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This is ClientEarth’s reply to the European Commission’s Consultation on the draft State aid Guidelines in the Agriculture and Forestry sectors and in rural areas and the Agriculture Block Exemption Regulation (ABER).
As a general principle, aid measures by Member States, whether notified under the Guidelines or exempted from notification under the ABER, must be consistent and actively contribute to reaching the EU Green Deal’s objectives and the Union’s climate targets for 2030 and 2050. As guardian of the treaties, it is on the Commission to verify this consistency when performing a broader compliance check with relevant Union law, which should systematically include environmental law and principles.
ClientEarth provides targeted feedback to the Commission with respect to public support given to both the agricultural and forestry sectors. On agricultural activities, we in particular address aid for carbon farming, for the production of biofuels for self-consumption by farmers, for land irrigation and animal welfare. For the support to forestry activities, we notably provide observations with respect to afforestation and the creation of woodland, investments in infrastructure related to the development, modernisation or adaptation of forestry as well as investments in mobilising and marketing forest products.