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Comments from the EU to the Spanish Energy Plan. Towards European Energy Convergence.

01 July 2019

The EU responds to the NECP (integrated national energy and climate plan) sent by the Spanish Government.

The European Commission publishes on 21 December 2018, the Regulation (EU) 2018/1999 on the governance of the Union of Energy and Climate Action.

It sets out the bases to configure the plans (NECP: integrated national energy and climate plans) that each of the member states must present to the European Commission.

Binding objectives (for 2030) for the Union of Energy and Climate Action are:

1. 40% emission reduction
2. 32% of final consumption of renewable

Indicative objectives:

1. 32.5% energy efficiency
2. 15% interconnection capacity.

On February 22, 2019, the government published the documents related to the legislation that constitute the Strategic Framework of Energy and Climate, basic pillar of our country's energy transition. They remained under public consultation until April 1.

Members of the Strategic Framework are:

A) The Integrated National Energy and Climate Plan (NECP).

This is the document-response to the European Commission, the requirement made to all member countries, including the period of 2021-2030 and tending to comply with the decarbonisation agreements of Paris.

"The plan lays the foundations for the modernization of the Spanish economy, the leadership position of Spain in renewable energy, the development of the rural environment, the improvement of the health of people and the environment, and social justice."

The draft document of the Spanish NECP sent to the Commission on February 22, 2019 can be seen in: https://ec.europa.eu/energy/sites/ener/files/documents/spain_draftnecp.pdf

In the previous article, we refer to the article entitled "10 keys to a good Integrated National Energy and Climate Plan", by Javier García Breva: "The NECP has to establish national objectives, planned measures, barriers and impacts on the competitiveness in the five dimensions of energy security, internal market, energy efficiency, decarbonisation and research, innovation and competitiveness "

B) The Law of Climate Change and Energy Transition.

Recently, the report prepared by the Energy Transition Expert Committee was published, created by the Council of Ministers at its meeting on July 7, 2017, as well as a summary report edited by the UNEF.

C) The Just Transition Strategy and the National Strategy against Energy Poverty 2019-20124. We already alluded to in previous article.

On June 18 of this year, the European Commission responds to the NECP sent by the Spanish government, with a series of observations, recommendations and other results of its evaluation. A rewrite of the NECP in response to these observations from the Commission should be resubmitted before the end of 2019.

We extract literally (from the seven pages that make up the Commission's response) some of the recommendations / observations of the Commission, for the improvement of the document:

1: Demonstrate that they have properly taken into account the energy efficiency first principle, by explaining notably how energy efficiency contributes to the cost-effective delivery of the national goals of a competitive low-carbon economy, security of energy supply and to address energy poverty.
2: There is a broad coherence of the objectives within and between the dimensions, in particular on decarbonisation and energy efficiency.
3: Spain should also describe the interlinkages between planned policies and measures and further quantify these where possible. A focus could be the synergies between the decarbonisation, the energy security and internal market dimensions with the energy efficiency first principle, by explaining how energy efficiency contributes to the costeffective delivery of the national goals of a competitive low-carbon economy, security of energy supply and its link to addressing energy poverty.
4: The interactions of the planned policies related to the phase out of coal-fired power plants and nuclear power plants, including the strategy for the use of nuclear fuel cycle facilities existing in the country, the impact of climate change risks on energy supply, and the impact of the increased penetration of renewable energy on the internal market
5: Present a global analysis of the current position of the low-carbon technologies sector in the world market, in which

a) areas of competitive strength and possible challenges will be determined,
b) quantifiable objectives for the future will be identified, as well as policies and measures to achieve them, and
c) appropriate links will be established with the business and industrial policy.

6: Underpin the welcome level of ambition of a 42 % renewable energy share for 2030 as Spain’s contribution to the Union’s 2030 target for renewable energy
7: Explore further on how the current measures would need to be further developed to realise their ambition towards achieving the expected energy savings.
8: Further develop measures supporting the energy security objectives on diversification and reduction of energy dependency, including measures ensuring flexibility, as well as information on phase-out from nuclear.
9: Outline a strategy and timeline for progressing towards fully market based prices.
10: Further clarify national objectives and funding targets in research, innovation and competitiveness, specifically related to the Energy Union, to be achieved between now and 2030.
11: Intensify the existing good regional cooperation with France and Portugal to address notably internal energy market and energy security areas, in particular cross-border and cross regional interconnections.
12: Providing more details on social, employment and skills impacts of planned objectives, policies and measures.(…) address the impacts on the coal and carbonintensive regions.
13: Include a specific assessment of energy poverty problems.

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