Germany’s National Energy and Climate Plan: A positive step forward, but underestimates the climate challenge
Berlin – Germany submitted its final National Energy and Climate Plan (NECP) to the European Commission on August 29th. While this represents an important step toward achieving its climate goals, the plan still falls short in acknowledging the complexity of the climate challenge and the range of solutions required to meet it.
The NECP, a 10-year planning document outlining how Germany intends to meet the EU energy and climate targets for 2030, details Germany’s efforts to cut its emissions and advance clean energy. The plan shows promise, with ambitious renewable energy goals, but still indicates that Germany is relying too heavily on imported fossil fuels and a narrow set of clean energy technologies – without the appropriate consideration of cost-effectiveness and reliability that would necessitate support for a broader set of solutions, including nuclear energy, carbon capture and storage, clean hydrogen, and methane mitigation.
“The final NECP tells us that Germany is underestimating the scale and complexity of the infrastructure challenge,” said Alejandra Muñoz Castañer, Government Affairs Manager, Europe at CATF. “While we welcome the increased renewable energy ambition, the plan still lacks the policy and technology support needed to expand Germany’s suite of climate solutions and ensure energy security, reliability and a fully decarbonised energy system. To mitigate geopolitical uncertainties and potential supply chain risks of certain technologies or their underperformance, Germany would be better off further diversifying its energy sources and strengthening its energy security.”
A diverse portfolio that includes clean firm generation technologies such as nuclear energy, geothermal energy, fusion energy, carbon capture, and zero-carbon fuels would help reduce risk and lower total system costs, increase reliability, and reduce land, critical minerals, and infrastructure needs.
For more on specific components of Germany’s NECP, hear from CATF’s subject matter experts below.
Carbon capture and storage in Germany’s NECP
Nearly a quarter of Germany’s CO2 emissions come from its industrial sector, which emits 147 Mt CO2 emissions per year, making it the highest emitting in Europe. For context, industry of Europe’s second largest emitter, France, emits nearly half of that number, with 75 Mt CO2 per year. Decarbonising Germany’s industries is thus imperative for achieving climate neutrality in Europe. It is a welcome development that the German NECP recognises the role for carbon capture and storage (CCS) technologies, both for tackling these industrial emissions and for achieving net-zero emissions through the development and deployment of permanent carbon removals, such as those delivered through CCS-based methods such as direct air capture (DAC) and bio-CCS to tackle remaining residual emissions. It is also welcome that the NECP recognizes the crucial fact that these technologies will depend on the same CO2 infrastructure as point-source CCS on industrial installations.
While recognising the role of CCS as a necessary part of the climate toolbox in the NECP is a step in the right direction, and the development of a Carbon Management Strategy (CMS) and plans to remove regulatory barriers are crucial, the NECP falls short of providing the concrete measures and commitments recommended by the European Commission. Given the CMS, it is surprising that at least some indicative targets and details were not included beyond the measures already expressed to be part of, or supporting the CMS.
The European Commission’s guidance clearly outlines that Member States should provide annual projections of process emissions requiring CO2 capture, available CO2 for geological storage, and specific storage capacities. Additionally, there should be detailed plans for developing CO2 transport infrastructure, public funding support for CCS investments, and any other measures to ensure the deployment of long-term geological storage. Germany’s NECP lacks these specifics, which are essential for creating a clear pathway to integrating CCS effectively into the national climate strategy up to 2030.
“Germany has recognised that CCS is necessary for achieving its climate targets, and it is welcome news that this recognition is present in the NECP. Unfortunately, the NECP remains a document of intentions, rather than a plan of action around CCS deployment by relying on future actions to be outlined in the forthcoming Carbon Management Strategy,” said Codie Rossi, Carbon Capture Senior Policy Associate at CATF.
Hydrogen in Germany’s NECP
Hydrogen is another key element of Germany’s NECP, mentioned almost 300 times across the published NECP document. Much of what is included on hydrogen mirrors plans and actions outlined in the nation’s 2023 updated National Hydrogen Strategy.
Germany remains overly ambitious and optimistic on the role that hydrogen can play for both the transformation of its industry (e.g., electrolyzer manufacturing) and decarbonisation of its economy. Despite this ambition, national plans lack realistic targets and actions on how clean hydrogen can be sustainably integrated into the economy, particularly for sectors where clean hydrogen may be the only decarbonisation option available.
While clean hydrogen can play an important role in Germany’s decarbonisation efforts, it will not be a panacea for solving the entire problem. It is also questionable how much it can contribute to national energy security. Germany has limited domestic energy resources which, consequently, limits its clean hydrogen resources. To make up for this reality it is placing huge and possibly risky bets on meeting much of its clean hydrogen needs from imports.
Germany must plan carefully for how much hydrogen it can realistically produce. That means putting aside political ideology and taking a more agnostic approach to all available low-carbon production pathways. It must limit its dependence on imports to an as-needed basis, which would limit its vulnerability to possible supply chain constraints. Whatever clean hydrogen resources it does amass should be deployed in the parts of its economy that need it the most today, particularly parts of heavy industry and transportation sub-sectors.
“Germany’s NECP lacks a strategic framework for the role of clean hydrogen in its decarbonised economy, almost leaving it up to the markets to decide its fate. It should plan much more carefully around how much clean hydrogen stock it can realistically amass and where its deployment must be prioritized. In doing so, Germany will increase its chances of developing a functional clean hydrogen economy at an appropriate scale and avoid infrastructure lock-in and future stranded assets. It will also set a precedent for other Member States to follow in building their own appropriate domestic hydrogen markets, leading to a suitable and sustainable clean hydrogen network functioning across Europe,” said Alex Carr, Europe Policy Manager for Zero-Carbon Fuels at CATF.
Methane mitigation in Germany’s NECP
An often-overlooked building block in reducing greenhouse gas (GHG) emissions is methane. As the second greatest contributor to climate change, it is over 80 times more potent than CO2 for global warming over a period of 20 years. Mitigation is therefore crucial to reduce the impact of climate change in our lifetimes and avoid irreversible tipping points.
Germany’s final NECP includes important measures to reduce emissions in the agricultural and waste sectors, including landfill aeration, reduction of food waste, and managing emissions from livestock farming and manure. While Germany’s NECP does set overall GHG reduction targets, it falls short of defining specific targets for methane emissions reductions in the waste and agriculture sectors.
Considering the recent adoption of the EU’s Methane Regulation, Germany’s planning should also include steps to reduce methane emissions from fossil fuels, including imported oil, gas, and coal. This will require building sufficient capacity of the national authorities responsible for its implementation, establishing rigorous fees for non-compliance, and working with partner countries to proactively abate upstream emissions.
“Germany’s NECP lays out important steps to address methane emissions in the waste and agriculture sectors, but without accompanying methane emissions reduction targets, the plan falls short of guaranteeing that these measures will be implemented at the necessary speed and scale,” said Brandon Locke, Europe Policy Manager, Methane Pollution Prevention at CATF.
“As a Global Methane Pledge Champion, Germany committed to be a global leader on methane – to truly be a role-model for other countries, it should develop abatement targets, timelines, and financing commitments in a subsequent Methane Action Plan. This plan should also include measures to curb emissions from imported oil and gas and support the global implementation of the EU’s new Methane Regulation,” Locke continued.
Sixteen countries, including Spain, Portugal, Poland and Belgium have yet to submit their final NECPs to Brussels, despite the deadline of June 30th. After all EU Member States have submitted their final NECPs, the European Commission will review each plan to ensure that the EU is collectively on track to meet its 2030 climate targets. The Commission will provide feedback and may request adjustments. Its earlier assessment of the draft plans in December 2023 found that they were not ambitious enough collectively to meet several of the EU’s key targets.
Press Contact
Julia Kislitsyna, Communications Manager, Europe, [email protected], +49 151 16220453
About Clean Air Task Force
Clean Air Task Force (CATF) is a global nonprofit organization working to safeguard against the worst impacts of climate change by catalysing the rapid development and deployment of low-carbon energy and other climate-protecting technologies. With more than 25 years of internationally recognized expertise on climate policy and a fierce commitment to exploring all potential solutions, CATF is a pragmatic, non-ideological advocacy group with the bold ideas needed to address climate change. Visit cleanairtaskforce.org and follow @cleanaircatf
