Europaudvalget 2021-22
EUU Alm.del Bilag 391
Offentligt
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NOTE
14 March 2022
tuobac
Danish response to the Commission’s
draft Temporary Crisis
Framework for State Aid measures to support the economy following
Russia’s military aggression against Ukraine
The Danish government appreciates the opportunity to comment on the
European Commission’s draft
Temporary Crisis Framework for State Aid
measures to support the economy following Russia’s military aggression
against Ukraine
(hereafter “TCF”).
1. General comments
The Danish government welcomes a common European approach
regarding the assessment of the economic effects following the invasion of
Ukraine by Russia and the following economic sanctions adopted in this
context. The Danish government agrees that a coordinated economic
response of Member States and EU institutions is crucial to mitigate the
negative repercussions on the EU economy.
In this coordinated response, it is crucial for the Danish government to
support the undertakings that are
most affected
by the situation in Ukraine.
This priority is in line with point 30 of
the Commission’s draft TCF, where
it is stated that state aid measures notified and assessed under the TCF are
intended to support undertakings active in the EU that are affected by the
Russian military aggression and consequences of the economic sanctions
taken.
Furthermore, it is of great importance to the Danish government that the
temporary state aid measures in the draft TCF are limited to the
undertakings that are
most affected
by the situation in Ukraine.
2. Specific comments related to the safeguards in Section 2.1 and
2.2
The Danish government accepts the possibility to ensure liquidity support
in form of guarantees (section 2.1) and subsidised loans (section 2.2) as
public guarantees on loans and subsidised interest rates both for a limited
period and limited loan amount can be an appropriate, necessary and
targeted solution during the current circumstances.
 EUU, Alm.del - 2021-22 - Bilag 391: Notat og høringssvar vedr. Kommissionens høring om midlertidige kriserammebestemmelser for statsstøtte ifm. Ruslands invasion af Ukraine
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While Section 2.3 of the TCF
distinguishes between “businesses” and
“energy-intensive businesses” this is not the case with Section 2.1 and 2.2.
This entails that the scope of Section 2.1 and 2.2 seem to be broader than
Section 2.3. The Danish government politely urges the Commission to
review the wording and scope of Section 2.1 and 2.2 again in the light of
the above.
3. Specific comments related to Section 2.3
The Commission proposes that the overall aid per undertaking in this
section should (as a starting point) not exceed 30% of the eligible costs up
to a maximum of EUR 2 million at any given point in cases where the
beneficiary is
not
an “energy intensive business”.
The Danish government
also agrees that in certain situations related to
“energy-intensive
businesses” further aid may be necessary to ensure the continuation of
economic activity within point 40, (a)-(d), in the TCF. In these cases, where
the beneficiary is an “energy-intensive business”
the overall aid may not
exceed EUR 25 million per undertaking at any given point in time.
It is important for the Danish government that Section 2.3 is limited to the
undertakings that are
most affected
by the situation in Ukraine.
Undertakings who want to adapt to new markets will therefore only be able
to receive liquidity support under Section 2.1 or 2.2.
4. Possible aid to farmers going beyond the liquidity measures
under Section 2.1 and 2.2
Because of the uncertainties of the current circumstances, the relevant
agriculture authorities in Denmark are not able to assess/estimate whether
the measures envisaged by the Commission in the draft TCF will be
sufficient or whether they could result in a reduction in prices for ordinary
consumers. The Danish government has as far as possible tried to answer
the Commission’s questions related
to farmers in the EU-Survey.
5. Questions to the Commission
The wording of Section 2.3 is limited to “aid for additional costs due to
exceptionally severe increase in gas and electricity”. Is
it then
–
with the
scope in mind
–
a typing error that the Commission refers to sanctions etc.
in point 39(e)?
Point 39(f) states the following:
 EUU, Alm.del - 2021-22 - Bilag 391: Notat og høringssvar vedr. Kommissionens høring om midlertidige kriserammebestemmelser for statsstøtte ifm. Ruslands invasion af Ukraine
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”Eligible costs under this measure are the increase in monthly gas
and electricity costs after the invasion of Ukraine by Russia in
comparison with a reference period between 1 November 2021
and 31 January 2022. Therefore, and for the purposes of this point,
aid can be granted in relation to the gas and electricity consumption
of the undertaking from 1 March 2022 until 31 December 2022, at
the latest (‘eligible period’).
The eligible cost includes the monthly
unit cost36 of the undertaking e.g. in EUR/MWh of gas and
electricity in the eligible period to the extent it exceeds [140%] of
the average unit cost of gas and electricity for the undertaking in
the reference period.”
In the underlined part of this
point, the Commission refers to “eligible cost” and not
“increase in eligible cost”.
Can the Commission please
confirm that “[140%] of the
average unit cost […]” involves a total increase of 40%
(and not 140%)?
In the Danish government’s opinion, it will
be useful if the Commission could
elaborate and clarify the calculation method in point 39(f).