The 2^nd of august marks the deadline for submitting feedback to the ongoing Consultation of the published Guidelines on State aid for climate, environmental protection and energy (CEEAG). While the published proposal is an important step on the path to delivering on the ambitions set in the European Green Deal, important changes to the draft are necessary to safeguard the climate impact of the CEEAG Guidelines.

Bellona Europa welcomes the ongoing efforts by the European Commission, and the invitation to provide views, feedback and recommendations on the published proposal. Bellona Europa’s feedback can be found in full here, a summary below outline the main recommendations sent to the European Commission by Bellona Europa:

1. As a general remark, we recommend that the EU Sustainable Finance Taxonomy Technical Screening Criteria are incorporated into the proposal and used to determine to what extent investments are sustainable and can be eligible for state aid under the CEEAG.
2. Undefined decarbonized gases and fuels cause distortive effects on market competition, it is therefore our recommendation that a definition as well as a robust and transparent accounting is included in the CEEAG – and indeed across EU legislation.
3. It is our strong recommendation that the current text referring to “fit for use” with “hydrogen, and renewable gases or fuels of non-biological origin” is amended to subject any investment into natural gas infrastructure to two of the three criteria outlined in point 339c): 1) state why the project does not create a lock-in effect for the use of fossil-gas, and 2) how the investment contributes to achieving the Union’s 2030 and 2050 climate target.
4. We see the current proposal as including exemptions for sustainability criteria contributing to lock-in effects, it is therefore our recommendations that:
5. As non-fossil based alternatives (such as heat pumps) exist on the market and can be widely deployed, state aid should not be given to the deployment of gas-fired solution which would lock in fossil fuel for the upcoming decades.
6. Wherever more sustainable alternative exist (e.g. electric vehicles), natural gas vehicles should be excluded from receiving state aid, regardless of the blending requirements.
7. It is our recommendation that the current proposal for the CEEAG is amended to ensure eligibility of multiple modalities for CO2 transport, also ship, barge, truck and rail, as opposed to today’s proposal which only covers CO2 transport via pipeline.
8. It is our strong recommendation that safeguards ensuring that investment into CCU of fossil CO2 can only be eligible as state aid if the CO2’s permanent storage following usage is ensured. This can be done either through specification in the definition of CCU under section 2.4 point (14) – or specification throughout the document.

Find our feedback here:

Bellona Europa feedback CEEAG consultation 28072021