Deliberate opinion of the Environmental Authority on the third multiannual energy planning (2025-2030, 2031-2035) for continental metropolitan France

France aims to mitigate climate change by achieving carbon neutrality by 2050, halving its final energy consumption compared with 2012, and reducing the country's carbon footprint. The multi-annual energy planning (PPE) and its appendix dedicated to transport, the clean mobility development strategy, set out priorities for action in managing all forms of energy in order to achieve these objectives. Its third version (PPE3), for the periods 2025-2030 and 2031-2035, is presented at the end of almost four years of in-depth preparation and consultation. It comes at a time when most of the targets set by the previous PPE (PPE2, 2019-2023 and 2024-2028) for reducing greenhouse gas (GHG) emissions have been met, except in the transport sector, but when natural carbon sinks have been degraded (droughts, forest fires, changes in land use, etc.) and targets for reducing energy consumption have not been met. For the Environmental authority (Ae), the main environmental challenges of the PPE are to reduce greenhouse gas emissions, primary and final energy consumption and the use of other resources (materials, water, space) mobilized directly or indirectly for energy needs, both in France and in the countries of origin of energy imports. The Ae makes a number of recommendations to improve the strategic environmental assessment of the PPE3, in particular concerning the analysis of the articulation of the PPE3 with other relevant plans and programs (including the national low-carbon strategy), to integrate air transport, to assess the outlook for water resource availability and the environmental impact of imports of fuels and metals required for energy production and use. It also recommends strengthening the justification of energy choices (infrastructures in all sectors, facilities, industries) with significant environmental impacts, in particular electricity interconnections. It also recommends that the PPE3 be supplemented or extended, and in particular: - lowering the 2030 target for final energy consumption by at least 12%, in order to meet European 'fit for 55' objectives, - reinforcing targets and improving monitoring of the efficiency of the energy system converting primary energy into final energy, and clarifying the consequences of choices made between primary energy sources, - reconsidering the hierarchy of biomass uses in line with the roadmap for the 2030 agenda, and supplement the actions of the PPE3 with provisions aimed at reducing soil artificialization and biodiversity erosion, as well as protecting and restoring carbon sinks, - developing mobility measures to improve air quality, to reduce health impacts and energy consumption, - raising digital ambitions, - presenting regionalised targets for energy production from renewable resources, - clarifying the consequences of a possible reduction in the availability of nuclear reactors, with the PPE3 projecting their maximum uninterrupted mobilization until 2035. All the Ae's observations and recommendations are set out in the detailed opinion document