Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’

Ember submitted comments on August 2, 2021, regarding the European Commission's draft 'Guidelines on State aid for climate, environmental protection and energy 2022' (CEEAG). The document argues for a nuanced approach to state aid for coal mine methane (CMM) abatement, distinguishing between active and abandoned mines to ensure environmental benefits are achieved without extending the operational life of coal mines.

• Ember identifies three categories of coal mine methane (CMM) projects with varying suitability for state aid: Drained CMM from active mines, Ventilation Air Methane (VAM) from active mines, and Abandoned Mine Methane (AMM).
• Drained CMM projects, which extract high-concentration methane (10-60%) from operational mines, are deemed unsuitable for state aid because they typically have good economics and support could risk increasing a mine's operational lifetime.
• VAM mitigation projects, which destroy low-concentration methane (typically around 0.5%) using thermal or catalytic oxidisers, are supported for state aid. Ember argues these projects have no obvious revenue stream outside of incentives and would have minimal effect on coal mine profitability.
• Abandoned Mine Methane (AMM) projects are considered highly suitable for state aid because they provide enormous environmental benefits and do not risk extending the operational life of a mine since the mine is already closed.
• Ember proposes specific additions to Annex 2 of the CEEAG to include the costs of sealing coal mines and the construction and operation of methane extraction systems, as well as costs for flaring when no economically viable utilization exists.

APA

Smirnov, A., & Kasprzak, M. (2021). Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’. Ember. https://ember-energy.org/app/uploads/2021/08/CEEAG-Comments-Ember.pdf

Chicago

Smirnov, Anatoli, and Małgorzata Kasprzak. Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’. Ember, 2021. https://ember-energy.org/app/uploads/2021/08/CEEAG-Comments-Ember.pdf.

Wikipedia

{{cite press release |last1=Smirnov |first1=Anatoli |last2=Kasprzak |first2=Małgorzata |title=Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’ |publisher=Ember |date=2 August 2021 |url=https://ember-energy.org/app/uploads/2021/08/CEEAG-Comments-Ember.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@misc{smirnov2021comments, author = {Smirnov, Anatoli and Kasprzak, Małgorzata}, title = {{Comments to the ‘Public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)’}}, publisher = {Ember}, year = {2021}, month = aug, url = {https://ember-energy.org/app/uploads/2021/08/CEEAG-Comments-Ember.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }