Dear Lars,
Denmark and all other EU countries must prepare a revised National Climate and Energy Plan (NECP) this spring. We are writing to you to clarify how Denmark intends to ensure the prescribed meaningful involvement of civil society in the NECP process?
The first NECP was drawn up in 2019, when the general election, change of government and climate act meant that the NECP process took place largely without public attention or involvement. When Denmark had to prepare its Recovery Plan in 2021, it was done without involvement. Had there been timely transparency about how the then government intended to spend the approx. 11.5 billion kroner in Denmark’s Recovery package, it could for example be pointed out in time that the RRP money should not go to support hybrid cars, which are not green.
With this inquiry, we want to ensure that the lack of involvement does not repeat itself during the current and future audit processes. Several EU decisions and regulations require real and meaningful involvement:
- Meaningful involvement in the NECP revision. The NECP process was established by the Governance Regulation 2018/1999. Article 10 of the Regulation obliges the member states to involve the public in the preparation of the NECP, among other things, by establishing an early and real opportunity to contribute. Including that the Member States, cf. Article 7 of the regulation, make written analysis work and other relevant information available to the public.
- Establishment of a Multilevel Climate and Energy Dialogue in Denmark. Article 11 of the Governance Regulation establishes that a permanent Climate and Energy Dialogue (Multilevel Climate and Energy Dialogue) must be established in each member state.
- Meaningful involvement in the preparation of the RePower chapter in Denmark’s Recovery Plan. With the RePowerEU agreement, it was decided that the EU countries, with real involvement of the public, must now describe the energy crisis projects they want financed by RePower. In the case of Denmark, there is an opportunity to finance approx. 1.5 billion DKK
“Meaningful involvement” can of course be achieved in various ways, but we do not believe that this has happened until now. In addition to the above examples of lack of involvement in connection with the NECP process, the public consultation on the RePowerEU chapter in Denmark’s Recovery Plan that has just been launched is another example of how the opportunity for meaningful involvement is missed. In connection with this “hearing”, no information is presented about the measures the government intends to finance with the RePowerEU money. Any consultation responses will thus have to be written blindly rather than on the basis of the specific expected measures.
Based on this, we encourage you to ensure that the necessary processes for meaningful public involvement, as required by the EU decisions and the regulation, are established.
We look forward to your response regarding this.
Full letter here: https://www.92grp.dk/fokus-og-nyheder-forside/740-brev-til-klimaministeren-om-meningsfuld-inddragelse-af-civilsamfund-i-revisionen-af-danmarks-necp.html
Download necps report — march 2023
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