Consultation on the draft Communication on State aid for important projects of common European interest

ClientEarth argues that State aid for IPCEIs must be strictly conditioned on compliance with EU environmental law and the 'do no harm' principle. The organization specifically advocates for the exclusion of fossil fuel projects and non-renewable hydrogen from aid eligibility, while calling for increased transparency in the Commission's State aid decisional process and the use of competitive procedures for selecting beneficiaries.

• The organization strongly recommends that the Commission exclude all fossil fuel projects from the scope of the IPCEI Communication, including those listed as Projects of Common Interest (PCI) under the TEN-E Regulation, to avoid "stranded asset risk" and align with the target to reduce greenhouse gas emissions by at least 55% by 2030.
• Regarding the Hydrogen IPCEI, ClientEarth urges the Commission to only allow aid for renewable hydrogen. It argues that supporting fossil gas or low-carbon hydrogen would be a mistake due to the risk of "gas lock-in" and the potential for renewable hydrogen to be more cost-effective by 2030.
• ClientEarth proposes that if the Commission allows support for non-renewable hydrogen, it must be subject to strict cumulative requirements, including the mandatory use of the best available CCS technologies and a methane leakage limit of 0.2% for upstream emissions by the start of 2025.
• The document suggests that the 'common European interest' eligibility criterion should explicitly include a project's impact on the environment and public health, and that net positive environmental effects should qualify as 'spillover effects'.
• ClientEarth calls for significantly higher transparency in State aid decisions, proposing that the Commission publish notification forms, procedural step dates, and non-confidential versions of decisions in a timely manner.
• The organization argues that the selection of aid beneficiaries should generally be conducted through "competitive, transparent and non-discriminatory" procedures rather than treating such procedures as merely a positive indicator.

APA

ClientEarth (2021). Consultation on the draft Communication on State aid for important projects of common European interest. https://www.clientearth.org/media/befckj1n/clientearth-response-to-consultation-on-ipcei-communication.pdf

Chicago

ClientEarth. Consultation on the draft Communication on State aid for important projects of common European interest. 2021. https://www.clientearth.org/media/befckj1n/clientearth-response-to-consultation-on-ipcei-communication.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=Consultation on the draft Communication on State aid for important projects of common European interest |date=April 2021 |url=https://www.clientearth.org/media/befckj1n/clientearth-response-to-consultation-on-ipcei-communication.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2021consultation, author = {{ClientEarth}}, title = {{Consultation on the draft Communication on State aid for important projects of common European interest}}, publisher = {ClientEarth}, year = {2021}, month = apr, url = {https://www.clientearth.org/media/befckj1n/clientearth-response-to-consultation-on-ipcei-communication.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }