LETTER to the European Commission: update long-term strategies and issue guidance for Member States

Climate action

We as signatory organisations to this letter ask you to invite and encourage Member States to
update their national long-term strategies, and to provide guidance to them on how best to do
so. We also ask you to prepare an update to the EU’s own Long Term Strategy, for submission
to the UNFCCC.

1. Updating long-term strategies is necessary for the EU to be consistent with its
long-term objectives
National Long Term Strategies (nLTSs) have in many cases been overlooked or not prioritised.
They are mostly also lacking key information and were prepared with inadequate public
engagement1. This is deeply concerning, as they are critical to enabling countries, regions,
economic sectors and businesses to plan ahead, improve competitiveness, avoid wasting
money on stranded assets, and ensure a just transition for all citizens in the EU.
According to Article 15 of the Regulation on the Governance of the Energy Union and Climate
Action, “Member States should, where necessary, update [their national long-term strategies]
every five years”. As signatories to this letter, we believe there are compelling reasons for
Member States and the EU as whole to update such strategies, namely:
● The world has changed dramatically since the Governance Regulation entered into force
and the first long-term strategies were submitted – both in terms of the external context
and in term of EU climate and energy targets: ongoing fossil-fueled energy crisis,
COVID-19 crisis, cost of living crisis, accumulation of scientific evidence on the need to
act swiftly to prevent dangerous climate change…
● In parallel, the EU climate and energy regulatory framework has thoroughly changed as
well, as a consequence of the adoption of the EU Climate Law, its introduction of a
binding long-term climate-neutrality objective for the EU, as well as the Fit for 55 and
REPowerEU packages. The current group of submitted long-term strategies is therefore
1 See Charting a Path to Net Zero: an assessment of national long-term strategies in the EU (Ecologic,
outdated, not least because nLTSs are required to be consistent with the EU’s
climate-neutrality objective set out in the Climate Law, according to Article 15.1 of the
Governance Regulation;
● Waiting until 2029 for Member States to update their nLTSs is high risk, and the
exhortation in the Governance Regulation that Member States update those strategies
every five years “where necessary” is now clearly applicable;
● National Energy and Climate Plans (NECPs) are legally required to be consistent with
nLTSs, which given the major recent updates to NECPs is unlikely now to be the case,
making one or both potentially vulnerable to challenge;
● The EU and its Member States need to continue to demonstrate leadership at
international level, including by responding to the invitation to UNFCCC parties at
COP28 to update their long-term low greenhouse gas development strategies
(something Member States themselves called for2).
Therefore, we as signatory organisations to this letter ask you to invite and encourage
Member States to update their national long-term strategies in 2025, as set out in the
Governance Regulation, while respecting the principle of non-regression. We also ask you
to prepare an update to the EU’s own LTS, for submission to the UNFCCC. Besides making
good on the commitments given at the COP, this would also provide invaluable support to
Member States in updating their own long term strategies and to industry sectors planning
pathways to a competitive and low carbon future.

2. Issuing guidance for Member States to support them in preparing robust nLTSs
EU Member States are currently in the process of updating their NECPs, based on the
constructive guidance and recommendations provided by your services. On 15th December
2022, the European Commission’s Directorate General for Energy published a Commission
Notice on the Guidance to Member States for the update of the 2021-2030 national energy and
climate plans (NECPs). This document, published ahead of the submission of the draft updated
NECPs, laid down principles and good practices for updating NECPs, and highlighted the new
political context and higher ambition of the EU that needed to be taken into account when
updating those plans. This provision of guidance for the update of NECPs is a good
practice per se and it would be relevant to issue guidance for the update of national
long-term strategies as well.
Therefore, we as signatory organisations to this letter ask you to provide Member States with
guidance on how best to update their national LTS. This guidance should be comprehensive
enough to ensure that national long-term strategies are updated and fit for purpose, and can
effectively guide the implementation of the EU Green Deal and the achievement of the EU-wide
climate-neutrality objective, as well as the updated 2030 climate target and the upcoming 2040
2 See Council conclusions on Climate and Energy Diplomacy:
climate target.3 We attach in annex some suggestions on what we believe it would be useful for
you to include in such guidance, and what other steps would be helpful, based on our
experience of seeing how the existing rules have been implemented by Member States to date.