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This is ClienthEarth’s reply to the European Commission’s Consultation on the Revision State Aid General Block Exemption Regulation (GBER)
The GBER should be aligned with the new laws and policies that are driving the Union’s action, notably the European Green Deal and its various implementing policies. This implies that only aid measures to activities complying with the Union’s decarbonisation objectives should be exempted from notification to the Commission. On the contrary, aid to high-efficient cogeneration, district heating or cooling and energy infrastructure relying on fossil fuels or unsustainable renewable energy sources (such as forest-biomass and small hydropower) should be found incompatible with the internal market or at least, be notified to the Commission in order to assess their compliance with EU environmental law and Green Deal objectives.
Moreover, new categories of aid should be included in the GBER in order to support the green transition, especially aid for energy storage and sustainable batteries, aid for zero exhaust emissions vehicles and charging infrastructure, as well as dedicated support for energy communities. Hydrogen should not be included as a new aid category in the GBER due to the lack of state aid experience with this innovative energy carrier.
Given the necessity of a fast-paced green transition, the GBER needs to be future-proof. This implies both immediately addressing any current flaws and anticipating the development of upcoming technologies, including their market potential and their impact on the Union’s energy systems and environmental and climate protection objectives. It means giving legal certainty to all stakeholders that the design of aid measures will fully support the green transition and be exempted from notification to the Commission only when it is right.