The Spanish Strategic Framework for Climate & Energy lacks ambition and it is not enough to tackle climate change

The International Institute of Law and the Environment (IIDMA) describes the Strategic Framework for Energy and Climate as a step in the right direction but it would require more concrete measures and more ambitious objectives in general, as assessed after a detailed analysis of its content within the process of public participation. IIDMA describes the draft National Energy and Climate Plan (NECP) as “positive, although there is room for improvement”, which was submitted in February to the European Commission for evaluation and will be one of the pillars of the future regulatory framework on climate change and energy transition in Spain. The draft Climate Change and Energy Transition Act (LCCTE), on the other hand, is less ambitious than the draft of 14 November. Finally, the Just Transition Strategy is complementary to the previous documents.

Although the NECP will deploy a number of positive measures for the decarbonization of the economy, it still contains several aspects to be improved. In particular, the comments presented by IIDMA highlight the absence of a concrete date for the end of coal-fired power plants and coal power generation, despite the fact that it is technically feasible to stop coal by 2025 and that it would mean considerable savings in polluting emissions. In this regard, emissions from coal-fired power plants have been linked, among others, to more than 1,500 premature deaths, according to the study “A dark outlook: the aftermath of coal”, between 2015 and 2016 in Spain. Likewise, certain aspects related to the promotion of renewable energies lack details and defined milestones of progress. Other recommendations made by IIDMA include the improvement of regional cooperation actions with other Member States of the European Union, which is fundamental given the inter-state nature of problems such as climate change, atmospheric pollution or the improvement of electrical interconnections.

The NECP sets a target of reducing greenhouse gas emissions by 20% in 2030 compared to 1990 and not compared to 2005, which is positive, even foreseeing government intervention if necessary to adopt emergency measures if the needed milestones to achieve the established goals are not met. However, this target is not ambitious enough to limit the global temperature increase to well below 1.5ºC. This 20% reduction is still in line with the EU’s 40% GHG reduction target compared with 1990, which was adopted before the Paris Agreement was approved. However, by 2030 the EU as a whole would need to reduce at least 65% of GHG emissions compared to 1990 levels to meet the 1.5°C target. Thus, Spain should also set a GHG reduction target for 2030 of at least 50% compared to 1990 levels. Likewise, the decarbonisation of the electricity sector relies mainly on the pillars of reducing the use of fossil fuels and their progressive substitution by renewable energies, where targets are set that could be higher: 74% of total electricity production by 2030 is conservative with a view to reaching 100% by 2050.

Draft Climate Change and Energy Transition Law preliminary project, on the other hand, is less ambitious compared to the version of 14 November 2018. IIDMA criticizes the disappearance of the independent Climate Change Committee, a fundamental body for the implementation and development of the Law to be approached from a strictly scientific point of view, with the aim of making it an effective instrument in the fight against climate change. The possibility of including carbon budget mechanisms in the NECP, an efficient measure for the control and monitoring of long-term emission reductions that was included in the first version, has also disappeared. Finally, it would be necessary to include in the Law the clear objective of achieving emissions neutrality by 2050.

IIDMA comments also highlight the importance of climate governance, especially with regard to public participation, something that is remembered concerning the three documents of the Strategic Framework. An efficient climate governance framework must be established to ensure the implementation of ambitious climate and energy policies and regulations to achieve the goals of the various international treaties, such as the Paris Agreement. It is also highlighted once again that the draft NECP should have been subject to public participation prior to being sent to the European Commission in line with the provisions of the Aarhus Convention.

Another point to take into account in the Framework are the gaps in the development of training policies within the labor forecasts in the greener sectors. It is necessary to include more training plans for the creation of the jobs foreseen in sectors such as renewable energies, where the NECP foresees a growth. between 102,000 and 182,000 jobs/year for the period 2020-2030.  Within the Just Transition Strategy, more concrete Green Vocational Training measures are foreseen for sectors affected by the Just Transition.

The end of coal: lack of ambition.

In the case of coal, the scenario drawn by the different legal instruments is plausible, but not very ambitious. It does not include a specific date for the coal phase-out, which should be 2025 at the latest in order to meet the objectives of the above-mentioned Paris Agreement to tackle climate change. On the contrary, the NECP assumes that market rules will leave out this most polluting fuel by 2030 at the latest, due to the reduction in the cost of renewable energies and the progressive increase in the price of CO2 in the EU Emissions Trading Scheme (EU ETS).

A positive point in this sense would be the recognition, included in the NECP, that in 2021 only 6 of the 15 coal-fired power plants operating in Spain remain open, and these 6 will be progressively closed in that decade due to the market itself, regardless of the investments to update them. However, no specific measures are included for the dismantling or deactivation of the plants, the closures of which will be decided on a case-by-case basis. However, neither the NECP nor the LCCTE envisages the implementation of specific aid for coal.

“The Spanish electricity system has overcapacity and could phase-out coal long before 2030 without endangering security of supply. By not including a specific date in a binding legal instrument and leaving the closure of plants in the hands of the market, there is a danger that some will continue to operate after 2030,” says Guillermo Ramo, IIDMA’s lawyer.

“With the call for elections in April and the dissolution of the Courts, the Law and the Just Transition Strategy are put on hold, but we believe that, whatever the government of the next legislature, these comments remain useful. It is essential to bear in mind that climate change is a problem that affects us all, and for whose effects Spain is a particularly vulnerable country. The next legislature should prioritize the creation of a stable regulatory framework with ambitious objectives” says Massimiliano Patierno, environmental engineer at IIDMA.

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