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The IPCEI Communication should be adapted to address the twin-transition to a green and digital economy. The implementation of the “do no significant harm” principle, newly introduced in the draft communication, is key to prevent public financial support to polluting and unsustainable activities. A thorough compliance check of the supported economic activities with all relevant EU environmental law should also ensure that State aid measures do not adversely harm environmental protection.
In addition to these two paramount principles, a project should only qualify as an Important Project of Common European Interest and be eligible for State aid if its impact on the environment and the climate is taken into account when assessing the project’s contribution to the EU objectives. The spillover effects that aid beneficiaries must achieve with their project may also consist of positive environmental benefits, alone or with other socio-economic benefits.
Moreover, this implies that State aid to projects of the hydrogen IPCEI can only be granted for renewable hydrogen. In the regrettable event that State aid to non-renewable hydrogen would also be allowed, it should be subject to the strict cumulative requirements proposed by ClientEarth in order to limit as much as possible the negative climate and economic consequences of a further gas lock-in.