Europex recognises the need to review the EEAG guidelines in the context of the European Green Deal initiatives and the objective of achieving climate neutrality by 2050. The revised guidelines should build on the clear market design framework as set out in the Clean Energy Package and take particular care to avoid undue distortions of competition in the Internal Energy Market. Despite the high fixed cost structure of renewables as well as the need for predictable revenue streams, market-based remuneration of renewables in the energy market offers the most cost-efficient way of achieving decarbonisation, especially as renewables are deployed at scale. Distortive aid, in particular operating aid, risks undermining the development of the energy market. Deviations from the ‘energy-only’ market should be seen as an exception and all types of aid should be minimised. Having a clear target model and a phase-out schedule for support is vital in order to minimise distortions of competition.
Please see our attached response for further details.