Erhvervsudvalget 2019-20
ERU Alm.del Bilag 50
Offentligt
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NOTAT
30. October 2019
DocumentNumber
Jen-dep
Overskrift
The Danish Government’s response to the evaluation of the Commu-
nication on Important Projects of Common European Interest (IPCEI)
The Danish Government welcomes the opportunity to comment on the
evaluation on the Communication on Important Projects of Common Eu-
ropean Interest (IPCEI)
The Danish Government finds that the Communication on IPCEI (2014/C
188/02) has contributed in a positive way to provide helpful guidelines for
member states when preparing schemes for an approval process that is as
smooth and quick as possible, while ensuring a strict use and application of
IPCEIs. When large cross border projects with clear common European
added value entail so big risks that private investors are not willing to take
them alone or considered unprofitable it is important that the states in-
volved have the opportunity to grant state aid. However, such state aid
should stimulate additional private investments and not distort competition
in a disproportional way.
When dealing with big projects and potentially large amounts of state aid
there is a potential for substantial distortion of the competition on the inter-
nal market.
Therefore, the Danish Government finds it important that state aid for IP-
CEIs in particular is assessed thoroughly by the Commission in a manner
where the balance test is carried out on a solid and well-informed founda-
tion of information. In addition the Commission should continue to apply
the market-based principles in the communication, including monitoring
the ex-post changes in the behavior as well as general market changes re-
sulting from the state aid.
It is the Danish opinion that an IPCEIs within strategic value chains that
are granted state aid should be open for participation of interested under-
takings from all EU Member states.
ERU, Alm.del - 2019-20 - Bilag 50: Notat, høringssvar samt spørgeskema vedr. vigtige projekter af fælleseuropæisk interesse (IPCEI), fra erhvervsministeren
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Currently there is no clear procedure for how Member States can coordi-
nate and cooperate on IPCEIs in advance of the state aid assessment. When
dealing with strategic value chain IPCEIs we suggest that all Member
States are provided with project descriptions well in advance before a for-
mal state aid notification is sent to the Commission. We suggest a formal-
ized process where Member States and other stakeholders are given a pe-
riod where they can submit comments on the project or request to join the
project. We need to ensure a transparent and inclusive process that allows
for stakeholders and companies of all sizes to participate and contribute in
order to ensure the best possible projects.
In general, we believe that IPCEIs should be allowed to pursue other ob-
jectives beyond climate and environmental objectives. However, strategic
value chain IPCEIs should contribute in a clear and identifiable manner to
one of the EU’s
climate objectives. The 2014 communication already states
that projects must contribute in a concrete, clear and identifiable manner to
one of more EU objectives, including but not limited to sustainable growth
and the 2030 framework for climate and energy policies. We suggest put-
ting higher weight on this criterion for projects to contribute to a climate
neutral economy in the EU by 2050 at the latest in the Commissions’ as-
sessment of strategic value chain IPCEIs by giving it precedence over other
EU objectives, i.e. exalting the criterion.
Please find enclosed the Danish response to the questionnaire on Evalua-
tion of the Communication on Important Projects of Common European
Interest (IPCEI) in the context of the fitness check on State aid policy.
Please also find two Danish non-papers with suggestions to a greener and
more transparent use of strategic value chain IPCEI and the governance
structure for strategic value chains. We stand ready to further elaborate on
our ideas or answer any follow-up questions you may have.
Finally, we refer to the Danish Government’s response of 8
th
August on the
general evaluation of the state aid rules also and in particular, the section
on the organisation and financing of transport infrastructure projects
(“Transport
infrastructure and the implementation of the Trans-European
transport network (TEN-T)”).