Non-compliance of the 4th PCI List with EU Law and the Paris Agreement

The document contends that the 4th PCI list is legally and environmentally flawed, specifically regarding gas projects. It argues that the selection process failed to meet TEN-E Regulation standards for cost-benefit and sustainability assessments. Furthermore, it asserts that investing in natural gas infrastructure creates stranded asset risks and is incompatible with the 1.5°C warming limit of the Paris Agreement and the EU's own Green Deal and climate emergency declaration.

• The methodology used to adopt the 4th PCI list is non-compliant with the TEN-E Regulation, as cost-benefit analyses relied on non-monetised indicators, making it impossible to prove that project benefits exceed their costs.
• The sustainability assessments for gas projects in the 4th PCI list are flawed; ENTSO-G assigned positive sustainability benefits to every candidate project based on dubious assumptions, while ACER noted that none of the projects clearly contribute to climate policy goals.
• There is a systemic failure by project promoters to provide credible mandatory data; for the 32 gas PCIs in the final list, at least 20 failed to provide credible economic performance indicators and 10 failed to provide consistent CAPEX figures.
• Support for gas PCIs is incompatible with the Paris Agreement and the EU's 2050 decarbonisation target, as Commission modelling indicates that natural gas's share in the energy mix must fall to around 3% by 2050 in 1.5°C scenarios.
• Natural gas cannot be considered a 'bridge fuel' because methane leaks are consistently underestimated and the remaining carbon budget is insufficient to allow for new gas plant construction.
• Investing in new gas infrastructure creates a high risk of stranded assets and diverts public funds from climate-ambitious projects, as existing infrastructure is already sufficient for security of supply.
• The potential for alternative gases (such as renewable methane or e-gas) to replace natural gas is too low to justify the expansion of gas networks, with e-gas estimated to be only around 5% of the fuel mix by 2050.

APA

ClientEarth (2020). Non-compliance of the 4th PCI List with EU Law and the Paris Agreement. https://www.clientearth.org/media/of1pdfim/clientearth-non-compliance-with-the-4th-pci-list-ce-en.pdf

Chicago

ClientEarth. Non-compliance of the 4th PCI List with EU Law and the Paris Agreement. 2020. https://www.clientearth.org/media/of1pdfim/clientearth-non-compliance-with-the-4th-pci-list-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Non-compliance of the 4th PCI List with EU Law and the Paris Agreement |date=29 January 2020 |url=https://www.clientearth.org/media/of1pdfim/clientearth-non-compliance-with-the-4th-pci-list-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2020noncompliance, author = {{ClientEarth}}, title = {{Non-compliance of the 4th PCI List with EU Law and the Paris Agreement}}, publisher = {ClientEarth}, year = {2020}, month = jan, url = {https://www.clientearth.org/media/of1pdfim/clientearth-non-compliance-with-the-4th-pci-list-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }