Not (yet) a missed opportunity. Influencing the 2021- 2030 NECPs through early Public Participation

ClientEarth warns that the Governance Regulation (GR) may allow EU Member States to bypass meaningful public participation during the initial drafting of National Energy and Climate Plans (NECPs). The briefing argues that waiting until after the first draft is submitted to the European Commission risks ignoring the interests of citizens and renewable energy developers in favor of fossil fuel operators. It highlights potential legal breaches of the Aarhus Convention and the SEA Directive, noting that some countries, such as Romania, have provided insufficient consultation windows (seven days). ClientEarth calls for a minimum eight-week consultation period before the first draft submission to ensure all policy options remain open.

• The Governance Regulation (GR) requires Member States to prepare National Energy and Climate Plans (NECPs) for 2021-2030 and long-term strategies (LTS) with a perspective of at least 30 years, aiming to deliver the objectives of the Paris Agreement.
• There is a significant risk that NECPs will primarily reflect the interests of fossil fuel operators if public participation does not occur early in the process, specifically before the first draft is submitted to the European Commission.
• ClientEarth contends that Article 10 of the GR may be incompatible with the Aarhus Convention because it allows public participation to occur after the first draft is created, whereas the Convention requires participation "when all options are open".
• The briefing argues that the Strategic Environmental Assessment (SEA) Directive should apply to NECPs because the plans include infrastructure projects and environmental impacts that match the directive's requirements.
• Member States show diverging and often insufficient approaches to public consultation: Romania provided only seven days for comments, while Germany, Italy, and Bulgaria planned to wait for European Commission recommendations in June 2019 before consulting the public.
• ClientEarth recommends that Member States implement a public consultation period of at least eight weeks prior to delivering the first draft NECP to the European Commission to ensure meaningful input without delaying the final 31 December 2019 deadline.

APA

ClientEarth (2018). Not (yet) a missed opportunity. Influencing the 2021- 2030 NECPs through early Public Participation. https://www.clientearth.org/media/deaipy4g/influencing-necps-2021-to-2030-through-public-participation-ce-en.pdf

Chicago

ClientEarth. Not (yet) a missed opportunity. Influencing the 2021- 2030 NECPs through early Public Participation. 2018. https://www.clientearth.org/media/deaipy4g/influencing-necps-2021-to-2030-through-public-participation-ce-en.pdf.

Wikipedia

{{cite report |author=ClientEarth |title=Not (yet) a missed opportunity. Influencing the 2021- 2030 NECPs through early Public Participation |date=7 December 2018 |url=https://www.clientearth.org/media/deaipy4g/influencing-necps-2021-to-2030-through-public-participation-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{clientearth2018not, author = {{ClientEarth}}, title = {{Not (yet) a missed opportunity. Influencing the 2021- 2030 NECPs through early Public Participation}}, institution = {ClientEarth}, year = {2018}, month = dec, url = {https://www.clientearth.org/media/deaipy4g/influencing-necps-2021-to-2030-through-public-participation-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }