive)  as  this  will  help  consolidate  the  policy  framework  and 
integrate  all  its  components.  Including  the  long-term  building  renovation  strategy  will 
provide a comprehensive picture of the planned actions to renovate the national stock of 
buildings  in  view  of  the  cost-effective  transformation  of  existing  buildings  into  nearly 
zero-energy buildings.  

Furthermore,  identifying  investment  needs  and  funding  sources  is  necessary  for 
mobilising  private  investments  in  energy  savings  and  growth  of  the  energy  efficiency 
services  market.  The  final  plans  should  further  elaborate  on  the  role  of  public  bodies’ 
buildings and explore the ways energy efficiency policies could address energy poverty.  

2.2.3 Energy security 

Energy  security  is  an  important  dimension  of  the  Energy  Union  and  hence  the 
NECPs. The Union still imports more than half  of all the primary  energy  it consumes, 
with  important  repercussions  in  terms  of  import  bills  and  vulnerability  to  supply  and 
price disruptions.  

Diversification  of  supply,  import  sources  and  routes  are  key  aspects  of  energy 
security. The NECPs should encourage efficient investments in infrastructure supporting 
national  energy  security  goals,  while  taking  into  account  synergies  across  the  different 
dimensions  of  the  plans.  The  NECPs  should  support  the  completion  of  the  gas 
infrastructure  projects  required  to  give  all  regions  an  access  to  LNG  terminals,  in 
particular in Croatia and Greece, and to give all Member States access to several routes 
of  supply,  in  particular  Finland,  Ireland,  Romania  and  Bulgaria.  The  NECPs  should 
also  promote  the  development  of  domestic  sources,  in  essence,  renewables,  as  well  as 
key components and raw materials necessary for the decarbonisation of energy intensive 
industries.  More  concrete  objectives  and  targets  with  concrete  timelines  would  better 
inform the political discussion around the final NECPs.  

The  continuously  growing  generation  of  variable  renewable  energy  sources  will  pose 
increasing challenges for the energy system. While it should primarily be for the market 
to ensure a continuous balance between supply and demand (including through increased 
sector  coupling),  residual  risks  should  be  addressed  in  a  coordinated  fashion  between 
Member States. The NECPs should reflect this. Properly addressing the energy security 
challenge means adequacy should be assessed, taking into account not only the demand 
and  generation  on  Member  States'  territory,  but  also  on  the  territory  of  connected 
Member States, as well as the long-term climate objectives.  

The  role  of  flexibility  instruments,  such  as  demand  response  and  storage,  is  key  to 
ensuring energy security. Member States with existing or planned capacity mechanisms 

12 

 
 
for  electricity  generation  will  need  to  take  into  account  the  new  rules  under  the  new 
Electricity Regulation and reflect, in the final NECPs how they plan to do this. 

For  those  Member  States  which  have  nuclear  energy  as  part  of  their  energy  mix,  the 
NECPs  could  introduce  policies  to  maintain  adequate  capacities  in  all  the  parts  of  the 
nuclear supply chain and to ensure security of fuel supply.  

To ensure resilience of the energy system, Member States should ensure that adequate 
links are made between the final NECPs and emergency plans for oil, gas and electricity. 
The  high  levels  of  digitalisation  increase  exposure  to  cyber-attacks,  which  could 
jeopardise  security  of  supply  and/or  the  data  privacy  of  consumers.  Cyber  security 
represents a new, emerging element of energy security that both the final plans and the 
plans  required  under  the  Regulation  on  gas  security  of  supply  and  the  Regulation  on 
electricity  risk  preparedness  should  address.  Member  States  are  encouraged  to  identify 
other  types  of  risks,  such  as  those  associated  with  raw  material  supply,  the  impacts  of 
climate  change  or  accidental,  man-made,  natural  or  terrorist  threats  to  critical  energy 
infrastructure in the final version of their NECPs. 

2.2.4 Internal Energy market 

A fully integrated and well-functioning internal  energy market is  needed to ensure 
affordable energy prices, secure energy supplies and to allowing cost-efficient integration 
of  increasing  renewable  sources.  The  NECPs  should  clarify  that  the  right  regulatory 
framework is in place to reap the benefits of more integrated energy markets.  

With the transition in the Union energy systems, common challenges around flexibility, 
decentralisation,  incentive  regulation  for  investment  in  infrastructure,  and  competition 
are emerging. NECPs need to provide more detailed information on the current state of 
national electricity and gas markets and how the challenges will be tackled. Concrete and 
measurable  national  objectives  for  the  future  market  development,  supported  by 
appropriate policies and measures, should be included. 

Internal energy market objectives – good practice: The creation of a joint regional gas 
market  between  the  Baltic  States  and  Finland  is  an  example  of  market  integration 
outlined in the respective draft plans, where the hardware component – the construction 
of the Balticconnector pipeline – is supplemented by harmonised market rules. Countries 
that have implemented EU gas market legislation to the fullest extent also have the most 
liquid markets and benefit most from the internal energy market. NECPs should provide 
a useful stocktaking on progress towards implementing the applicable gas market rules.  

The  objectives,  programmes  and  timelines  for  energy  market  reforms  which  Member 
States  set  out  in  the  NECPs  need  to  be  in  line  with  the  legislation  adopted  under  the 
Clean  Energy  for  all  Europeans’  Package  and  with  existing  network  codes  and 
guidelines.  Given  its  importance  for  European  security  of  supply,  generation  adequacy 
and  market  functioning,  there  is  a  need  to  enable  reliable  access  to  adequate 
interconnection  capacity for trading electricity  and gas across borders. The NECPs and 

13 

 
 
 
the  ‘Implementation  Plans’  required  by  the  Electricity  Regulation20  should  be  fully 
coherent. The NECPs also need to  take into account  the monitoring reports  of national 
regulators and the Agency for the Cooperation of Energy Regulators (ACER). 

The  NECPs  should  support  the  reforms  of  wholesale  markets.  The  NECPs  are  an 
opportunity  for  Member  States  to  include  more  forward  looking  concepts  of  energy 
system integration and sector coupling, including the further integration of the power, gas 
and heat sectors, as they become central for a decarbonised energy system. 

Energy subsidies. It is of utmost importance that public resources are spent in a coherent 
and  cost-effective  manner  while  not  distorting  the  energy  market  and  inhibiting 
investment  in  the  clean  energy  transition  and  innovation.  It  is  essential  to  have  a  good 
account of explicit and implicit energy subsidies and of future plans to phase out those 
that  do  not  contribute  to  long-term  objectives.  While  most  draft  NECPs  have  partially 
addressed  the  issue  of  energy  subsidies,  the  final  plans  should  systematically  describe 
and  quantify  all  types  of  such  subsidies,  from  grants,  support  schemes,  tax  benefits  to 
subsidies  resulting  from  regulatory  obligations,  based  on  existing  definitions  used 
internationally. The draft NECP submitted by Italy is a good example in this respect. It is 
important that all Member States indicate in the final NECPs their future efforts and the 
timelines  to  phase  out  fossil  fuels  subsidies  while  taking  into  account  the  impact  these 
might have on vulnerable consumer groups. 

The  NECPs  should  support  the  introduction  of  forward-looking  policies  aimed  at 
developing  competitive  retail  markets  in  Europe,  allowing  consumers  to  take 
advantage  of  smart  infrastructures.  On  system  flexibility  and  consumer  participation,  a 
considerable number of draft NECPs refer to smart meter deployment with concrete and 
measurable  target.  By  the  end  of  2017,  around  37%  of  EU  households  were  equipped 
with  an  electricity  smart  meter,  while  7  Member  States  have  completed  their  national 
rollouts. The NECPs need to reflect updates to the existing framework as introduced by 
the Clean Energy for all Europeans package to ensure that final customers have access to 
a smart meter. NECPs should report planned measures allowing citizens and businesses 
(in particular SMEs) to have greater control over their electricity consumption and costs, 
such as dynamic price contracts.  

Consumer empowerment, awareness raising and protection also need to be ensured and 
promoted  in  the  NECPs,  which  can  also  introduce  a  more  structured  approach  to 
addressing energy poverty issues (see also section 2.3.5). 

2.2.5 Research, innovation and competitiveness 

Research and innovation are crucial for the Union to achieve the ambitious energy and 
climate objectives and to ensure security, reliability  and resilience of energy supply. At 
the same time, the EU needs to ensure a competitive landscape for its industry. Both 

20 As required by the Electricity Regulation for those Member States which envisage starting or continuing 
capacity mechanisms and which therefore need to upgrade their markets. 

14 

 
 
 
                                                           
processes should go hand in hand. As part of the Energy Union Strategy, the European 
Strategic Energy Technology Plan (SET Plan) and the Communication on Accelerating 
Clean Energy Innovation21 identified the strategic research and innovation priorities and 
actions  needed  at  EU  level  to  accelerate  this  energy  system  transformation  in  a  cost-
effective way. The NECPs are intended to set out specifically which of these objectives 
are  being  pursued  nationally,  thereby  effectively  translating  the  SET  Plan  into  national 
objectives and measures.  

Member  States  need  to  make  additional  efforts  to  integrate  research,  innovation 
and  competitiveness  into  their  NECPs.  The  NECPs  should  set  policies  specifically 
focusing on energy and climate priorities, including research and innovation programmes 
and related funding targets and the use of Union funding and financing instruments. The 
NECPs  should  consider  how  planned  national  public  investments  can  support  market 
uptake  of  available  technologies  and  large-scale  deployment  of  new  breakthrough 
technologies  and  their  integration  into  the  energy  system.  There  is  also  a  need  for  an 
appropriate infrastructure that could support the transition towards climate neutrality for 
energy  intensive,  automotive  and  building  sectors.  The  contribution  of  the  national 
innovation/industrial ecosystems to building European strategic sustainable value chains 
(e.g. batteries, hydrogen, emerging bio-based products, clean, connected and autonomous 
driving, heat pumps, integrated energy management systems) should also be developed. 

Building  on  the  success  of  Horizon  2020,  Horizon  Europe  (2021-2027)  will  streamline 
and  rationalise  the  Union  funding  for  research  and  innovation  to  increase  its  relevance 
and  impact  towards  more  renewables,  energy  efficiency  and  decarbonisation.  The 
Innovation  Fund22  will  support  investments  in  all  Member  States  that  bring  clean 
innovative technologies to the market. 

Research and innovation efforts for the transition to a climate-neutral economy by 
2050 

The Commission’s strategic long-term vision for a climate neutral economy – the “Clean 
Planet  for  all”  Communication23  -  highlighted  the  need  for  a  massive  coordinated 
research  and  innovation  effort.  European  research  should  focus  on  transformational 
carbon-neutral  solutions in  areas  such as  energy  and transport, hydrogen and fuel  cells, 
energy storage, carbon-neutral transformation of energy intensive industries, the circular 
economy,  the  bio-economy,  smart  cities  and  sustainable  intensification  of  agriculture, 
aquaculture and forestry.  

21 COM(2016) 763 final. 
22  The  Innovation  Fund  is  an  European  Union  investment  programme  of  about  EUR  10  billion  financed 
through the sale of allowances from the EU ETS. 
23 A Clean Planet for all - A European strategic long-term vision for a prosperous, modern, competitive and 
climate neutral economy, COM/2018/773 final.  

15 

 
 
 
                                                           
2.3. Robustness, consistency of the draft NECPs and consideration of policy 

interactions 

2.3.1 Is the analytical framework adequate?  

The solidity, credibility and robustness of the final NECPs will determine the extent 
to  which  they  will  be  able  to  support  the  delivery  of  the  Energy  Union  goals.  The 
quality  and  credibility  of  the  analytical  framework  largely  depend  on  the  modelling 
approach,  the  data  sources  used,  the  transparency  of  the  analysis  as  well  as  on  the 
comprehensive assessment of the proposed policies and measures. All those aspects are 
crucial  to  demonstrate  to  what  extent  Member  States  have  carefully  weighed  all  main 
factors in setting their objectives and policies. Detailed projections resulting from a solid 
modelling, and analysis of the impact of planned policies and measures are both crucial 
aspects.  

Comparability  of  the  NECPs  requires  as  much  as  possible  a  common  approach  of 
metrics  used  and  an  alignment  of  base  year  figures  to  reported  data  points.  While  the 
majority  of  the  draft  NECPs  document  key  assumptions  and  data  sources,  the 
completeness  of  the  information  can  still  be  improved.  The  Commission  has  offered 
assistance  and  common  templates  to  ensure  consistency  and  completeness.  Member 
States  should  use  official  Eurostat  statistics  to  the  maximum  extent  possible.  This 
planning  exercise  offers  the  possibility  to  enhance  further  the  co-ordination  among  the 
bodies in charge of energy and climate statistics.  

2.3.2 How have interactions between Energy Union dimensions been 

considered? 

To  enable  the  clean  energy  transition,  Member  States  should  assess  and  adequately 
address  the  interactions  between  different  dimensions.  The  NECPs  should  allow  a 
structured  assessment  of  the  impacts  of  national  policies  and  the  interaction 
between European and national measures on energy and climate. A more systematic 
assessment  of  the  interactions  between  policies  could  be  provided  in  the  impact 
assessments, e.g. between energy efficiency and energy infrastructure policies or policy 
impacts  with  respect  to  the  sustainable  use  of  bioenergy  for  different  purposes.  The 
political implications of the assessed interactions and synergies between different energy 
and  climate  policies  and  objectives  should  however  be  explored  further,  in  particular 
between  security  of  supply,  internal  energy  market  goals  and  renewables  and  energy 
efficiency policies. 

For  instance,  digital  technologies  are  fundamentally  changing  the  energy  market. 
However, if not properly implemented, the positive effects of digitalisation on reducing 
energy consumption and greenhouse gas emission can be offset by a drastic increase of 
electricity consumption, by data centres and telecom networks.  

The  Energy  Efficiency  First  Principle  provides  a  clear  example  of  a  cross-cutting 
policy. It implies that authorities should verify, before introducing new energy policies or 
deciding  on  investments,  whether  the  same  objectives  could  be  achieved  more  cost-
efficiently by means of energy efficiency. Some draft NECPs provide concrete examples, 
notably on how this principle was taken into account to ensure the coherence between the 

16 

 
 
projected  evolutions  of  energy  demand  in  the  design  of  energy  security  measures.  The 
final NECPs should develop the application of the principle further.  

2.3.3 How can the draft NECPs trigger the required investments?  

The  transition  towards  climate  neutrality  means  a  profound  change  for  our  economies. 
Identifying  investment  needs  and  securing  the  necessary  funding  is  essential  to 
deliver  the  yearly  additional  investment  of  around  EUR  260  billion24  necessary  to 
achieve the EU’s climate and energy targets by 2030. NECPs can be an important tool to 
plan national investments in the areas of energy and climate. Public funding will also be 
necessary to upgrade of digital and sustainable skills, to boost the recycling facilities and 
the  renovation  of  public  buildings  and  to  maintain  and  renovate  infrastructure.  The 
coordination of new investments between public authorities, private sectors and citizens 
will mainstream funding, avoid stranded assets and address new needs for businesses and 
citizens. 

Figure 5: Average annual investment need 2021-30 (Source: Commission modelling). 

The  European  Fund  for  Strategic  Investments25,  the  Connecting  Europe  Facility26,  the 
European  Structural  and  Investment  Funds  and  other  existing  initiatives  have  been 
successful  in  supporting  investments  in  renewable  energy  and  energy  efficiency. 
Building  on  these,  the  Commission’s  proposals  for  the  next  multi-annual  financial 

24 Figure derived from the EUCO32-32.5 scenario (in line with key technology assumptions of the EUCO 
family scenarios, see https://ec.europa.eu/energy/en/data-analysis/energy-modelling/euco-scenarios). 
25 Regulation (EU) 2015/1017   of the European Parliament and of the Council of 25 June 2015 on the 
European Fund for Strategic Investments, the European Investment Advisory Hub and the European 
Investment Project Portal and amending Regulations (EU) No 1291/2013 and (EU) No 1316/2013 — the 
European Fund for Strategic Investments. 
OJ L 169, 1.7.2015, p. 1–38. 
26 Regulation (EU) No 1316/2013.  

17 

 
 
 
 
                                                           
framework  running  from  2021-2027  foresee  that  at  least  25%  of  Union  funds  should 
contribute  to  support  climate  mitigation  and  adaptation.  To  mobilise  private  capital  in 
sustainable  investments,  30%  of  the  overall  financial  envelope  of  the  InvestEU 
programme27  is  expected  to  support  the  climate  objectives.  Under  its  Sustainable 
Infrastructure Window, the contribution to Union objectives on climate and environment 
should  be  even  higher  (55%).  As  part  of  the  Connecting  Europe  Facility,  a  dedicated 
proportion of funds has been allocated to support cross-border renewable energy projects. 
All  Member  States  are  also  encouraged  to  use  EU  ETS  auction  revenues  for  funding 
investments  in  emission reductions  and  removals,  renewable  energy,  energy  efficiency, 
research and innovation for clean energy and industry technologies. 

Identifying and quantifying the expected investment needs and the potential sources 
of  finance  are  an  essential  part  of  delivering  the  Energy  Union  objectives.  Eleven 
Member  States  have  estimated  either  the  overall  investment  needs  to  achieve  their 
objectives,  (France,  Italy  and  Spain)  or  parts  of  their  investment  needs  (Greece, 
Finland,  Hungary,  Ireland,  Italy,  Latvia,  Poland  and  Romania),  while  providing 
varying  levels  of  detail  on  the  sources  of  finance.  A  majority  of  Member  States  have 
included in their draft NECPs some concrete investment figures.  

In parallel, the European Commission has addressed this topic as part of the 2018-2019 
European  Semester  cycle,  with  a  strong  focus  on  Member  States’  investment  needs, 
both in the 2019 Country Reports and in the Commission’s proposal for 2019 Semester 
country-specific  recommendations  issued  on  5  June  2019,  where  most  Member  States 
received  recommendations  on  the  importance  of  investing  in  energy  efficiency, 
renewable energy  and/or climate action. This  assessment of the draft NECPs takes into 
account these latest European Semester findings and recommendations.  

Several Member States are already making the link between the NECPs and the Country 
Specific  Recommendations  as  part  of  the  European  Semester  and  all  Member  States 
should  ensure  this  link28.  More  generally,  dialogue  should  continue  to  maximise 
consistency  and  synergies  between  energy  and  climate  policies  and  the  European 
Semester,  as  a  key  tool  to  promote  structural  reforms.  In  this  context,  a  robust  macro-
economic  assessment  of  the  proposed  policies  and  measures  in  the  final  NECP  is 
important  to  understand  the  overall  economic  implications  of  the  planned  policies. 
Progress  made  towards  finalising  the  NECPs  will  inform  the  2020  European  Semester 
country reports.  

The  Commission  has  proposed29  that  cohesion  policy  funds  take  into  account  the 
national  and  regional  needs  that  the  NECPs  identify.  The  priorities  for  investments 

27 COM/2018/439 final. 
28  The  Governance  Regulation  explicitly  mention  that  Member  States  should  ensure  that  their  integrated 
national  energy  and  climate  plans  take  into  consideration  the  latest  country-specific  recommendations 
issued in the context of the European Semester. 
29  Proposal  for  a  Regulation  of  the  European  Parliament  and  of  the  Council  laying  down  common 
provisions  on  the  European  Regional  Development  Fund,  the  European  Social  Fund  Plus,  the  Cohesion 
Fund, and the European Maritime and Fisheries Fund and financial rules for those and for the Asylum and 

18 

 
 
                                                           
 
identified in the Country Reports under the 2019 European Semester cycle and outlined 
in the draft NECPs are complementary. Particularly relevant will be the support that can 
help  build  capacity  for  local,  regional  and  national  authorities,  provide  technical 
assistance and cross-border cooperation. For the period 2021-2027, there will be a strong 
focus on a clean and fair energy transition, R&I and industrial transition based on smart 
specialisation, cross-sectoral coupling of industrial clusters and support for interregional 
cooperation  in  innovation  activities.  In  addition,  in  the  Commission’s  proposals,  the 
adoption  of  a  complete  NECP  is  a  “thematic  enabling  condition”  for  access  to  the 
European  Regional  Development  Fund  and  Cohesion  Fund  for  energy  efficiency  and 
renewable energy investments in particular.  

2.3.4 How can the draft NECPs promote competitiveness of the Union?  

Between  now  and  2030,  each  Member  State  needs  to  create  the  right  framework 
conditions to develop strategic value chains, to be ready for the next investment cycle 
and to support climate neutrality by 2050. The draft NECPs could generally benefit from 
a more detailed overview of the way Member States intend to promote these conditions, 
by  coordinating  policies  and  measures  addressed  to  promote  cost-effectively  the 
industrial  transformation  towards  a  climate  neutral,  circular  and  sustainable  industry 
between  now  and  2030.  These  framework  conditions  should  act  as  drivers  for  change 
benefiting the society and the planet without losing the competitive edge of the European 
industry.  

More  generally,  the  NECPs  should  help  identify  and  develop  Member  States’ 
competitive advantages whilst duly assessing the impact of proposed measures. Clearer 
analysis of the macro-economic impacts of proposed policies and of the competitiveness 
challenges faced by industries, are crucial to successfully navigate the energy and climate 
transition. The approach proposed by several Member States to launch a broad industry 
consultation process in this regard is a good practice. 

Competition  policy  ensures  that  government  spending  in  support  of  the  low  emission 
and  clean  energy  transition  is  efficient  and  does  not  create  distortions  in  the  internal 
energy market. While not substituting existing legal requirements in terms of notification, 
the NECPs could be useful to identify future needs for state aid pre-notification. Member 
States  also  need  to  ensure  that  policies  and  measures  respect  international  obligations, 
notably in the context of WTO Agreements. 

2.3.5 How do the draft NECPs promote a fair transition? 

The envisaged transformation of our economies will require an integrated approach 
to assess carefully social, territorial and employment impacts in the short term and 
in  the  long  run.  This  assessment  is  the  basis  for  a  comprehensive  policy  mix  to 
ensure a just transition. The public funding for upgrading skills, research, innovation, 
infrastructure and social protection has to be aligned with the new needs of society. For 
the success of the EU’s energy and climate plans, the social dimension must be integrated 

Migration  Fund,  the  Internal  Security  Fund  and  the  Border  Management  and  Visa  Instrument, 
COM/2018/375 final - 2018/0196 (COD). 

19 

 
 
 
                                                                                                                                                                            
from the outset. This will help to ensure a socially fair, just transition, including in rural 
areas, and, eventually, social acceptance and public support for reform, in particular for 
large-scale projects and breakthrough technologies. 

Where  needed,  mitigating  or  compensatory  measures,  including  to  reduce  energy 
poverty, need to be part of the reforms and the NECPs should highlight these. 

Energy  poverty  still  affects  nearly  50  million  people  across  the  Union.  The  NECPs 
should address energy poverty in a more structured way, starting with an assessment of 
the  number  of  households  in  energy  poverty  as  well  as  their  main  characteristics 
(composition, income levels, etc.) and their potential geographic concentration30. Where 
the number is significant or where specific groups or regions are exposed to hardship, an 
indicative  objective  to  reduce  energy  poverty  coupled  with  relevant  target  groups, 
policies and measures as well as potential funding sources should be identified. There are 
already some positive elements in a number of draft NECPs. For example, Greece sets 
specific objectives, while the assessments by Italy, Malta, and Finland provide a good 
level of detail. 

The European Social Fund (ESF+) and the Skills Agenda for Europe are also important 
instruments  to  accompany  the  low  carbon  and  energy  transition.  Together  with  the 
European Pillar of Social Rights, they further help ensure that people are granted equal 
opportunities and access to a labour market subject to changes in skill requirements and 
sectoral composition. In particular, the Pillar highlights the right to retraining, reskilling, 
upskilling and social protection – all crucial elements of a just transition. 

In  parallel,  the  Modernisation  Fund  financed  by  the  EU  ETS  is  dedicated  to  the 
modernisation  of  the  energy  systems  of  the  ten  lower-income  Member  States  and  will 
also  help  spur  the  transition  to  a  climate  neutral  economy  while  promoting  upward 
convergence.  

The  Commission  will  further  explore  possible  synergies  with  other  initiatives  aimed  at 
addressing  the  clean  energy  transition  challenges  and  potential  in  specific  European 
territories, such as the EU Covenant of Mayors for Climate and Energy, the Clean energy 
for  EU  Islands  Initiative,  the  Commission  strategy  towards  the  outermost  regions,  the 
European Battery Alliance and the Coal Region in Transition Initiative. 

2.3.6 How do the draft NECPs relate to environmental policies? 

Energy  and  climate  actions  can  bring  benefits  to  air  quality.  Addressing  biodiversity 
loss  and  climate  change  are  policies  that  must  go  hand  in  hand.  The  benefits  of  the 
circular economy for decarbonisation are widely acknowledged. 

Some  Member  States  have  already  integrated  these  elements  in  their  draft  NECPs. 
Member States should ensure the consistency between their NECPs and the National Air 

30 A significant share of households exposed to energy poverty e.g. are middle income households (based 
on EU-Statistics on Income and Living Conditions (EU-SILC) data). 

20 

 
 
 
                                                           
Pollution  Control  Programmes  (NAPCPs)31,  including  their  quantitative  aspects,  as 
required  by  the  respective  legislation.  The  links  between  energy  and  climate  strategies 
and  biodiversity  preservation,  circular  economy,  bioeconomy  and  resource  efficiency 
should  be  made  explicit,  identifying  concrete  measures,  assessing  their  impacts  and 
establishing corrective  actions when  appropriate. For example,  more  re-use of products 
and better recycling of certain secondary raw materials can reduce energy demand.  

The  Commission  can  help  Member  States  to  incorporate  these  aspects  in  their  NECPs, 
through  policy  dialogues  and  sharing  of  best  practice,  using  instruments  such  as  Clean 
Air Dialogues, Virtuous Circle Missions, TAIEX (Technical Assistance and Information 
Exchange) peer2peer, action plans for the circular economy,  LIFE,  guidance on Natura 
2000  and  renewable  energy  and  climate,  or  the  support  provided  by  the  Structural 
Reform Support Service. 

3.  NEXT STEPS – TOWARDS THE FINAL NATIONAL PLANS 

3.1. An ongoing iterative process  

The  analysis  in  this  Communication  and  the  country-specific  Recommendations  on  the 
draft NECPs underpinned by the country-specific Staff Working Documents are the first 
milestones of the iterative process for the finalisation of the NECPs.  

Since  2015,  the  European  Commission  and  Member  States  have  been  working  hand  in 
hand on the preparation and submission of the first draft NECPs. In the coming months, 
the  Commission  will  continue  and  intensify  technical  exchanges  with  Member  States, 
including via Technical Working Group meetings and bilateral meetings. 

The  agreed  2030  energy  and  climate  targets  are  very  ambitious  and  require 
concrete  efforts  across  the  economy.  The  draft  NECPs  offer  a  common,  solid  and 
comparable  platform  to  engage  and  discuss  across  the  Union  with  civil  society, 
business, social partners and local governments the Union’s common challenges and 
long-term priorities in the field of energy and climate. Thanks to their publication at 
the  time  of  submission,  these  discussions  have  already  started  in  a  transparent  manner. 
These interactions should help  to  increase the level  of  ambition of the final  NECPs, as 
well  as  providing  tangible  examples  of  projects  and  policies  to  be  implemented  in  the 
next  ten  years.  Member  States  need  to  ensure  that  the  public  has  early  and  effective 
opportunities  to  participate  in  preparing  the  final  plans,  which  should  then  include  a 
summary of the public’s views. 

In parallel, the Commission will also continue to secure the participation of all levels of 
society  in  a  systemic  way,  while  enhancing  stronger  synergies  between  European, 
national  and  local  efforts  via  the  NECPs.  In  the  second  half  of  2019  and  beyond,  the 
European Commission will continue to promote an inclusive debate on the NECPs. 

31 Directive (EU) 2016/2284 of the European Parliament and of the Council of 14 December 2016 on the 
reduction  of  national  emissions  of  certain  atmospheric  pollutants,  amending  Directive  2003/35/EC  and 
repealing  Directive  2001/81/EC,  OJ  L  344,  17.12.2016.  p.  1–31.  The  National  Air  Pollution  Control 
Programme under Article 6 is the main governance measure by which Member States must ensure that the 
reduction commitments for 2020 and 2030 are met. 

21 

 
 
 
                                                           
    3.2. Priorities for the next six months 

The  next  six  months  –  until  the  end  of  2019  –  will  be  crucial  for  Member  States  to 
develop their solid, robust, complete and reliable final NECPs. To maximise the impact 
of  forthcoming  exchanges,  the  Commission  would  like  to  steer  those  iterations  around 
seven main priorities.  

In  the  recommendations  addressed  to  Member  States,  the  Commission  has  put  the 
emphasis on delivering on the Energy Union dimensions themselves, but also on issues 
of specific importance, in particular investment, a socially just and fair transition, and air 
quality. 

In  finalising  the  NECPs,  Member  States  should  consider  the  following  priorities  in 
addition to the country specific Recommendations. 

3.2.1 Close all 2030 “ambition” and policy gaps  

There is  still  scope to close several  gaps  when finalising the NECPs.  On the energy 
efficiency  and  renewable  contributions,  some  Member  States  are  called  to  better 
exploit their national potential while others will need to confirm their already ambitious 
objectives.  In finalising the NECPs, Member States should  collectively  step up efforts 
to  achieve  the  Union  2030  energy  and  climate  goals,  since  continuation  of  existing 
policies at the same scale would not be sufficient to meet these targets.  

Many Member States are also called upon to further substantiate the achievement of their 
national targets and contributions towards the European level targets with more concrete 
additional policies and measures, underpinned where relevant by funding sources, and 
to  work  further  on  the  analytical  foundation  of  their  NECPs.  Final  NECPs  have  to  be 
complete  and  comprehensive  to  allow  efforts  and  progress  to  be  adequately  monitored 
and revised as needed. The Commission previously published guidance that can be used 
to  set  measurable,  achievable,  realistic  and  time-related  objectives  across  all  five 
dimensions32.  

Should the ambition of final NECPs remain insufficient for the collective achievement of 
the Energy Union objectives and, in particular the 2030 targets for renewable energy and 
energy  efficiency,  the  Commission  will  need  to  consider  additional  measures  at  Union 
level in order to ensure that they are met.  

3.2.2 Involve all relevant ministries at the national level 

The  draft  NECPs  represent  an  unprecedented  opportunity  for  Member  States  to 
explore  better  the  synergies  between  policy  areas  and  to  adopt  a  true  ‘whole  of 
government’ approach.  

32 In 2015, the Commission produced a SWD on monitoring progress towards the Energy Union objectives 
as part of first State of the Energy Union package. This document includes a set of relevant key indicators 
to quantify and measure progress on EU energy and climate objectives and targets. SWD(2015) 243 final. 
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1449767808781&uri=CELEX:52015SC0243. 

22 

 
 
 
                                                           
While several Member States have already developed a new institutional set-up allowing 
better coordination across different policy areas, further work has to be done in view of 
finalising  and  implementing  the  NECPs.  This  is  particularly  the  case  for  synergies  and 
cooperation with ministries of finance and economy. The described synergies of energy 
and  climate  policies  with  areas  such  as  regional,  industrial,  transport,  digital,  social 
agricultural  and  environmental  policy  can  be  better  explored.  This  includes  full 
coherence between the alternative fuel aspects in the final plans and the National Policy 
Framework  that  each  Member  State  has  to  submit  by  November  2019  under  the 
Alternative Fuels Infrastructure Directive33.  

3.2.3 Make the best of cooperation with neighbouring Member States  

Ongoing efforts on regional cooperation should be brought to the next level to facilitate 
market  integration  and  cost-efficient  policies  and  measures.  Member  States  are  also 
encouraged  to  further  pursue  cooperation,  not  only  with  their  neighbouring  Member 
States,  but  also  with  signatories  to  the  Energy  Community  and  with  third-country 
members of the European Economic Area.  

Regional cooperation – good practice:  

To  help  with  preparing  the  draft  NECPs,  the  Nordic  Energy  Research  coordinated  a 
scenario-based energy system analysis that explores the changes in the Baltic countries’ 
energy systems. Within the Benelux cooperation framework a declaration was signed 
on  the  margins  of  the  Energy  Council  on  11  June  2018  to  strengthen  cooperation  in 
preparing the draft NECPs. The members of the Pentalateral Energy Forum signed, in 
the margins of the Energy Council on 4 March 2019, a political declaration confirming 
their intention to maintain and strengthen cooperation in developing and monitoring the 
NECPs  with  a  specific  focus  on  issues  with  high  cross-border  relevance.  Within  the 
North Seas Energy Cooperation, several Member States have committed to developing 
coordinated  elements  for  their  NECPs  to  facilitate  the  cost-effective  use  of  offshore 
renewable  energy,  particularly  wind  energy.  The  Commission  looks  forward  to  similar 
cooperation  in  other  sea  basins  taking  into  account  that  achieving  a  climate  neutral 
economy  by  2050  will  require  substantial  part  of  Europe’s  electricity  to  be  generated 
offshore34. 

More  generally,  without  the  leadership  of  the  European  Union,  it  will  be  difficult  to 
achieve the objective of  accelerating  a worldwide energy and climate transition.  At the 
same time, Union efforts will have little impact on a global scale if third countries do not 
follow  the  same  path.  Against  this  background,  Member  States  are  encouraged  to 
complement  their  NECPs  with  practical,  potentially  transferable  and  scalable  policies 
that  could  be  shared  beyond  Europe  as  part  of  Union  efforts  to  lead  the  global  clean 

33  Directive 2014/94/EU  of  the  European  Parliament  and  of  the  Council  of  22  October  2014  on  the 
deployment of alternative fuels infrastructure, OJ L 307, 28.10.2014, p. 1–20. 
34 The EU directive on maritime spatial planning, ongoing EU efforts to stimulate innovation and improve 
access  to  reliable  ocean  data  as  well  as  targeted  opportunities  within  InvestEU  for  the  necessary  cabling 
and port infrastructure will support this transition. 

23 

 
 
                                                           
energy transition. If deemed appropriate, Member States may also consult third countries 
that have expressed an interest.  

3.2.4 Use NECPs to support industry, competitiveness and innovation  

A  wide  range  of  reforms  will  be  needed  to  fully  exploit  the  growth  potential  of 
climate and energy policies. The NECPs need to help identify and develop Member 
States’  competitive  advantages  by  setting  the  right  reforms  as  well  as  the  correct 
investment  signals  and  incentives,  including  by  further  developing  taxation.  NECPs 
should set out the necessary objectives while supporting national structural reforms and 
the  deployment  of 
industrial  strategies  prioritising  competitiveness, 
sustainability,  investments,  trade  infrastructure  and  innovation.  Clearer  strategies  in 
terms  of  research  and  innovation  priorities  could  also  reinforce  European  long-term 
priorities while sustaining EU exports in cutting-edge sectors. 

integrated 

The  NECPs  can  become  useful  platforms  to  develop  with  the  banking  sector,  new 
programmes  for  financing  long-term  investment  and  to  stimulate  the  mobilisation 
of  private  resources  or  to  support  new  initiatives  between  industry  players  across 
sectors and value chains, and enhance the ones already launched by the Commission in 
2017, such as the one on batteries and plastics (European Battery Alliance and Circular 
Plastic Alliance). 

3.2.5 Attract investment and identify financing opportunities 

Mobilising  new  investments  and  private  finance  will  be  key  part  of  implementing 
the NECPs over the coming years. Clarity on policy objectives and instruments will 
be essential for identifying both the scope and scale of additional investment needs, 
thus  making  it  easier  to  plan  and  mobilise  different  sources  of  funding.  In  the  coming 
months Member States should therefore clarify the instruments and reinforce the analysis 
of  projected  investment  needs,  existing  barriers  and  possible  sources  of  financing,  also 
taking into account the synergies with the European Semester process.  

This  detailed  assessment  is  essential  to  ensure  efficient  and  more  targeted  spending  of 
State resources, to better inform industry on the direction of policies, and to attract new 
investments,  with  positive  repercussions  in  terms  of  jobs  and  growth.  The  European 
Commission’s current work on sustainable finance, aiming to reorient capital flows from 
private  investors  to  environmentally  sustainable  investments,  could  help  identify 
investment opportunities and mobilise private finance. 

Synergies will have to be exploited with existing and future Union policies and Union 
financial  instruments.  In  parallel,  the  Commission  will  continue  to  support  Member 
States  in  finalising  and  implementing  their  NECPs  by  delivering  a  number  of  enabling 
measures as described above.  

3.2.6. Fully integrate the social dimension  

Addressing  social  aspects  will  be  essential  in  securing  a  successful  clean  energy 
transition. In their final NECPs, Member States are encouraged to fully tackle the issue 
of ensuring a socially just and fair transition.  

24 

 
 
This  encompasses  notably  employment  aspects,  including  training,  upskilling  and 
reskilling,  as  well  as  adequate  social  protection  for  people  concerned  by  the  energy  
transition.  Properly addressing the  energy poverty dimension is  also  needed, including 
by assessing the number of households in energy poverty and where necessary defining 
an indicative objective to reduce energy poverty. 

Finally, those Member States concerned should consider the impact of the transition on 
the  populations  living  in  coal  or  carbon-intensive  regions  and  make  the  link  with 
existing, planned or necessary actions in this regard.  

3.2.7 Factor-in long term objectives and a long-term vision 

In parallel to finalising their NECPs, the Governance Regulation requires Member States 
to develop their national long-term greenhouse gas emission reduction strategies with 
a perspective of at least 30 years. More than half the draft NECPs already include 2050 
objectives or visions, albeit with varying degrees of detail. Both the NECPs and the long 
term  strategies  will  need  to  be  developed  in  a  complementary  way,  while  also 
contributing  to  the  ongoing  work  to  finalise  the  European  long-term  strategy  that  the 
European  Union  will  have  to  submit  by  2020  under  the  Paris  Agreement  and  the  UN 
Framework  Convention  on  Climate  Change.  While  focusing  on  the  2030  horizon,  the 
2050 horizon should be included in the NECPs, including a reflection of consistency of 
the targets and objectives with the long term decarbonisation goal and further efforts to 
better qualify long terms objectives across all five dimensions.  

In the second half of 2019, relevant  Council formations  should be able to  finalise their 
ongoing policy debates on the European vision for a climate neutral Europe by 2050 with 
a reflection on this aspect in the final NECPs. 

More than half the draft NECPs include 2050 objectives or visions, albeit with varying 
degree of detail. Denmark, Spain, France, Netherlands, Portugal, and Sweden aim for 
climate neutrality at latest by 2050. France and the United Kingdom have established 
legally  binding  2050  targets  in  their  domestic  legislation  and  use  carbon  budgets  as 
mechanism  to  ensure  consistency  of  medium  and  long  term  objectives.  Netherlands, 
Portugal  and  Sweden  increased  their  national  2030  greenhouse  gas  targets  to  be 
consistent with their long term targets. Other Member States with 2050 decarbonisation 
objectives  include  Czechia,  Germany,  Estonia,  Ireland,  Italy,  Lithuania,  Hungary, 
Austria, and Finland. 

4.  CONCLUSIONS 

Delivering the Energy Union’s commitments requires further close cooperation between 
the  Commission,  Member  States  and  all  segments  of  society,  including  stakeholders, 
social partners and the general public. It is a joint process in which the timely submission 
by Member States of final integrated NECPs for the post-2020 period is a key milestone. 

In  order  to  ensure  that  the  final  NECPs  submitted  by  the  end  of  2019  meet  all 
requirements  and  reach  the  ambitious  EU  2030  targets,  the  Commission  invites  the 
Council  to  open  a  debate  around  the  main  priorities  identified  by  this  Communication 

25 

 
 
 
and  the  Commission’s  Recommendations  to  ensure  that  the  final  NECPs  contain  an 
adequate  level  of  ambition  to  fulfil,  in  particular,  the  European-level  renewable  and 
energy efficiency targets. The Commission will keep a close dialogue with the European 
Parliament and the Council on progress achieved by the Energy Union on all dimensions 
of energy and climate policies.  

In  parallel,  the  European  Commission  will  support  Member  States  in  finalising  their 
NECPs by the end of 2019, building on the excellent cooperative process to date.  

Solid  and  comprehensive  NECPs  will  be  crucial  to  achieve  the  Energy  Union’s 
objectives,  their  implementation  and  the  Union’s  contribution  to  the  Paris  Agreement, 
while generating investor confidence and investment certainty. 

Beyond  our  borders,  the  integrated  national  energy  and  climate  plans  will  be  an 
expression of the European Union's credibility on international climate policy, including 
the clean energy transition, and contribute to the long-term decarbonisation goals in the 
context of the Paris Agreement and the UN Sustainable Development Goals. They could 
become an international best practice on developing sound mid-term energy and climate 
policy planning and be a tool to foster international cooperation around those aims. 

The delivery of these final NECPs will be a start, not an endpoint – continued dialogue, 
cooperation and reviews of the ambition level will remain critical all the way to 2030 and 
beyond.  

26