In order to meet the goals under the Green Deal, the competition rulebook of the European Commission must be modernised and adapted so that investment into the green energy transition is facilitated and granted with greater flexibility. The Guidelines on State aid for climate, environmental protection, and energy (CEEAG) are one of the tools at our disposal to achieve this. It is crucial that these guidelines are in line with European Directives, especially the RED II and upcoming RED III, and the overall objectives of the Green Deal. The new rules must allow governments to support companies and societies that are decarbonising and moving towards a more sustainable future, and the guidance must be clear and effective in supporting green investment. 

With the 2030 target of -55% GHG emissions less than 9 years away, we need to adopt and implement the most effective and robust policy instruments. Aligning our climate and energy targets with the Paris Agreement is a legal and moral obligation and battling to keep our planet inhabitable for the generations to come requires rapid action, putting forward ambitious policies and legal initiatives. While EREF supports the overall ambition of the Commission to enlarge the scope of the guidelines to new areas and technologies and to allow greater flexibility of the compatibility rules, there are several recommendations we would like to make in order to achieve these goals without frustrating the ambitions of the Green Deal.

While EREF understands the Commission’s reasoning behind creating the category of aid “for the reduction and removal of greenhouse gas emissions including through support of renewable energy” in order to make the guidelines “future proof” and flexible for possible new technologies over the next few years, we think it is vitally important for there to be a separate aid category solely for renewables. This would recognise their crucial role in the energy transition and allow for more flexible support to achieve the rapid growth of renewables. Therefore, EREF would suggest keeping the aid category “for the reduction and removal of greenhouse gas emissions”, in order to provide flexibility for new technologies that may emerge on to the market. However, a separate category of aid should be added specifically for support to renewable energy. Within this new chapter, special rules should apply in order to promote the rapid deployment of renewables.

The following paragraphs in attached document contain EREF’s suggestions for the category of aid supporting renewable energy.

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