IOGP response to public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG)

This document provides IOGP’s input to the EU public consultation on the revised Climate, Energy and Environmental Aid Guidelines (CEEAG).

The Commission published for consultation the draft revised Guidelines on State aid for environmental protection and energy 2014-2020. The two main drivers of the revision are an enlargement of the scope of the Guidelines to new areas and all technologies that can deliver the Green Deal and a flexibilization of compatibility rules.

• IOGP believes that the CEEAG should be aimed at allowing for European industries to deliver the scale of projects required to meet the EU’s climate objectives, while, as a priority, maintaining competitiveness, keeping existing and creating new jobs
• The future contributions of carbon capture and utilisation or storage (CCU and CCS) and low-carbon hydrogen from natural gas with CCS to the achievement of the EU’s energy and climate objectives should be reflected in the State aid framework
• The CEEAG should allow support for reducing emissions from the production of oil and gas across the EU. Continued oil and gas production in the EU will be required during the transition and will provide the basis for the development of many necessary low-carbon technologies and their supply chains

• General remarks
• Ensuring that the definitions of CCS and CCU cover all relevant sources of CO2
• Including all CO2 transport modes in the definitions for energy infrastructure
• Including all relevant low-carbon gas technologies and solutions in the definitions of energy infrastructure
• Eligibility for PCI and PMI status according to the definitions of energy infrastructure
• Adequately covering natural gas-based technologies, ensuring legal certainty and reflecting regional conditions in the definitions of “cogeneration”, “high-efficiency cogeneration” and “energy-efficient district heating and cooling”
• Facilitating the coal-to-gas shift in the context of GHG emission reduction
• Facilitating necessary investments in gas infrastructure
• Anticipating the electrification of new sectors in the context of reductions from electricity levies