Response to EC consultation on the reviewed GBER proposal

The revision of GBER should go hand in hand with the revision of the Guidelines on State aid for climate, environmental protection and energy (CEEAG) 2022 considering the new principles established under the European Green Deal (including the Energy System Integration Strategy and the Hydrogen Strategy) as well as the Industrial and Digital Strategies.

State aid has a crucial role to play when there are well-identified structural market failures, making market signals sufficient to achieve Green Deal objectives. The CEEAG should be the reference tool to define the framework allowing Member States’ support, while the GBER should remain complementary for specific projects.

Proposal for key messages:

• Eurelectric welcomes the GBER reviewed proposal put forward by the European Commission. Eurelectric is committed to leading a cost-effective energy transition. GBER plays a crucial role in supporting electrification, which is key to achieving carbon neutrality and should be the first choice for the EU to meet the 2030 and 2050 objectives.

• Moreover, Eurelectric also welcomes the increased notification thresholds for certain types of projects (see below) and the inclusion of a dedicated category for electric vehicle charging infrastructure.

• Furthermore, Eurelectric highlights the growing importance of all types of storage, stand-alone and those combined with renewable power plants, in contributing to decarbonisation in terms of integration of renewable sources and avoiding curtailment of renewable energy.

• The GBER review should take into consideration and seek coherence with the ongoing review and development of other EU initiatives under the scope of the Fit for 55 Package and the upcoming Hydrogen and Decarbonised gas market package. In this context, the European Commission should ensure consistency in terms of terminology and legislative acquis.

• GBER should take into account the different starting points of Member States and their regions in the decarbonisation process.

• The European Commission should clarify some of the terms and concepts included in the GBER to ensure a better understanding and implementation of the text (see detailed comments below).
• Lastly, Eurelectric welcomes any provision aiming to streamline, rationalise and accelerate permitting procedures (also in light of the CEEAG), which would be tangible and effective immediately, both for new and existing in need of modernisation. In this regard, Eurelectric supports the European Commission’s Toolbox on Energy prices which recommends accelerating permitting procedures and looking at issuing an EU Guidance document on Permitting in 2022.