Energi-, Forsynings- og Klimaudvalget 2015-16
EFK Alm.del Bilag 243
Offentligt
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CONSULTATION ON STREAMLINING OF PLANNING
AND REPORTING OBLIGATIONS AS PART OF THE
ENERGY UNION GOVERNANCE
Fields marked with * are mandatory.
What this consultation is about
The Commission's State of the Energy Union presented on 18 November 2015 states that "[t]he
Energy Union needs a reliable and transparent governance process, anchored in legislation, to make
sure that energy-related actions at European, regional, national and local level all contribute to the
Energy Union's objectives." This corresponds to similar calls from the European Council and the
European Parliament[*].
The State of the Energy Union also underlines that "[i]ntegrated national energy and climate plans,
addressing all five dimensions of the Energy Union, are necessary tools to have more strategic
planning", and that "[i]n order to track progress, a transparent monitoring system needs to be put in
place based on key indicators as well as on Member States' biannual reports concerning progress
made on their national plans". This builds further on the Commission's Communication on the Energy
Union from February 2015, which explained that a purpose of the governance process for the Energy
Union is to "streamline current planning and reporting requirements, avoiding unnecessary
administrative burden".
In this context, the present consultation seeks stakeholders' views on current planning and reporting
arrangements in the energy field, and on how these could be improved to better serve the objectives
of the Energy Union and to reduce administrative burden. An overview of existing planning and
reporting obligations in the energy sector concerning the Member States as well as the Commission
is available here:
COM planning and reporting obligations (energy field)
;
MS planning and reporting
obligations (energy field);
 
COM planning and reporting obligations (climate field); MS planning and
reporting obligations (climate field).
The responses to the public consultation will feed into the Commission's evaluation and fitness check
of existing planning and reporting obligations (a REFIT initiative in the Commission's 2015 Work
Programme) as well as into the Impact Assessment for the Commission's proposal(s) for streamlining
of planning and reporting in the energy field foreseen for late 2016, as announced by the State of the
Energy Union.
The consultation as well as the initiatives it will contribute to should be understood in the broader
context of the Energy Union strategy; the Commission's guidance to Member States on national plans
from 18 November 2015, and the Council's Conclusions on Energy Union governance from 26
November 2015 – which underscore the need for holistic national plans that address all five
dimensions of the Energy Union in an integrated way.
This public consultation also relates to the preparation of other initiatives to implement the Energy
Union foreseen for 2016 (notably initiatives on energy efficiency, renewable energy and electricity
market design). For other completed and ongoing public consultation processes and their outcomes,
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market design). For other completed and ongoing public consultation processes and their outcomes,
see:
http://ec.europa.eu/energy/en/consultations
.
[*] REF to EUCO October 2014 and March 2015; EP 15 Dec 2015.
The questionnaire is structured as follows:
A. Respondent's profile
B. Evaluation of existing planning obligations
C. Evaluation of existing reporting obligations
D. Options for streamlining planning and reporting obligations
E. Options for the governance of the Energy Union
Questions marked with an asterisk (*) are mandatory.
*
A. Respondent's profile
Please provide information to help us build your profile as a respondent. In accordance with
Regulation 45/2001[*], all personal data collected through this survey will be kept securely and will
ultimately be destroyed.
[*] Regulation (EC) No 45/2001 of the European Parliament and of the Council of 18 December 2000
on the protection of individuals with regard to the processing of personal data by the Community
institutions and bodies and on the free movement of such data, OJ L 008, 12.1.2001, p.1.
A.1 Are you answering as an individual or on behalf of an organisation/institution?
I am answering as an individual.
I am answering on behalf of an organisation.
A.2 Please specify your main field of activity.
Please tick the appropriate field. Only one choice is possible:
Individual citizen
National public authority (central or local government)
Private company/ Industry association
International organisation
Workers' organisation/trade union
Research organisation/university
NGO
Other interest group organisation/association
Other - please specify:
*
A.3. Please indicate your country of residence/establishment:
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*
A.3. Please indicate your country of residence/establishment:
If answering as an individual, please provide your country of residence.
If answering on behalf of an organisation/institution, please provide the country of establishment of
the organisation/institution.
Please tick the appropriate field, only one choice is possible.
Austria
Belgium
Bulgaria
Croatia
Cyprus
Czech Republic
Denmark
Estonia
Finland
France
Germany
Greece
Hungary
Iceland
Ireland
Italy
Latvia
Liechtenstein
Lithuania
Luxembourg
Malta
Netherlands
Norway
Poland
Portugal
Romania
Slovenia
Spain
Sweden
Slovakia
Switzerland
United Kingdom
Other/international - please specify:
*
A.4 Name and contact details
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*
A.4 Name and contact details
I prefer to provide a general comment only. Please provide your general comment in the box
below. (up to 2000 characters)
I will provide my name and contact details in the boxes below.
[Questionnaire ends here]
Name:
Organisation (
where applicable
):
Address:
ID from the Interest Representative Register[*] (
where applicable
):
Telephone:
Email:
[*] In the interest of transparency, organisations (including, for example, NGOs, trade associations
and commercial enterprises) are invited to provide the public with relevant information about
themselves by registering in the Interest Representative Register and subscribing to its Code of
Conduct. If you are a registered organisation, please indicate the name and address of your
organisation and your Register ID number on the first page of your contribution. Your contribution will
then be considered as representing the views of your organisation.
*
A.5 Received contributions may be published on the Commission's website, with the identity
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A.5 Received contributions may be published on the Commission's website, with the identity
of the contributor. Which publication arrangement would you agree upon?
My contribution may be published under the name indicated.
My contribution may be published but shall be kept anonymous.
I do not agree that my contribution will be published.
B. Evaluation of planning obligations
Existing obligations
The EU energy and climate legislation includes a number of different planning obligations for the
Member States. Planning obligations play a crucial role for EU energy policies in e.g. the fields of
renewable energy, energy efficiency, security of gas supply, energy performance of buildings, waste
management and decarbonisation. The main features of existing planning obligations can be
summarised as follows:
Current planning obligations usually include indicators and projections as an analytical basis as
well as policies and measures needed to achieve the plan's objectives;
Current plans usually cover a specific area of the energy or climate field, but do not necessarily
refer to possible overlaps and interactions with other plans in these fields; in some cases
templates are provided, which can be either voluntary or compulsory;
Plans often have to be submitted once, but in many cases a periodical revision or the submission
of new plans is required. The process for the adoption of the plans is often left to the discretion of
the Member States;
The role of the Commission varies. In some cases, it monitors plans, in other cases, it analyses
plans and is requested to report to the European Parliament and the Council. In some instances
the Commission could ask for modifications. Furthermore, it can use its enforcement powers, if
the planning obligations are not fulfilled or not all the necessary details/content were provided.
1) How would you rate the following aspects of such planning obligations at EU level?
Very
important
Coherence of national plans
among all EU Member States
Effective and efficient
implementation of EU legislation
in the energy and climate field
Achievement of the EU energy
and climate objectives
Increased certainty for investors
across all EU Member States
stimulating economic growth as
well as research, innovation and
competitiveness of the EU
Better implementation of
Less
important
Not
important
No
opinion
Important
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Better implementation of
international commitments by the
EU as a whole and by Member
States (e.g. concerning the
reduction of greenhouse gas
emissions)
The Commission is better
enabled to provide substantial
and useful advice
If other, please explain: (up to 1000 characters)
2) Are you aware of overlaps or inconsistencies among the existing planning obligations in the
same or different areas of the energy and climate acquis? Please provide examples. (up to 1000
characters)
3) a) Which of the current planning obligations could in your opinion be streamlined[*] into one
integrated plan and why? (up to 1500 characters)
b) Are there any planning obligations that should be kept separate from the integrated plan?
(up to 1500 characters)
c) Are there any planning obligations that could be repealed? (up to 1500 characters)
[*] By streamlining we understand the possibility to integrate planning and reporting obligations
resulting from (different) sectorial legislation by reducing possible duplications or gaps in the reporting
and planning obligations, thereby ensuring transparency, coherence, relevance, efficiency and
effectiveness of the reporting and planning. Furthermore planning and reporting cycles should be
harmonised to the extent possible.
4) Which elements/articles of the current planning obligations in the field of renewable energy
do you consider indispensable and why? If relevant please, refer to specific Articles
of the
Renewable Energy Directive
. (up to 1000 characters)
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5) Which elements/articles of the current planning obligations in the field of energy efficiency
do you consider indispensable and why? Please, if relevant, refer to specific Articles of the Ene
rgy Efficiency Directive
and 
Energy Performance of Buildings Directive
. (up to 1000 characters)
6) Which elements/articles of the current planning in the field of low-carbon development
strategies do you consider indispensable and why? (up to 1000 characters)
7) Which elements/articles of the current planning obligations in the field of infrastructure
development (like for example TEN-E) do you consider indispensable and why? (up to 1000
characters)
8) Which elements/articles of other existing planning obligations in the field of energy,
including on security of supply, infrastructure and market integration do you consider
indispensable and why? (up to 1000 characters)
9) Can you provide qualitative or quantitative evidence on the administrative burden on
Member States and other stakeholders resulting from planning obligations at EU level? (up to
1000 characters; a possibility to upload further evidence is provided at the end of the
questionnaire)
Future obligations
10) What level of importance do you attach to future planning obligations for Member States in
the following key elements of the Energy Union Strategy?
Very
important
Security of supply
Internal Energy Market
Less
important
Not
important
No
opinion
Important
Energy infrastructure
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Energy infrastructure
Energy efficiency
Renewable energy
GHG emissions reduction
(decarbonisation)
Research, Innovation and
competitiveness
C. Evaluation of reporting obligations
Existing obligations
In the energy and climate field there are a number reporting obligations for the Member States and for
the Commission. These have been developed to cover specific elements of the Energy Union, with
less focus on integrated planning and reporting. Both the Member States and the Commission have
to abide to reporting obligations. Usually, the information collected through Member States' reports is
used by the Commission to assess trends in the climate and energy sectors, assess progress
towards certain policy objectives, to monitor implementation and to propose policy and legislative
reforms. Importantly, there are several different types of reporting obligations. The following
distinctions are useful for the purpose of evaluating them:
Reporting obligations can be regular or irregular. The former are fulfilled periodically; the latter
usually once or after a specific request.
The content of the reporting obligations may be specified in EU legislation, but the level of detail
varies from one sector to another.
Templates used to respond to reporting obligations are sometimes compulsory. In other cases,
they have a voluntary nature.
Reporting obligations are set up according to the information needs of each area of the energy
field linked to the specific requirement of the objective of the initiative. Only in some cases they
are coordinated with reporting obligations in other areas.
 
11) How would you rate the following aspects of reporting obligations in EU legislation?
Very
important
Coherence of reporting
formats among all EU
Member States
Possibility to monitor the
performance and trends (and
Less
important
Not
important
No
opinion
Important
put in place corrective
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put in place corrective
measures if the results are
lagging behind)
Effective and efficient
implementation of EU
legislation in the energy and
climate field
Assess progress to targets at
Member State level and
enable aggregation of data at
EU level
Better comparability of data
from different Member States
enabling an informed
evaluation
Increased certainty for
investors across all EU
Member States stimulating
economic growth as well as
research, innovation and
competitiveness of the EU
EU as a whole and Member
States themselves are better
informed on the actual
performance and it provides
ground for further action
If other, please explain: (up to 1000 characters)
12) Are you aware of overlaps or inconsistencies among the existing reporting obligations in
the same or different areas of the energy acquis? Please provide examples. (up to 1000
characters)
13)  a) Which of the current reporting obligations could in your opinion be streamlined[*] into
one integrated report and why? (up to 1500 characters)
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b) Are there reporting obligations that should be kept separate from the integrated report? (up
to 1500 characters)
c) Are there reporting obligations that could be repealed? (up to 1500 characters)
 
[*] By streamlining we understand the possibility to integrate planning and reporting obligations
resulting from different sectorial legislation by reducing possible duplication or gaps in the reporting
and planning obligations, thereby ensuring transparency, coherence, relevance, efficiency and
effectiveness of the reporting and planning. Furthermore planning and reporting cycles should be
harmonised to the extent possible.
14) Which elements/articles of the current reporting obligations in the field of renewable energy
do you consider indispensable and why? Please, if relevant, refer to specific articles of the
Renewable Energy Directive. (up to 1000 characters)
15) Which elements/articles of the current reporting obligations in the field of energy efficiency
do you consider indispensable and why? Please, if relevant, refer to specific articles of the
Energy Efficiency Directive, the Energy Performance of Buildings Directive and the legislation
on products. (up to 1000 characters)
16) Which elements/articles of the current reporting in the field of low-carbon development
strategies do you consider indispensable and why? (up to 1000 characters)
17) Which elements/articles of the current reporting obligations in the field of infrastructure
development (like for example TEN-E) do you consider indispensable and why? (up to 1000
characters)
18) Which other reporting obligations in the field of energy, including on security of supply
infrastructure and market integration, do you consider indispensable and why? (up to 1000
characters)
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19) Which elements of the current reporting obligations in the field of energy research and
innovation do you consider indispensable (investments in R&I, R&I funding programmes and
projects and direct funding to institutions) and which information is publicly available or
reported to other organisations? How can this reporting be made more consistent between
Member States and more updated so that it can support more transnational cooperation in this
field? (up to 1000 characters)
20) Can you provide qualitative or quantitative evidence on the administrative burden imposed
by existing reporting obligations on both Member States and other stakeholders? (up to 1000
characters, a possibility to upload further evidence is provided at the end of the questionnaire)
Future obligations
21) Do you consider future reporting obligations for Member States in the following key
elements of the Energy Union Strategy to be?
 
Very
important
Security of supply
Internal Energy Market
Energy infrastructure
Energy efficiency
Renewable energy
GHG emissions reduction
(decarbonisation)
Research, Innovation and
competitiveness
Less
important
Not
important
No
opinion
Important
D. Options for streamlining planning and reporting obligations
This part of the consultation seeks stakeholders' views on the options for the design of the planning
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This part of the consultation seeks stakeholders' views on the options for the design of the planning
and reporting obligations in the new governance system.
22) Do you agree that a comprehensive new legislative act covering both planning and
reporting obligations of policy areas related to the Energy Union including the 2030 Energy and
Climate framework would ensure consistency and reduce unnecessary administrative burden?
YES
NO
No Opinion
23) Do you think that non-legislative approaches (e.g. guidance to Member States) can assure
effective and efficient streamlining of planning and reporting obligations and would provide the
necessary certainty for investors?
YES
NO
No Opinion
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24) Concerning options to streamline planning and reporting obligations in the framework of
the governance of the Energy Union, how would "Non-binding guidance for both planning and
reporting obligations covering all Energy Union dimensions" influence the following
categories?
Considerable
Improvement
Coherence of
national plans
and reporting
formats among
all EU Member
States
Effective and
efficient
implementation
of EU
legislation in
the energy and
climate field
Achievement of
the EU energy
and climate
objectives
Possibility to
monitor the
performance
and trends (and
put in place
corrective
No
Change
Significant
deterioration
No
Opinion
Improvement
Deterioration
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corrective
measures if the
results are
lagging behind)
Increased
certainty for
investors
across all EU
Member States
stimulating
economic
growth as well
as research,
innovation and
competitiveness
of the EU
Better
implementation
of international
commitments
by the EU as a
whole and by
Member States
(e.g.
concerning the
reduction of
greenhouse
gas emissions)
The
Commission is
better enabled
to provide
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to provide
substantial and
useful advice
and ensure
uniform
application of
EU legislation
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25) Concerning options to streamline planning and reporting obligations in the framework of
the governance of the Energy Union, how would "Regulating planning and reporting
obligations in sectorial legislation as currently the case" influence the following categories?
Considerable
Improvement
Coherence of
national plans
and reporting
formats among
all EU Member
States
Effective and
efficient
implementation
of EU
legislation in
the energy and
climate field
Achievement of
the EU energy
and climate
objectives
Possibility to
monitor the
performance
and trends (and
put in place
corrective
measures if the
No
Change
Significant
deterioration
No
Opinion
Improvement
Deterioration
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measures if the
results are
lagging behind)
Increased
certainty for
investors
across all EU
Member States
stimulating
economic
growth as well
as research,
innovation and
competitiveness
of the EU
Better
implementation
of international
commitments
by the EU as a
whole and by
Member States
(e.g.
concerning the
reduction of
greenhouse
gas emissions)
The
Commission is
better enabled
to provide
substantial and
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substantial and
useful advice
and ensure
uniform
application of
EU legislation
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26) Concerning options to streamline planning and reporting obligations in the framework of
the governance of the Energy Union, how would "Regulating both planning and reporting
obligations by a new comprehensive legislative act covering all Energy Union dimensions"
influence the following categories?
Considerable
Improvement
Coherence of
national plans
and reporting
formats among
all EU Member
States
Effective and
efficient
implementation
of EU
legislation in
the energy and
climate field
Achievement of
the EU energy
and climate
objectives
Possibility to
monitor the
performance
and trends (and
put in place
corrective
No
Change
Significant
deterioration
No
Opinion
Improvement
Deterioration
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corrective
measures if the
results are
lagging behind)
Increased
certainty for
investors
across all EU
Member States
stimulating
economic
growth as well
as research,
innovation and
competitiveness
of the EU
Better
implementation
of international
commitments
by the EU as a
whole and by
Member States
(e.g.
concerning the
reduction of
greenhouse
gas emissions)
The
Commission is
better enabled
to provide
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to provide
substantial and
useful advice
and ensure
uniform
application of
EU legislation
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27) In your view, what should be the nature of the initiative to best streamline the planning and
reporting obligations in the framework of the governance of the Energy Union?
Non-binding guidance for both planning and reporting obligations covering all Energy Union
dimensions
Regulating planning and reporting obligations in sectorial legislation as currently the case
Regulating both planning and reporting obligations by a new comprehensive legislative act
covering all Energy Union dimensions
If other, please elaborate: (up to 1000 characters)
28) Please elaborate on the reasons justifying your choice in the previous question: (up to 1000
characters)
 
E. Options for the governance system of the Energy Union and its process
E.1 Scope and nature of the integrated national climate and energy plans
National plans should take a holistic approach and address the five dimensions of the Energy Union
in an integrated way recognising the interactions between different dimensions. The nation plans
should cover the period from 2021 to 2030 and build upon what each Member State should deliver in
relation to their policies for 2020 and also include a perspective until 2050. These national plans
should provide long term predictability and certainty for investment and ensure greater cooperation
and coherence among Member States' approaches on climate and energy policies.
29) Notwithstanding the fact that all five dimensions will be part of the National Energy and
Climate plans, which elements of the Energy Union Strategy should be given prominence?
Very
important
Security of supply
Internal Energy Market
Energy infrastructure
Energy efficiency
Renewable energy
Less
important
Not
important
No
opinion
Important
GHG emissions reduction
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GHG emissions reduction
(decarbonisation)
Research, Innovation and
competitiveness
30)   a) Building further on your replies to the sections devoted to the existing planning and
reporting obligations (questions 1-21), which of the areas/articles subject to current planning
obligations should be included in the integrated National Energy and Climate Plans? Please
explain. (up to 1500 characters)
b) Building further on your replies to the sections devoted to the existing planning and
reporting obligations (questions 1-21), which of the areas/articles subject to current reporting
obligations should also be included in the integrated National Energy and Climate Plans?
Please explain. (up to 1500 characters)
c) Are there current planning obligations that should continue to be treated separately? (up to
1500 characters)
31) What political process would be necessary to ensure the stability of the National Energy
and Climate Plans (e.g. approval by national governments, cross-party approval, approval by
national parliaments, or national legislative acts)? (up to 1000 characters)
 
32) What, in your opinion, would be the main factors that could justify an update of the National
Energy and Climate Plans in the period from 2021 to 2030 (e.g. energy market developments,
economic changes, evolving EU legislation, or collective progress made towards the Energy
Union objectives)? (up to 1000 characters)
E.2 Role of different institutions in the governance process
33) How relevant would you rate the role of different institutions in the development of
integrated National Energy and Climate Plans?
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Very
relevant
European Commission
European Parliament
European Council
Energy Council
Environment Council
National administration
National parliaments
National stakeholders
Neighbouring or other group of
Member States
Regional fora
Relevant
Less
relevant
Not
relevant
No
opinion
34) How relevant would you rate the role of different institutions in the monitoring of the
implementation of integrated National Energy and Climate Plans
Very
relevant
European Commission
European Parliament
European Council
Energy Council
Environment Council
National administration
National parliaments
National stakeholders
Less
relevant
Not
relevant
No
opinion
Relevant
Neighbouring or other group of
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Neighbouring or other group of
Member States
Regional fora
35) With respect to the National Energy and Climate Plans, what should be the role of the
European Commission in order to ensure the achievement of the Energy Union's objectives?
Very
relevant
Support to Member States in
developing national plans, notably by
providing templates and technical
support and disseminating best
practice
Review national plans and analyse
Member States' contributions
Issue policy recommendations,
notably in its annual State of the
Energy Union
Approve national plans
Propose measures on EU level in
view of delivering on the objectives
of the Energy Union
Less
relevant
Not
relevant
No
opinion
Relevant
E.3 Regional cooperation to establish, and peer review before finalisation of, integrated
climate and energy plans
36) In accordance with the conclusions of October 2014 and March 2015 European Councils,
the new governance system should facilitate the coordination of national energy policies and
foster regional cooperation. How important would you rate regional cooperation in the course
of integrated climate and energy plans?
 
Very
important
As part of their national integrated
plans Member States should
jointly develop regional
objectives, standards and
common coherent strategies on
Less
important
Not
important
No
opinion
Important
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common coherent strategies on
the relevant dimensions of the
Energy Union.
The national plans should
describe how they reflect regional
integration and cooperation on
the Energy Union domains.
Member States should consult
relevant other Member States on
national plans before their
submission.
The plans should provide clear
account of these consultations
and how they are incorporated in
the plans.
The Commission should guide
the process, and develop
appropriate fora for consultations
of draft plans and regional
cooperation where required.
37) Concerning consultations and mutual reviews of the integrated National Energy and
Climate Plans (meaning that plans or progress reports of one Member State being reviewed by
other Member States), how important would you rate the following options?
 
Very
important
Only consultations should
take place in the preparation
of the plans leading to the
draft plans
Mutual reviews should be
done on draft plans
Mutual reviews should be
also used for progress
reports assessing the
implementation of plans
Less
important
Not
important
No
opinion
Important
Mutual reviews should be of
 EFK, Alm.del - 2015-16 - Bilag 243: Høringssvar om planlægning og rapportering som en del af forvaltningssystemet for Energiunionen
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Mutual reviews should be of
voluntary nature for Member
States
Mutual reviews should be
mandatory for Member
States
A dedicated system of
mutual reviews should be
established including the
creation of adequate fora
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