Stanovisko do veřejné konzultace EU k veřejné podpoře v oblasti energeticko-environmentální

Response to response to the draft Commission Guidelines on Environmental and Energy Aid 2014–2020 (EEAG)  .

General view

The Confederation of Industry of the Czech Republic (CICZ) welcomes the overall systematic approach with which the second EEAG draft has been prepared, namely the idea of providing right, predictable, even and non-discriminatory framework for energy and environment support measures. In this sense, CICZ strongly supports the holistic view that with support schemes the EU should at all costs avoid or minimize distortions of competition – internally among the EU states with their different entry conditions, technologically and sectorial-wise – with the ultimate aim. We truly believe that the current situation, when the existing variety of support schemes or levies and their general benevolence fundamentally jeopardizes the common market as the essential pillar of the EU and causes the fall of EU competitiveness, deserve an immediate action which should not be delayed any further.

Key reservations

Although we acknowledge that the second draft has taken in significant, positive changes we still see in the text some problems which might potentially peril the above mentioned certainty in the fundamental field for European competitiveness. Those include:

-          Clarity of definitions

• • “generation adequacy” and “generation adequacy standards” must be unequivocally better defined reflecting current, expert discussions on the EU level
    
    

  • „genuinely competitive bidding process “  should be more specifically defined in order to avoid misunderstandings and incoherence with other EU legislation
    
    
  • “minor changes or improvements” in definition of eco-innovation needs to be specified to prevent cross-subsidy effects
    
    
  • “deployed” and “less deployed technology” terms should be defined in a greater detail to avoid purpose-built interpretations
    
    
  • “state of the art” ought to have either a more precise definition or interpretation linked to EU specific norms
    
    

-          Correlation of scope and interpretations with interfering EU legislation

• • in areas where EEAG (namely levies, exceptions and eligibility) interacts with interpretations stemming from the Energy Tax Directive, the first (EEAG) should be given unequivocal precedence
    
    
  • in areas where EEAG (namely levies, exceptions and eligibility) interacts with interpretations stemming from the EU Emission Trading System, the later (EU ETS) should be given unequivocal precedence
    
    
  • in areas where EEAG (namely appropriateness and proportionality) interacts with interpretations stemming from the legislation accompanying the Common Strategic Framework/ESI funds, the later should be given unequivocal precedence  
    
    

-          Lack of cost efficiency parameter in renewable energies’ promotion

• • Whilst all other sources of energy have their cost efficiency/effectiveness defined in respective legislation, the renewables are to large extent lacking such parameters. Hence the EEAG should introduce such a parameter to avoid disruptions on the energy markets, ensure more technological neutrality and support market-oriented measures.