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Response to Consultation on Community Guidelines on State Aid for Environmental Protection

EUROSOLAR and the World Council for Renewable Energy (WCRE) presented eight essential requirements for the guidelines on support instruments for environmental protection, released for consultation by the Directorate-General for Competition of the European Commission.

Dear Director General,

Two organizations issue this submission document. EUROSOLAR represents some 4000 members across 13 countries, and is active since 1988.The WORLD COUNCIL FOR RENEWABLE ENERGY is its global network of international experts and policy leaders, and operates since 2001.

It is our considered view that the proposed rules risk destabilizing the resilience and prosperity of the European Community: they do not live up to global or local standards of best practice in environmental protection, financial stability and economic innovation. To improve any guidelines we present the following eight essential requirements.

  1. Feed-in-tariffs for renewable energy must continue as the most effective and cost efficient instruments of climate protection, energy security and economic prosperity.
  2. Member states should be allowed to decide the most appropriate support instrument, depending on the technology, size and national market conditions, unless EU-wide feed-in tariffs were to be instated.
  3. Support schemes should aim at paths to 100% renewable energy, already achieved in several regions, and set a 2040 outside target across all of Europe.
  4. There should be no upper limit in the allowable aid to energy efficiency projects.
  5. Demand management measures should be eligible for aid.
  6. Combined renewable/fossil firing installations are not to be eligible for aid.
  7. Storage systems and intelligent networks must be supported as essential European infrastructure.
  8. Fossil fuel and nuclear projects should be avoided and must be excluded from aid and other forms of subsidy.

Thank you for the opportunity to submit this important input, at this critical stage in Europe's development.

With my best regards

Professor Peter Droege
General Chairman, WCRE / President, EUROSOLAR

Bonn/Berlin, 14 February 2014