Introduction With this long gestation period, the Western Balkans coun­tries have few excuses compared to the EU for not ade­quately involving civil society in the process. Indeed some countries such as Montenegro and Kosovo have included civil society representatives in their NECP working groups, while North Macedonia is the only country to have publicly consulted its draft document so far. The Energy Community Secretariat is also one of the most active players in the new Initiative to support the clean en­ergy transition in coal regions in the Western Balkans and Ukraine, launched in December 2020, with a Secretariat op­erating since February this year. 33 The Platform is, among others, supported by the European Commission and it aims to support the development of national plans which will be directed toward reforms of the energy system and decrease of coal use as well as assisting with knowledge exchange, technical assistance, and financial assistance. One of the main contributors to CO 2 emissions in the West­ern Balkans are coal power plants. Emissions from electrici­ty and heat production amount to nearly 65 per cent of to­tal emissions from fossil fuels in the WB6 and in 2020, the carbon intensity of electricity production in the region was more than three times the average in the EU-27. 34 These two processes – NECP development and the Coal Re­gions Initiative – present an opportunity for the Western Balkans to decrease these emissions and plan orderly and fair transitions away from coal and other fossil fuels. But for some countries it is already very late. Since 1 January 2018 the Large Combustion Plants(LCP) Di­rective has been in force. The Directive regulates the levels of sulphur dioxide(SO2), nitrogen oxides(NOx) and dust emissions from existing power plants, requiring significant investments into pollution control or closure of plants. Around 1,000 MW of thermal capacities need to be shut down by the end of 2023 under the Directive. 35 Although all of the Western Balkan countries with coal plants are fla­grantly breaching the LCP Directive at the moment, 36 it will eventually – together with the sheer age of most of the plants – bring about the end of the coal era in the region. Renewables and energy savings can cover the gap that will be left by coal, but as of July 2020 solar and wind made up less than three per cent of the generation mix in Western Balkan countries. 37 Renewable energy in heating 33 European Commission, Initiative for coal regions in transition in the Western Balkans and Ukraine, February 2021. 34 Energy Community Secretariat, Secretariat, WB6 Energy Transition Tracker. 35 Directive 2001/80/EC of the European Parliament and of the Council of 23 October 2001 on the limitation of emissions of certain pollut­ants into the air from large combustion plants, Official Journal L 309, 27 November 2001, 1-30(amended). 36 CEE Bankwatch Network, Comply or Close. 37 Energy Community Secretariat, Powering the Energy Transition: ­Secretariat launches Western Balkan 6 Energy Transition Tracker, 16 July 2020. also­­mainly consists of inefficient wood burning and little progress has been made in transport. The situation is slow­ly beginning to change in the power sector, partly due to the falling prices of solar and wind, and partly due to the gradual introduction of market-based support schemes in some countries. THE EUROPEAN GREEN DEAL AND THE WESTERN BALKANS The European Green Deal also lays the ground for the Green Agenda for the Western Balkans, on the basis that ‘[t]he ecological transition for Europe can only be fully ef­fective if the EU’s immediate neighbourhood also takes ef­fective action’. 38 In October 2020 the European Commis­sion therefore published Guidelines for the implementation of the Green Agenda for the Western Balkans 39 as well as an Economic and Investment Plan for the Western Balkans 40 worth EUR 9 billion in Instrument for Pre-Accession(IPA III) funding for the period from 2021 to 2027. The core areas for investments are sustainable transporta­tion, clean energy, the environment and climate, a digital future, human capital, and the private sector. Also, a new Western Balkans Guarantee facility aims to raise additional private sector funds for investments of up to EUR 20 bil­lion. In November 2020, Western Balkan leaders committed to implement the Green Agenda via the Sofia Declaration, 41 including a pledge to implement the EU Climate Law, i.e. to phase out fossil fuels by 2050. Unfortunately, so far the Green Agenda process has been far from inclusive. Environmental civil society groups did not have access to any draft of either the Guidelines or the Eco­nomic and Investment Plan before they were published. Af­ter this, the European Commission and the Regional Coop­eration Council(RCC), who have been engaged to help im­plement the process, pledged to do better and invited non-governmental organisation(NGO) representatives to speak at several online events, as well as setting up an NGO Forum. However, as 2021 wore on, it was less and less clear why it was taking so long for the RCC to draft an Action Plan for the implementation of the Green Agenda. 38 European Commission, Communication from the Commission – The European Green Deal. 39 European Commission, Guidelines for the Implementation of the Green Agenda for the Western Balkans Accompanying the Com­munication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions An Economic and Investment Plan for the Western Balkans, 6 October 2020. 40 European Commission, Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – An Economic and Investment Plan for the Western Balkans, 6 October 2020. 41 Sofia Declaration on the Green Agenda for the Western Balkans, Berlin Process, 10 November 2020. 13