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The document argues that the restructuring plan for Complexul Energetic Oltenia (CEO) fails to restore long-term viability because it maintains unviable lignite assets and invests in fossil gas, which are viewed as stranded assets. The authors contend that the plan contradicts the European Green Deal and the Paris Agreement, and that the proposed State aid—including €241.4 million for 2020 CO2 allowances—violates EU law and the 'do no harm' principle. They highlight a lack of real own contribution from CEO and the absence of meaningful compensatory measures, suggesting instead a full lignite phase-out by 2030.

ClientEarth argues that Greece's proposed extension of its flexibility and interruptibility schemes is unjustified because a recent resource adequacy assessment indicates no supply concerns for 2020-2030. The organization contends that these schemes act as a disincentive for Greece to implement the 'Target Model' market reforms and may violate the recast Electricity Market Regulation (EMR), which positions such measures as a 'last resort'. ClientEarth highlights that the interruptibility scheme disproportionately impacts solar power producers through its levy formula and notes ongoing legal challenges against both schemes in the Greek Council of State.

ClientEarth argues that the proposed reductions in the capacity mechanism levy for energy-intensive users (EIUs) in Poland would undermine the security of supply objectives of the capacity market by dis-incentivising demand-side response. The organisation highlights that the scheme's costs would be shifted to households and non-EIU consumers, potentially affecting public acceptance. ClientEarth suggests that a fixed annual compensation would be a more adequate form of aid to maintain incentives for shifting consumption away from peak hours. The document also questions the expansion of the beneficiary pool from 52 to 300-350 EIUs and recommends that the Commission reject the scheme to avoid distorting the energy market.

ClientEarth challenges the proposed Greek capacity mechanism (CM), asserting that the Greek authorities have failed to implement necessary market reforms and have provided a flawed generation adequacy assessment. The document argues that the CM's design discriminates against demand side response (DSR) and renewable energy in favor of lignite-fired plants, potentially using a 'grandfathering' clause to bypass EU emission standards. ClientEarth calls for a formal State aid investigation to ensure the scheme does not provide unjustified subsidies to fossil fuel incumbents.