Estonia’s REPowerEU chapter: civil society excluded from decision-making on energy transition investments

Since the launch of the REPowerEU strategy, Member States have been working to amend their national recovery and resilience plans to include measures that meet the objectives of the European Union’s plan to wean Europe off Russian fossil fuels and accelerate the green transition. On 12 May 2023, the European Commission endorsed Estonia’s amended recovery plan, worth a total of EUR 953 million. Compared to the initial document, the new version of the plan supports a bolder shift towards domestic renewable energy independence. However, there has been a lack of transparency in the updating process and the voices of civil society organisations have not been heard. This is deeply regrettable. After all, if public money is to be spent in a way that truly benefits ordinary people, civil society must have a say in how it is allocated.  

What do we know about Estonia’s amended recovery plan? 

Although the amended recovery plan has been endorsed by the European Commission, it has still not been shared with the public. A table providing an overview of amendments to Estonia’s recovery plan was published in mid-December 2022. Surprisingly, however, in a press release issued by the Ministry of Finance on 12 May 2023, announcing the Commission’s endorsement and the final financial adjustments to the plan, the table had suddenly changed. Notably, a new investment for an offshore wind farm was added during the negotiations without any prior information being provided. Throughout this intervening period, no further documentation was made available to the public, making it impossible for civil society organisations to follow the progress and status of the negotiations. In effect, the public was left uninformed about the planned interventions and the eligibility criteria for the newly added investments.  

Based on currently available information, several measures unrelated to energy issues have been removed from the initial recovery plan. These include plans for Tallinn Hospital, the controversial Rail Baltica terminal, the Turba–Rohuküla railway line and the acquisition of medical helicopters. Some of the removed measures have been replaced with new energy-related investments, including the development of offshore wind farms (EUR 66.8 million), support for companies to replace their fossil fuel heating sources (EUR 20 million) and a hydrogen-powered ship (EUR 18 million). Additionally, financial support for the reconstruction of small residential buildings has increased from EUR 8.9 million to EUR 28.9 million. The newly added REPowerEU chapter includes additional grid investments (EUR 38 million in total), support for biogas production (EUR 20.2 million) and a new reform to accelerate the deployment of renewable energy (EUR 31.8 million).  

This renewable energy reform aims to remove the barriers that have hindered Estonia’s wind energy potential up to this point. It follows the Estonian government’s decision to support amendments to the existing energy sector legislation, which sets a new ambitious target of supplying 100 per cent of Estonia’s annual electricity consumption from renewable energy sources by 2030. The reform consists of several elements, such as mapping additional suitable areas for wind parks, simplifying and shortening strategic environmental impact assessment procedures, optimising permitting processes. While accelerating the deployment of renewable energy is in principle the right thing to do, environmental organisations have raised concerns about the potential of the reform to exacerbate negative impacts on biodiversity. The installation of wind parks is inevitably associated with some degree of deforestation. However, environmental civil society organisations have repeatedly emphasised the need to address the climate and biodiversity crises simultaneously. They argue that relying solely on offsetting mechanisms is not sufficient to reverse the destruction of forest ecosystems, which is why they oppose the use of forests as sites for wind parks. As part of their commitment to upholding existing EU nature legislation, these organisations will continue to monitor the design and implementation of this reform to expose any environmentally destructive practices that may occur under the guise of clean energy. 

Support for community energy still absent from the amended recovery plan   

Although it is fair to acknowledge the limited resources of REPowerEU and the need to make strategic decisions in a short space of time, the Estonian REPowerEU chapter has completely overlooked measures related to energy communities, which environmental civil society organisations were hoping to see added to the revised version. Due to the tight timeframe, the Estonian ministries evidently preferred to increase the volume of existing measures instead of introducing new ones. Given that the Estonian government previously included no support for energy communities across its entire Multiannual Financial Framework 2021-2027 and Recovery and Resilience Facility funding, yet another opportunity to incorporate important provisions for energy communities has been squandered. 

Environmental civil society organisations have highlighted the need for state support to stimulate and encourage the emergence of energy communities, but the current political context has forced other priorities. Given the need to improve energy independence and strengthen a decentralised energy system, the allocation of public finances to promote community energy is crucial to empower citizens and send the right message to the energy market.  

Lack of inclusion and meaningful participation 

Although environmental civil society organisations have been proactive in regularly contacting the ministries regarding the drafting of the REPowerEU chapter since the plan was announced in late spring 2022, there has been a lack of clear communication from the government. Based on our discussions with  several ministry officials, we were told that the lack of progress on public consultations was due to the absence of clear instructions from the European Commission. But it is precisely these consultations, including those with civil society organisations, that the Commission has stated should be made transparent in the development of the REPowerEU chapters. According to the amended regulation and Commission guidance, Member States are required to justify how they incorporate stakeholder input. Therefore, this situation evidently demonstrates the government’s lack of transparency and non-compliance with the basic requirement to consult with stakeholders.   

A consortium led by Trinomics consultancy, contracted by the Directorate-General for Structural Reform Support (DG REFORM), has compiled a country report focusing on the necessary investments to be included in Estonia’s REPowerEU chapter. The as-yet unpublished draft report, which has been shared with us, does not include any input from environmental civil society organisations. However, in the drafting of the report, the authors did consult industry representatives and business stakeholders. This renders the Estonian ministries’ excuses for avoiding public consultation with other stakeholders questionable at best. And although the final recommendations of the report partially overlap with those independently submitted by civil society organisations, the exclusion of these organisations from the process is deeply disappointing. Environmental stakeholders should at least be given the same platform as other groups to provide informed input and raise concerns regarding the use of public finances.  

Public participation needs to be enhanced 

Estonia’s proactive and determined approach in becoming the first country to have its REPowerEU chapter greenlit by the European Commission is commendable. However, the participation of civil society is fundamental for safeguarding the public interest. If there is time to consult with businesses, there is time to consult with environmental partners. It all comes down to a matter of choice. 

We call on the Estonian authorities to provide transparent feedback on the decisions that led to the exclusion of contributions from civil society organisations. We strongly urge the EU authorities to consider the input that was overlooked at the national level before the chapter is formally adopted by the Council. It is essential that these concerns are adequately addressed through alternative EU processes, such as the revision of Estonia’s 2030 National Energy and Climate Plan or the Modernisation Fund. The involvement of civil society organisations in the implementation of policies, in particular the reform of renewable energy sources, must be strengthened. 

In the context of the overlapping crises, it is more important than ever to keep policy-making transparent and democratic. Only by keeping civil society on board will the green transition be socially just and accepted.