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CEE Bankwatch Network

BWN

CEE Bankwatch Network monitors international financial institutions and EU funds in Central and Eastern Europe, promoting public participation and preventing harmful environmental and social impacts.

Lobbying Activity

Meeting with Aleksandra Baranska (Cabinet of Executive Vice-President Teresa Ribera Rodríguez) and Climate Action Network Europe and

12 Jan 2026 · Social Climate Fund, ETS 1 revision and ETS2

Meeting with Gabriella Gerzsenyi (Member of the European Parliament)

5 Dec 2025 · Exchange of views on the Just Transition of CEE regions

Meeting with Jana Toom (Member of the European Parliament)

5 Dec 2025 · Just Transition

Meeting with Estelle Ceulemans (Member of the European Parliament)

4 Dec 2025 · Dossier Just Transition

Meeting with Chris Uregian (Cabinet of Executive Vice-President Raffaele Fitto), Felicia Stanescu (Cabinet of Executive Vice-President Raffaele Fitto)

2 Dec 2025 · Cohesion's Policy Mid-Term Review and Multiannual Framework

Response to EU’s next long-term budget (MFF) – EU funding for external action

21 Nov 2025

CEE Bankwatch Network welcomes the increase of the budget for external action. However, the target for climate and environment of 30% for Global Europe is not enough for enlargement countries and must be increased to at least the level of the overall MFF whose target should itself be increased to at least 50%. The target must also be more granular to prevent marginalising biodiversity spending and other less commercially attractive activities. Moreover, fossil fuels must be explicitly excluded from funding. Funding for just transition of carbon-intensive regions must be earmarked for enlargement countries. Environment and climate financing, as well as support for just transition for municipalities should be excluded from the performance-based approach for candidate and potential candidate countries and subject to specific grant-based programmes. Our full position on the Global Europe instrument is attached.
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Meeting with Dan Barna (Member of the European Parliament)

20 Nov 2025 · The current status of EU funding instruments in the Western Balkan countries

Meeting with Alberto Fernandez Diez (Cabinet of Commissioner Marta Kos) and Transport and Environment (European Federation for Transport and Environment) and

20 Oct 2025 · Implementation of EU acquis across several areas, including environment, climate, labour and animal welfare.

CEE Bankwatch urges end to fossil fuel subsidies in state aid rules

6 Oct 2025
Topic — Revision of EU rules exempting certain state aid from prior Commission approval.
Message — The organization demands complete exclusion of fossil gas, non-renewable hydrogen, and carbon capture from state aid. They argue aid must not contribute to environmental harm and should only support the least damaging activities.123
Why — This would redirect public funds toward genuine renewable energy and energy efficiency measures.45
Impact — Fossil fuel industries lose subsidies supporting gas infrastructure, hydrogen production, and carbon capture.67
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Bankwatch urges EU to scrap nature credits plan as unproven distraction

26 Sept 2025
Topic — EU roadmap proposing a new voluntary market for biodiversity conservation certificates.
Message — The organization requests the Commission abandon nature credits and instead prioritize cutting harmful subsidies, improving public funds, enforcing environmental law, and raising revenue through taxes and user charges. They argue nature credits lack evidence of effectiveness and distract from proven solutions.1234
Why — This would redirect Commission resources toward policies with proven track records for biodiversity.56
Impact — Biodiversity loses as limited EU staff capacity gets diverted to experimental schemes instead of urgent protection needs.78
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CEE Bankwatch urges EU grid funding for renewables, not fossils

5 Aug 2025
Topic — The European grid package aims to modernize infrastructure for cleaner, secure energy.
Message — Maintain environmental standards while accelerating permitting through better staffing and digitalisation. Fund only electricity grids and exclude support for fossil-based hydrogen or CO2 networks.123
Why — The group ensures that biodiversity protections remain intact while securing funds for community energy.45
Impact — Fossil fuel and carbon capture industries would lose access to significant EU infrastructure subsidies.67
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Bankwatch demands environmental safeguards for CBAM energy imports

1 Aug 2025
Topic — Extending the carbon border adjustment mechanism to downstream products and anti-circumvention measures.
Message — The organization supports including downstream steel and aluminium products while tracking the ultimate origin of materials. They demand strict environmental criteria for foreign renewable energy facilities to protect biodiversity and local communities.123
Why — This ensures their climate and environmental goals are not undermined by foreign circumvention.45
Impact — Nearby producers using unsustainable methods would lose their competitive access to EU markets.67
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CEE Bankwatch Network urges stricter EU carbon market rules

8 Jul 2025
Topic — Evaluation of the EU emissions trading system and market stability reserve by 2026.
Message — CEE Bankwatch Network demands waste incinerators join the ETS by 2028. They call for ending free pollution allowances earlier and widening aviation coverage.123
Why — This would shift substantial EU investment toward cleaner energy infrastructure in Central Europe.4
Impact — Industrial polluters and airlines would lose lucrative subsidies and free carbon permits.5
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Meeting with Anne Funch Jensen (Cabinet of Commissioner Piotr Serafin) and Transport and Environment (European Federation for Transport and Environment) and

11 Jun 2025 · Exchange of views on the future Multiannual Financial Framework and other EU priorities

Meeting with Agnese Dagile (Cabinet of Executive Vice-President Raffaele Fitto), Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

8 Apr 2025 · Just Transition Fund

Meeting with Yolanda Garcia Mezquita (Head of Unit Energy)

19 Mar 2025 · Follow-up meeting to discuss Western Balkans' energy sector developments amid regional political tensions

CEE Bankwatch Network urges public-led EU water resilience strategy

4 Mar 2025
Topic — The consultation seeks to create a multi-annual plan to ensure European water resilience.
Message — The organization demands a focus on public sector projects over private concessions and better enforcement of water directives. They reject the competitiveness framing, arguing the sector should prioritize environmental justice and resource efficiency. They also seek to reduce the global water footprint of industries like mining and textiles.123
Why — Prioritizing public management and nature-based solutions would ensure long-term environmental restoration and water security.45
Impact — Private water concessionaires and hydropower developers would face reduced investment opportunities and stricter oversight.67
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Bankwatch demands stricter data quality for national restoration plans

6 Feb 2025
Topic — This consultation establishes a uniform format for reporting national nature restoration plans.
Message — The Commission should set ground rules to ensure restoration data is current. Member States must make reporting on strategic raw material projects mandatory. Meaningful public consultations with NGOs are essential to reflect needs on the ground.123
Why — NGO involvement would help the network ensure EU funding aligns with conservation goals.45
Impact — National authorities can no longer rely on outdated datasets to meet reporting requirements.6
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Meeting with Victor Negrescu (Member of the European Parliament)

6 Feb 2025 · Multiannual Financial Framework and Recovery and Resilience Facility

Meeting with Mirka Janda (Cabinet of Executive Vice-President Raffaele Fitto)

6 Feb 2025 · Inclusion of civil society in decision-making to achieve social and climate justice

Meeting with Iulia-Mirela Serban (Acting Head of Unit Regional and Urban Policy)

5 Feb 2025 · Meeting to discuss the findings of two Bankwatch Network’s reports on “Navigating the 2025 mid-term review and the next EU budget” (12/2024)and “Strengthening the participation of civil society in monitoring committees through technical assistance"

Meeting with Nils Ušakovs (Member of the European Parliament)

5 Feb 2025 · EU Budget

Meeting with Iuliu Winkler (Member of the European Parliament)

4 Feb 2025 · the future of Cohesion Policy

Meeting with Rasmus Nordqvist (Member of the European Parliament, Shadow rapporteur)

29 Jan 2025 · Future MFF

Meeting with Csaba Molnár (Member of the European Parliament) and National Society of Conservationists -Friends of the Earth Hungary (Magyar Termeszetvedok Szovetsege)

3 Dec 2024 · Just transition, energy transition

Meeting with Sebastian Everding (Member of the European Parliament)

20 Nov 2024 · Introductory meeting

Meeting with Gordan Bosanac (Member of the European Parliament)

18 Nov 2024 · Energy and environmental issues in the Western Balkans

Meeting with Cristina Guarda (Member of the European Parliament)

14 Oct 2024 · Cohesion Policy

Meeting with Dario Tamburrano (Member of the European Parliament)

24 Sept 2024 · Incontro di presentazione

Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

CEE Bankwatch Network welcomes the opportunity to provide feedback and input for the application of DNSH to the Social Climate Fund. As an organisation, we have been closely monitoring the application of the DNSH to both the Recovery and Resilience Facility (RRF) and Cohesion Policy Funds at both EU and national levels, and believe our findings can help strengthen its use when expanding to new funding instruments. In principle, the tool has recognised the need to take a holistic approach and avoid an investment in one sector leading to a negative impact in another, which is very much welcomed. However, overall our experience is that it ultimately depends on how DNSH is applied in practice on the ground by the national authorities. Greater training and support is needed at national level to ensure those applying the DNSH assessment to programmes/projects have the necessary level of knowledge and expertise to do so in a meaningful way. Without this, the tool is largely ineffective at preventing environmental harm. Furthermore, the implementation of DNSH corresponds to different rules depending on the funding programmes. This leads to inconsistencies and challenges in its implementation, as recognised by the recent JRC study. Adding to the fact that the methodology is still relatively new and can be interpreted widely by different authorities, this is likely to create confusion and weaken the purpose of the principle. The DNSH under the SCF should be built on the lessons from the experience under the various funds and a strong methodology should be defined to ensure this consistency gap can be reduced in the future. Moreover, any approach must balance the necessary flexibility needed to accommodate the different national contexts, as well as the need for concrete impact to actually prevent any climate or environmental harm and increase the ambition of the measures. In this regard, stricter rules, applied more thoroughly and with higher control and assistance from the European Commission, is needed. In general, rules governing DNSH application for cohesion policy have proven too weak to provide sufficient benefit. Member States can develop their own methodologies for how to demonstrate compliance, as opposed to RRF where they are required to conduct an assessment based on the Commissions pre-defined methodology. This is not acceptable as this undermines consistency on how the DNSH is being implemented from countries to countries. Please find attached additional input consisting of ten key issues with corresponding recommendations in relation to the future development of DNSH guidelines.
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Response to Assessment of the energy efficiency public funding support at Union and national level

26 Feb 2024

CEE Bankwatch Network welcomes the European Commissions call for evidence ahead of the report it will provide to the Council and the Parliament on the evaluation of public funding for energy efficiency. Energy Efficiency financing coming from EU funds is critical for the energy transformation in the central and eastern European (CEE) region. Currently, a decent amount of money is available thanks to EU public finance by 2030, thanks to a variety of funds: the Recovery and Resilience Facility, Cohesion Policy Funds, the Modernisation Fund, and soon the Social Climate Fund. Together they provide a significant amount of money as well as the bulk of public investments for energy efficiency in the central and eastern European countries. Yet they have to be used wisely to reap the potential for genuine energy efficiency gain and limit greenhouse gas emissions while helping to reduce energy needs and help alleviate energy poverty situations. With the proposal for a 2040 climate target, it is expected that the decarbonisation costs in the upcoming period would be multiple times higher than by 2030. This is why it is crucial to make the best use of the money available now under the existing programmes and not postpone the crucial investments that can lead to significant energy savings. A review of current practices in designing and implementing public programmes for energy efficiency (see below an analysis of eight countries in CEE region) shows that this objective is not a priority in many countries. Public administrations managing grants are often lacking capacities as well as the needed data to design innovative financing instruments that could lead to higher energy savings while taking into account better the needs of the beneficiaries. As a result, the current funding mechanisms in place are not appropriate to tackle the challenge, in particular: - The current public support schemes for energy efficiency show a low ambition, more specifically they do not provide specific support to reach a higher level of energy efficiency, e.g. in the building sector by prioritising deep renovation. The data from Renovate Europe analyses also says that from the 20bn EU cohesion policy funds, three quarters (15.3bn) will go to projects subject to minimum energy savings criteria. Such projects would need to achieve at least medium depth renovation (primary energy savings of over 30%; or for public sector, realise greenhouse gas emission savings of over 30%). Overall, there is need for special efforts to make sure that the public funding ensures higher quality renovation closer to the EED and EPBD requirements. - There is also too little use of financial instruments for making a better use of public money (e.g. by using revolving funds, loans, energy performance contracting, ...). Current practices of grants with 0% beneficiary cofinancing (like in some countries like Bulgaria) discourage energy performance contracting - Low income and energy poor stakeholders are not systematically targeted as potential beneficiaries of the programmes, and sometimes de facto excluded since beneficiaries often have to provide upfront financing before being reimbursed. - The potential of public funded measures is undermined by the fact that behavioural changes leading to energy savings are not encouraged. In some cases, the regulatory framework needs to be reformed in this regard. - The energy efficiency projects also often suffer from lower absorption, especially in less developed regions, which according to the European Commission statistics, are also the ones with lower efficiency, competitiveness and innovation. Key issue with underspending is the administrative and technical capacity for preparation and management of the calls. Therefore, the projects could have crucial for increasing the quality of the spending and also the speed of absorption
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Response to Guidance to facilitate the designation of renewables acceleration areas

23 Feb 2024

CEE Bankwatch Network welcomes the improvement in spatial planning and the clarity that acceleration areas have the potential to bring for investors as the EU strives to ramp up its renewable energy share. But we remain highly concerned about the rollback of environmental safeguards and public participation provisions in the latest updates to the Renewable Energy Directive. Our input, which can be found in the attached document, is therefore aimed at formulating guidelines that could help limit the potential damage as much as possible and ensure compliance with EU environmental law, as well as the Aarhus Convention.
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Meeting with Dino Toljan (Cabinet of Vice-President Maroš Šefčovič)

14 Feb 2024 · 2030 climate and energy targets and role of NECPs

Meeting with Maroš Šefčovič (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

30 Jan 2024 · Green Deal, 2040 climate target, strategic dialogue on the future of agriculture in the EU

Meeting with Rosa D'Amato (Member of the European Parliament)

19 Dec 2023 · RRF

Meeting with Themis Christophidou (Director-General Regional and Urban Policy)

15 Dec 2023 · Cohesion policy funding

Meeting with Francisco Barros Castro (Cabinet of Commissioner Elisa Ferreira)

5 Dec 2023 · CEE Bankwatch shared most current information and views about the Just Transition process in Central and Eastern Europe.

Meeting with Aleksandra Baranska (Cabinet of Vice-President Maroš Šefčovič)

5 Dec 2023 · Just Transition

Meeting with Maroš Šefčovič (Executive Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

7 Nov 2023 · Transition towards sustainable food systems

Response to Mid-term evaluation of the ERDF, the CF and the JTF 2021-2027

9 Oct 2023

Please find attached Bankwatch feedback on the mid-term evaluation of the ERDF, CF and JTF.
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CEE Bankwatch urges stricter gas restrictions and better transparency

28 Aug 2023
Topic — Revision of operational rules for the EU Modernisation Fund's energy investments.
Message — They want a mechanism to assess and mitigate the risk of long-term gas dependence. The groups seek publicly available lists of fund recipients and project climate impacts. They recommend that consultations be open to the public following strict standards.123
Why — Stricter reporting would allow the NGO to effectively monitor and challenge energy projects.4
Impact — Fossil gas companies would face stricter oversight and higher hurdles for project approval.5
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Meeting with Sergey Lagodinsky (Member of the European Parliament, Rapporteur)

26 Apr 2023 · Exchange of Views on Asset Recovery and Confiscation

Meeting with Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans), Stefanie Hiesinger (Cabinet of Executive Vice-President Frans Timmermans)

15 Feb 2023 · Civil society views on current and future challenges in climate and energy policies issues in selected CEE countries

Response to Mid-term evaluation of the Recovery and Resilience Facility (2020 – 2024)

6 Dec 2022

Please find Bankwatch's response attached
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Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans)

2 Dec 2022 · Implementation of the Just Transition Fund

Meeting with Francisco Barros Castro (Cabinet of Commissioner Elisa Ferreira)

1 Dec 2022 · CEE Bankwatch shared information and views about the Just Transition process on the ground in Central and Eastern Europe.

Meeting with Niklas Nienass (Member of the European Parliament)

1 Dec 2022 · exchange of views with Just Transition national campaigners

Meeting with Marc Botenga (Member of the European Parliament) and EuroNatur - Stiftung Europäisches Naturerbe

8 Nov 2022 · Renewable energies and protection of biodiversity in the RED III and RED IV revisions

Meeting with Thomas Waitz (Member of the European Parliament)

29 Sept 2022 · Ukraine and financial support

Meeting with Anna Deparnay-Grunenberg (Member of the European Parliament) and European Environmental Bureau and

8 Sept 2022 · exchange on RED II

Meeting with Petros Kokkalis (Member of the European Parliament) and EuroNatur - Stiftung Europäisches Naturerbe

2 Sept 2022 · energy from renewable sources

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Lukas Visek (Cabinet of Executive Vice-President Frans Timmermans), Riccardo Maggi (Cabinet of Executive Vice-President Frans Timmermans)

2 Sept 2022 · Fit for 55, Repower EU and events planned under CZ Presidency

CEE Bankwatch Network warns against weakening environmental laws for renewables

27 Jul 2022
Topic — EU guidance on accelerating permitting processes for renewable energy projects and power agreements.
Message — The organization opposes exempting renewable projects from environmental impact assessments and the overriding public interest designation. They demand stronger administrative capacity and the preservation of public consultation rights.12
Why — Strengthening environmental oversight ensures their long-term goal of sustainable, legally certain energy deployment.34
Impact — Local populations and biodiversity suffer if legal protections and public participation rights are bypassed.56
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Response to Regulation on REPowerEU chapters

20 Jul 2022

Please find attached CEE Bankwatch Network's response to the consultation.
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Meeting with Alexandra Geese (Member of the European Parliament) and SMEunited aisbl and

29 Jun 2022 · Event: Repowering the Recovery - RRF one year on

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson)

22 Jun 2022 · To discuss the role district heating could play in the Repower EU package.

Meeting with Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis) and ClientEarth AISBL and

28 Apr 2022 · Contribution and engagement from CSOs, local authorities and social partners on Polish RRP

Meeting with Bas Eickhout (Member of the European Parliament)

28 Apr 2022 · REPowerEU

Meeting with Margarida Marques (Member of the European Parliament)

26 Apr 2022 · Public Finance towards environment and climate

CEE Bankwatch urges biodiversity safeguards in renewable energy expansion

12 Apr 2022
Topic — EU guidance focuses on speeding up renewable energy permitting and administrative processes.
Message — The group demands prioritizing energy efficiency and rooftop solar on brownfields. They insist on strict enforcement of environmental laws to prevent habitat destruction.123
Why — Clear spatial zoning would streamline the permitting process and reduce public opposition.4
Impact — Wildlife and ecosystems are threatened if environmental impact assessment procedures are abolished.56
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Bankwatch urges EU to prioritize rooftop solar and biodiversity

12 Apr 2022
Topic — A consultation on accelerating solar deployment to meet climate and energy targets.
Message — The organization proposes a two-phase approach prioritizing solar on rooftops and industrial sites to protect nature. They also demand legal reforms to support energy communities and involve citizens in the transition.12
Why — These recommendations would ensure EU funds support environmentally sound projects and boost local energy security.34
Impact — Large developers face restrictions on building solar farms in ecologically sensitive grasslands and meadows.5
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Meeting with Giorgos Rossides (Cabinet of Commissioner Stella Kyriakides), Roberto Reig Rodrigo (Cabinet of Commissioner Stella Kyriakides) and

9 Mar 2022 · VTC meeting: Revision of the SUD Proposal

Meeting with David Cormand (Member of the European Parliament, Rapporteur) and Greenpeace European Unit and Counter Balance

16 Feb 2022 · EIB

Response to Ex post evaluation of the European Regional Development Fund and the Cohesion Fund 2014-2020

9 Feb 2022

Please find document attached for public consultation response.
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Meeting with Kadri Simson (Commissioner) and

3 Dec 2021 · Discussion on upcoming Hydrogen and Decarbonised Gas Markets Package (adoption foreseen for 14.12.2021)

Meeting with Barbara Glowacka (Cabinet of Commissioner Kadri Simson), Tatiana Marquez Uriarte (Cabinet of Commissioner Kadri Simson)

2 Dec 2021 · Colossal Western Balkans coal pollution must prompt EU action

Response to Review of Directive 2012/27/EU on energy efficiency

19 Nov 2021

Bankwatch welcomes the possibility to react to the European Commission's proposal on the Energy Efficiency Directive. Please find attached our position.
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Response to Proposal for a Regulation on establishing a Climate Action Social Facility

18 Nov 2021

Bankwatch welcomes the possibility to react to the European Commission's proposal on the Social Climate Fund. Please find attached our position.
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

CEE Bankwatch Network welcomes the proposal for the EU's planned CBAM. Our responses to this consultation concentrate specifically on the power sector, based on our experience in southeast Europe, where a CBAM is much-needed. 1) While the concept of carbon leakage so far appears to be theoretical for many industries in the EU, for the power sector, the import of carbon-intensive electricity from the Western Balkans and Ukraine is ongoing every day. The price of such electricity is artificially low, not only because the countries do not apply carbon pricing,1 but also because all of those who use coal have also failed to comply with the provisions of the Large Combustion Plants Directive, which have been binding under the Energy Community Treaty since 1 January 2018. Our recent report shows that between 2018 and 2020 coal power plants in the Western Balkans caused an estimated 19,000 deaths, with almost 12,000 of these due to non-compliance with the Directive. And in 2020, the Western Balkans’ 18 coal plants emitted two and half times as much sulphur dioxide as all 221 coal power stations in the EU combined. On one hand the EU benefits from these deadly breaches as between 2018 and 2020 it imported around 8 per cent of the Western Balkans’ coal-based electricity. But on the other hand it pays a high price, as over half of the modelled pollution related deaths took place in the EU. Efforts are ongoing to introduce carbon pricing into the Energy Community Treaty, but this will take time. The CBAM has the potential to take effect much earlier, and this opportunity must be seized. 2) Overall, we agree that the CBAM must replace free allowances under the ETS. However it is unclear why the overlap period needs to be so long – 10 years starting from 2026. It is also not clear how this relates to the power sector, where in our understanding all free allocations under ETS must end by 2030 at the very latest under the current ETS legislation – a date which should be brought forward under the new Directive. 3) Regarding the use of revenues, they should be used for climate action. For example a just transition fund for the Western Balkans and Ukraine could utilise the income from the power sector from the CBAM. For detailed responses and proposals for amendments on the text, please see the accompanying file.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

CEE Bankwatch Network supports amending the RED II to further align it with the European Green Deal, and raising the ambition of the RED II targets. However, such an increase in ambition must be accompanied by a tightening of the Directive’s sustainability provisions – for all technologies, not only biomass – if it is to truly contribute to the Green Deal. The draft contains some welcome innovations which may help to move forward renewable energy development in the EU. Nevertheless, it does not pay sufficient attention to providing safeguards with regard to the potential impacts of renewable energy installations on the environment. The explanatory memorandum, p.9. under Fundamental rights, rightly states that: ‘In terms of consistency with the Charter for fundamental rights, the overarching aim of this review is to increase the use of renewable energy and reduce GHG emissions, and this is entirely in line with Article 37 of the Charter under which a high level of environmental protection and the improvement of the quality of the environment must be integrated into the policies of the Union and ensured in accordance with the principle of sustainable development.’ Nevertheless, it is not only GHG emissions which need to be integrated into the Union’s policies, but also others including biodiversity protection. It may be argued that such issues are dealt with by the environmental acquis itself, but this is only partly the case. The environmental acquis tells us nothing on how to ensure that installations whose development or operation breach its provisions do not receive renewable energy incentives, for example, and there is no systematic mechanism by which State aid for illegally permitted projects can be halted or prevented. At the same time there is a significant grey zone of installations whose development proceeds only because of derogations under Article 6.4 of Directive 92/43/EEC or Article 4 of Directive 2000/60/EC. The EU is struggling to fulfil the goals of these Directives, yet such projects are still allowed to receive incentives. As the EC’s 5th Water Framework Directive implementation report put it in February 2019: “The exemptions foreseen in Article 4 of the WFD currently cover around half of Europe’s water bodies. This mainly concerns natural water bodies, but increasingly also heavily modified and artificial water bodies, next to new physical modifications. Whilst the justifications for such exemptions have overall improved, their persistent wide use is an indicator of the significant efforts still needed to achieve good status or potential by 2027.” It is therefore high time to tightly link the Renewable Energy Directive with strong provisions ensuring that no State aid is provided for projects which are in breach of environmental law or which require derogations from it. Please find our detailed comments on specific provisions and proposals for amendments in the attached file.
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Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

7 Sept 2021 · state of play on just transition planning in coal regions in Europe

Response to Setting out common indicators and detailed elements of the recovery and resilience scoreboard

25 Aug 2021

Monitoring the spending of the 672.5bn of the recovery and resilience facility will require accurate and meaningful indicators to assess progress against its intended objectives. The unprecedented amount of money released in such a short period of time requires strong mechanisms in order to guarantee compliance with all relevant rules and levels of control. We therefore welcome the Commission’s proposal to establish a scoreboard mechanism for assessing the progress of national recovery plans against shared objectives. However, we are concerned that, under its current form, the indicators are insufficient and lacking in substance to accurate reflect such progress. In general, we recommend increasing the number and granularity of the indicators proposed. Recovery plans include a wide range of investments and reforms with varying objectives, yet we feel the current indicators do not provide a thorough and comprehensive enough assessment of these. This is especially true regarding the number of indicators for the green transition pillar, which accounts for at least 37 percent of expenditure for each national recovery and resilience plan. The low number of indicators (only four in the draft delegated act) proposed for the green transition contradicts the importance of this pillar under the RRF and delivering on the European Green Deal objective for 2030. We specifically encourage the introduction, or at least to consider the integration of new indicators to reflect the following: Energy and climate While we welcome indicators 1 and 2, an indicator is needed to monitor the reduction of greenhouse gas emissions. Furthermore, a specific indicator monitoring the necessary phasing out of fossil fuels would reflect the commitment of the EU to become a carbon neutral economy by 2050. This could include, for example, the share of coal and gas present in the energy mix. Given the important role of building renovation in the fight against climate change, introducing an indicator on the number of dwellings and public buildings with improved energy performance would be welcome, in line with the renovation wave strategy. Nature and biodiversity There are no meaningful indicators to measure and assess progress with regard to biodiversity targets and objectives. This contrasts with the Commission’s message that biodiversity restoration should be a key part of the recovery due to both its poor state and direct contribution to the climate objectives. Although indicator 4 states “Population benefiting from protection measures against floods, wildfires, and other climate related natural disasters”, this does not indicate any such information for biodiversity nor does it give any indicator whether these measures were reached by the use of nature-based solutions. To better reflect the contribution of recovery funds on biodiversity, more specific and targeted indicators are needed. This could include, for example, the surface of Natura 2000 sites covered by protection and restoration measures and/or the surface area of rehabilitated land supported. If the recovery is to be genuinely positive for nature, as stated, the efforts and progress made by Member States must be substantiated and communicated transparently and accurately to the public. Overall, we feel that the setup of the indicators overly favours the reporting of positive progress made by Member States, and as a result it can conceal any negative progress made. We are therefore concerned that this would lead to an inaccurate and misleading positive depiction of how these funds have been spent. (please see full response to public consultation attached below)
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Response to Delegated act supplementing the Instrument for Pre-accession Assistance (IPA III)

29 Jul 2021

CEE Bankwatch Network welcomes this consultation but we are rather confused on why the priorities list is being consulted but we are not aware of any consultation on the draft IPA III Regulation itself having taken place. A consultation on the whole Regulation would have been more useful, as the issue of conditionality and safeguards for IPA III is crucial. As far as we have been able to ascertain, the final text agreed between the Council and European Parliament is not even publicly available at the moment, which makes the list of priorities rather disembodied. Moreover, the timing of the consultation is very unfortunate, coming in the middle of the holiday period when input is least likely. For the above reasons, our input is very limited. Nevertheless, we would like to underline that although the 15 areas set out are all useful and needed, this seems a very long list of priority areas, which limits the likelihood of effectiveness per area. More specifically, in view of the EU's 2050 decarbonisation commitments, an update of the language used is needed. In section 11 f) - "Promoting policies to support the shift towards a resource-efficient, safe and sustainable low-carbon economy, energy efficiency and strengthen disaster resilience as well as disaster prevention, preparedness and response", the term "zero carbon" should replace "low-carbon", which no longer reflects the EU's policy commitments. In addition, in point 15 b), on Thematic priorities for Cross-border cooperation, "Protecting the environment and promoting climate change adaptation and mitigation, risk prevention and management and promoting the use of renewable energy sources", we advise the deletion of "and promoting the use of renewable energy sources", as the likelihood of cross-border auctions in the region is very low and in all likelihood this will mainly be interpreted as an invitation to build hydropower plants on transboundary rivers, even though most such planned projects are not being carried out in line with EU legislation. Overall, we stand ready to contribute to the IPA implementation and monitoring, but in order to make this easier we call on the Commission to step up its efforts to provide public explanations of the process and how and at what stages civil society can contribute, as the process and timing has not been very clear so far.
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Mirzha De Manuel (Cabinet of Executive Vice-President Valdis Dombrovskis) and

8 Apr 2021 · Recovery and resilience plans

Meeting with Virginijus Sinkevičius (Commissioner) and

12 Jan 2021 · To discuss the implementation of the Biodiversity strategy, the actions under the zero-pollution ambition as well as green funding under the new MFF and the recovery funds.

Response to Revision of the Communication on important projects of common European interest

21 Dec 2020

Although the IPCEIs framework has been in place for 15 years, only four such projects have been notified and assessed by the EC so far. The last two were launched in the areas of strategic value chains for microelectronics and batteries. The "Battery" IPCEI decision has not yet been published in the EC's case database. The “Microelectronics” project runs for a long time and will not be evaluated for many years. There is thus a lack of information to be able to decide whether this type of State Aid is effective and efficient, which makes it more difficult to revise the regulatory framework. Building on these facts, our general view is that the EC needs to take a cautious and moderate approach in drafting and implementing future IPCEI communication. Special care must be taken that the IPCEI communication and concrete projects selected under this framework deliver on the Green Deal and contribute to the overarching target of climate neutrality. For this reason, we call upon the EC to integrate the Green Deal objectives and environmental protection requirements into the IPCEI Communication, especially under the eligibility and compatibility criteria of the Communication. We follow on the views from ClientEarth and The Confederation of Swedish Enterprise that increased transparency and accountability is needed at all stages of the IPCEI framework, from the selection of projects and the participating companies, through the entire application process to decisions, as well as in how projects are evaluated. Bankwatch calls for all fossil fuel projects to be excluded from the IPCEI instrument scheme, even if carbon capture and storage (CCS) technology is used, as this will still not address methane leakages during extraction and transport. Due to the concrete intention for a new IPCEI on hydrogen, we urge the EC to take a cautious approach. This technology could be used as a justification for the continued development of natural gas infrastructure, thereby postponing the phase-out of natural gas, as well as other unsustainable energy sources. Building on the arguments already raised by ClientEarth and Danish Energy, we call on the EC to exclude low-carbon hydrogen from the IPCEI state aid support scheme. This technology is non-consistent with the objectives of the Green Deal: among others, CCS technology that is planned to be used parallel to low-carbon hydrogen production has serious questions from economic, environmental and technical perspectives. Even when proven successful and profitable at scale (which still needs to happen) CCS’s high energy use means it should not be a preferred option and cannot be considered a public benefit and therefore does not deserve any public funding, especially under the IPCEI. Besides, any state aid to hydrogen that is not produced at 100% from sustainable renewable sources must be excluded. The blending of hydrogen with natural gas should not be stimulated under the IPCEI instrument scheme. There is also a danger that hydrogen is produced using unsustainable renewables like hydropower and biomass, which must not be supported by public money, as it could encourage their widespread expansion. Hydrogen can be a solution for hard to abate sectors, only if hydrogen production is based on additional renewable energy. Given the low efficiency of the electrolysis process paired with the need for RES in power production, hydrogen projects must not compete where renewables-based electricity can be used directly (e.g. heating or land transport sectors). Furthermore, we call upon the EC to develop sustainability criteria for the IPCEI projects, in line with the Green Deal, preferably under the general cumulative criteria of the IPCEI communication. The sustainability criteria should assess the climate and environmental benefits of a proposed project while taking care not to finance “transition” activities that can lead to lock-in and "stranded assets" issues.
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CEE Bankwatch Network Urges Exclusion of Nuclear, Gas, and Small Hydropower from EU Taxonomy

18 Dec 2020
Topic — EU classification of environmentally sustainable economic activities for climate investment.
Message — The organization demands nuclear and fossil fuels remain excluded from the taxonomy. They request reinstating stricter Technical Expert Group criteria for hydropower, biomass, and methane leakage monitoring. They call for strengthening biodiversity protections and excluding hazardous waste burning in cement production.1234
Why — This would preserve the taxonomy's environmental credibility and ensure only truly sustainable activities receive green finance classification.56
Impact — Nuclear and fossil fuel industries lose access to sustainable finance classification and associated investment.78
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Bankwatch agrees that “... the extended scope of the EEAG needs to be accompanied by (...) safeguards to ensure that the aid: (i) is effectively directed (...) (no crowding out of private investment, no greenwashing), and (ii) is limited to what is needed to achieve the environmental goals (...).” The following improvements are therefore needed: Coherence with EU environmental acquis: EEAG para. (7) and (117) require environmental compliance, however in reality, aid schemes still support non-compliant projects. The EEAG needs to specify that aid for illegally permitted projects must be halted. In reality, the Water Framework Directive (WFD)’s exemptions are over-applied and threaten to derail its goals (see EC 5th implementation report). DG COMP’s State aid decisions on support schemes do not analyse whether countries properly apply eg. Article 4(7). The EEAG needs to stipulate that no incentives for hydropower may be provided in countries that have not achieved the WFD goals. To make sure that renewable projects developed in breach of the EIA, Birds or Habitats Directives do not receive incentives, the EEAG needs to state that projects or sectors subject to EC environmental infringement procedures, ongoing investigations, or national level court cases may not receive incentives. Capacity mechanisms: Provisions in line with Chapter IV, EU Electricity Market Regulation are needed to verify whether Member States have alternatives to applying capacity mechanisms, and if not, whether the proposed scheme’s design limits environmentally harmful subsidies. Assessments must always apply the energy efficiency first principle. Energy infrastructure: The EEAG will need to be aligned with the upcoming new TEN-E Regulation. Para. (208) needs to be amended to: “For oil and gas infrastructure projects, the Commission presumes that there is no need for State aid.” Theoretical future use of infrastructure for “green gas” cannot justify continued lock-in. Cogeneration: Para. (151) allows operating aid for high energy efficient cogeneration plants. However in practice this is a loophole that allows aid for gas and non-biodegradable waste incineration that cannot qualify for renewable energy aid. No State aid may be granted for fossil fuels, efficient or not. Aid to waste management: EEAG Section 3.5.2. must be aligned with Renewable Energy Directive Art. 3 ie. Member States shall grant no support for energy produced from waste incineration if their separate collection obligations have not been complied with. This must apply to all waste-to-energy incentives, even if assessed as cogeneration (not renewable energy) to avoid circumventing the waste hierarchy. The EEAG must clarify how to apply this to renewables incentives schemes and to specific projects (eg. cogeneration). Biomass: Biomass can currently benefit from operating aid, even after depreciation. It is receiving overly favourable treatment considering its environmental impact. The EC must re-examine whether forest biomass should be counted as renewable energy at all, and if so, under what conditions. The EEAG must be adjusted accordingly. Hydrogen: Renewable hydrogen may play a role in difficult-to-decarbonise sectors, but with caution. Its production needs large amounts of energy, which even if renewable, puts pressure on ecosystems. Boosting fossil gas hydrogen by overestimating the availability of renewable hydrogen and infrastructure needs is also a threat. Currently, less than 0.1% of hydrogen capacity is “green”, and its future availability has yet to be proven. Support for hydrogen must be limited to strictly renewable hydrogen. Thresholds for renewable energy auctions: The current exceptions to the renewable auction requirements are not sufficient to support energy communities. The EEAG needs to either raise the auction exemption threshold for energy communities, or stipulate a specific regime for energy communities eg. reserving specific auction capacity for them.
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Response to Access to Justice in Environmental matters

6 Dec 2020

The Aarhus Convention recognizes, among other things, the importance of fully integrating environmental considerations in governmental decision-making - a goal which has recently received renewed emphasis in the EU, via the EU Green Deal. The Convention further stipulates that effective judicial mechanisms must be accessible to the public, including organizations, so that its legitimate interests are protected and the law is enforced. This means that civil society must be able to hold decision-makers accountable for failure to implement environmental law or to fully integrate environmental considerations in decision-making, including EU institutions. This is not currently the case, as NGOs cannot in practice seek judicial review of EU acts that breach environmental law. Of particular concern for CEE Bankwatch Network are acts which have clear environmental consequences by allowing State aid and other public funds to be used for infrastructure projects with environmental impacts, such as the approval of lists of Projects of Common Interest under the TEN-E Regulation, or State aid decisions in which environmental considerations may not have been adequately integrated. We welcome the European Commission’s proposal to amend the Aarhus Regulation, however the current proposals do not go far enough to bring the Regulation into line with the Aarhus Convention. The main issue is that the scope of the decisions subject to internal review in the amendments is still unjustifiably narrow and is also unclear. It appears to exclude State aid decisions, for example - even though the CJEU has recently confirmed that the European Commission needs to ensure that its State aid decisions only authorise projects that comply with EU environmental law (Judgement of 22 September 2020, Austria v. Commission, C-594/18P, paras. 44-45 and 100). Where there is evidence that this is not the case, NGOs clearly need to be able to request an internal review if EU law is to be upheld. Even on decisions which are within its scope, it does not appear to ensure that the Court would review the substance of the case brought forward by NGOs regarding the breach of environmental law, rather than limiting itself to a mere technical review of the refusal by the Commission to carry out an internal review. Another issue is that the proposal does not limit the potential costs for civil society organisations when they lose a case, which means that the Aarhus Convention’s (Article 9.4) requirement for access to justice not to be “prohibitively expensive” is not implemented. This is particularly problematic where EU bodies hire external, private law firms to defend them, rather than relying on their own lawyers. We therefore make the following recommendations: 1) Delete the exception for acts that entail “implementing measures” in Article 2.1g) and align the wording on binding effects with CJEU case law - ie. all acts that produce legal effects must be subject to internal review. 2) Explicitly stipulate that court review (Article 12) must be able to include not only a review of a decision to reject an internal review, but also a review of the substance of the complainant’s arguments regarding the breach of environmental law which was the grounds for the request for the internal review in the first place. 3) Include State aid decisions as being subject to internal review (Article 2.2). 4) Ensure that access to justice in the context of the Aarhus Regulation is not prohibitively expensive for NGOs. We understand that the Aarhus Convention Compliance Committee is set to deliver advice on this issue in December 2020 and urge all involved in the decision-making on the amendments to take due account of the Committee’s input.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

Bankwatch fully supports the EC's proposal for an Action Plan to better prevent, remedy, monitor and report on pollution, as well as strengthening implementation and enforcement. In our view, the following recommendations and priorities would substantially mitigate and prevent further increases in pollution. This text is short summary of our position which are expressed more at-length in the attachment to this roadmap. The role of EU funds in tackling pollution Our research has found that EU funds often drive and exacerbate pollution and environmental degradation in CEE countries. To prevent this, the EC should: 1) Provide additional funding for protection of Natura 2000 sites, subject to strong conditionality that they will be properly protected by full implementation of the Birds and Habitats Directives and Water Framework Directive safeguard provisions, to protect them from pollution threats. 2) Ensure that no EU funds support harmful projects in the EU and globally. This should include measures to ensure that whole categories of projects are excluded from EU funding (and especially Cohesion Policy funding) until they are no longer affected by systemic problems concerning the enforcement and implementation of EU environmental rules. 3) Better enforce the polluter pays principle when EU Funds are involved, eg, pre-accession funds under IPA III must not be used to support pollution abatement equipment at coal power plants, as these must cover their own costs. 4) European public banks, the EBRD and EIB, need to ensure that EU standards are properly applied in the projects they support. Tackling pollution in accession countries. Air and water pollution in the EU cannot be properly tackled without taking into account transboundary pollution from the Western Balkan accession countries. Pollution of certain waterways in the EU also depends on the actions of accession countries, which have so far not enforced the Water Framework Directive. We see two main ways to tackle air and water pollution from accession countries: 1) Strengthening the Energy Community Treaty enforcement and penalty mechanisms, a CO2 price that would disincentivize the operation of coal plants, and additional EU environmental acquis including the Water Framework Directive and environmental quality standards. 2) Introducing a carbon border tax or equivalent “pollution border tax” which would at least prevent Western Balkan countries undercutting EU energy producers on the common energy market by failing to apply pollution control standards. Environmental liability in the EU and Energy Community There is still a lack of baseline data in CEE EU Member States that would allow the application of the Environmental Liability Directive. This means even when environmental crimes have been committed, offenders are often not charged with an environmental crime and the Directive cannot be applied, because of the lack of baseline data available. The EC needs to step up its monitoring of, and support for collecting baseline data in all industrial areas. The same applies to the Energy Community countries where the Environmental Liability Directive will apply from 01.01.2021. Improving enforcement procedures The EC does not often intervene on individual projects, and instead mainly deals with systemic issues. Even when it intervenes on individual cases, it comes at a very late stage where harm cannot be prevented or properly mitigated. Meanwhile, even if offenders are issued a fine by national courts, they can appeal and still operate until the court case is settled, harming the health of people in nearby communities. We call on the EC to address this by taking action where necessary at a much earlier stage and instigating a fast-track procedure for cases where environmental harm and/or health damage is ongoing. This would ensure a more effective and timely approach, rather than waiting until such damage is already done and environmentally irreversible.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Bankwatch supports a combination of non-regulatory measures, amending the RED II to accommodate for the new measures foreseen in the European Green Deal (EGD), and raising the ambition of the RED II targets and subtargets (option 5). However, such an increase in ambition should not be done without tightening the Directive’s sustainability provisions. Biomass: Bankwatch’s NECP analysis shows that Central and Eastern European (CEE) countries overall plan logging biomass use above sustainable levels. This means an increase in CO2 emissions from biomass, and a decline in CO2 storage by forests. Sustainable renewable energy should therefore be of highest priority for these countries. It is crucial for the Commission to ensure the sustainability criteria for biomass specified in article 29 of the RED II are both enforceable and properly enforced, which has not been the case so far in CEE. Enforcement of EU environmental legislation in CEE is decisive in order to implement the EGD objectives, as already shown by Bankwatch. Moreover, given the uncertainties and new evidence on emissions from biomass combustion, we call on the Commission to re-examine whether forest biomass should be counted as renewable energy and if so, under what conditions. In addition, we ask the Commission to re-examine the environmental impacts of biomass harvesting on biodiversity. When it comes to public financial support for biomass, the criteria defined in the EU taxonomy should fully apply. Sustainability criteria for hydropower: Art. 29 and 30 need to be simplified and then applied to at least the use of hydropower, if not all forms of renewable energy to prevent EU targets from driving energy projects that contravene the EU environmental acquis. The renewable energy target should exclude new renewable energy projects in or impacting Natura 2000 areas in countries that are subject to infringement procedures under the Birds/Habitats Directives, as well as new hydropower plants in countries or rivers which have not achieved the goals of the WTO Water Directive. Support mechanisms: Greater coherence between the EU environmental acquis, where implementation is lagging in many countries, and the RED’s provisions on support mechanisms is needed, as there is no systematic mechanism by which State aid for illegally permitted projects can be halted or prevented. The Energy and Environment Aid Guidelines contain a provision that only hydropower compliant with the WFD may be supported through incentive schemes. However, the exemptions in Art. 4 of the Directive are over-applied and endanger the achievement of the Directive’s goals (noted by the EC’s 5th WFD implementation report). Incentives for hydropower are aso still encouraging overdevelopment of small hydropower plants in Italy and EU accession countries. Art. 3 of the RED rightly states that “Member States shall grant no support for renewable energy produced from the incineration of waste if the separate collection obligations laid down in that Directive have not been complied with”. This should also include the provision for no hydropower incentives in countries which have not achieved the goals of the WFD, even for very small plants. This should also apply to projects which have been developed in breach of EIA Directive and Birds and Habitats Directives, and would be further strengthened by excluding hydropower from the exceptions in Art. 4.3 and 4.4. of the RED. Article 6 on Stability of Financial Support should also reflect these issues, and “adaptations necessary to comply with Articles 107 and 108 TFEU” as permitted grounds for revisions of support schemes should be extended to to ensure compliance with the EU environmental acquis. Third countries: Art.11 and 12 on joint projects between Member States and third countries need to be deleted. They open the door for environmentally damaging renewable energy projects in third countries, without the recourse mechanisms available in EU countries.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Bankwatch supports the revision of the Energy Efficiency Directive (EED) and welcomes the opportunity to react to its roadmap. As regards to the options put forward by the European Commission, Bankwatch also supports a stronger implementation of “energy efficiency first” principle, especially in the planning of the EU funds and their spending. Given the amount of investment needed in the field of energy efficiency, the role of public funding and especially of the next EU budget will be crucial to achieve the 2030 target and the 2050 carbon-neutrality objective. End fossil fuel subsidies and start financing a clean transition: Current EU funds allocated for improving energy efficiency (EE) are not enough. Energy renovation of buildings only accounts for around 4.35% of Cohesion Policy Funds. Substantial improvements can be made with better promotional campaigns and technical guidance to Member States and local managing authorities to encourage a greater amount of cohesion funding into this field. EU funds should better conform to and really drive the Energy Efficiency First principle. Experience has shown this is often not the case, with funds instead being invested into new, unsustainable infrastructure projects such as gas corridor expansion. Energy sources, i.e. biomass boilers should be conditioned with sustainability criteria, specifically: Minimum requirements for the EE of buildings and consumption of heating from bioenergy facilities. Stricter conditionality in exchange for Member States receiving these funds should be applied; 5 Member States have collectively invested €940 million into fossil gas infrastructure, despite almost all these countries ranking below the EU average for investments in EE. Better streamlining at national and EU levels: The current link between EU funding streams and national level strategies for EE renovations is fragmented and lacks cohesion. Better alignment between EU funds and national financing strategies need improvement as there is currently no overarching system to ensure streamlining between these two frameworks. Improving knowledge and coordination by managing authorities: Managing Authorities often lack awareness and expertise on EE and should receive guidance and training to expand their knowledge of this. This would make them more aware and willing to take into account EE when promoting and managing Structural and Cohesion Funds. The Court of Auditors also observe that important factors such as potential energy savings and investments are not always considered when designing and implementing EU funded programmes. Introducing a “one-stop shop” for assisting in the preparation of the renovation or construction of buildings could help tackle this barrier and assist building owners with applying for financial support. Supporting community-led energy efficiency projects: Community led energy projects allow for reduced financing costs, as people investing in their own energy saving or energy production projects do not expect the same high financial return as traditional investors do. Improving legislative frameworks for community led EE should be further developed, despite the limitations over a EU wide ‘one size fits all' model for doing so. There is however a lack of consensus over the EU’s role in this field, and as such the current focus should be directed on examples of national laws that promote development of community power. The 2030 Climate and Energy reform process should include consideration for more explicit promotion and support for community power, particularly through integration into relevant existing EU legislation. Bankwatch’s assessment of submitted NECPs by CEE countries reveals an overall lack of funding for promoting and enabling community led projects for EE. Although there are some mentions of such programs, these are only minor and do not contain detailed measures on how EU funds will be integrated into these.
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Response to Union renewable Financing mechanism

3 Jun 2020

The proposed RES Financing Mechanism has potential to make a positive contribution to reaching the EU’s 2030 renewable energy target only if it includes strong environmental, social and integrity safeguards and takes a long-term view of countries’ real sustainable potential. There is a danger of countries offering to host projects without taking into account whether they have enough sustainable renewable energy potential to reach 100 per cent renewable energy in the coming decades. In other words, short-term gains may result in mid-long-term inability to reach more ambitious EU renewable energy targets in a sustainable manner. Recommendation: Carry out an assessment of EU countries’ sustainable renewable energy potential (eg. excluding projects with impacts on Natura 2000 areas, excluding hydropower projects not in line with the Water Framework Directive etc.) and host countries’ offers assessed against their future ability to meet their own targets using only sustainable sources of renewable energy. Environmental and social safeguards and public participation are missing from the draft, and the sustainable investment taxonomy is mentioned only for private sector projects. Integrity safeguards are mentioned only in the preamble but not elaborated. There is a danger that this EU mechanism supports projects that later turn out to raise integrity issues or breach the EU environmental acquis. Our experience with the EIB shows that a presumption of legality does not stand up, even within the EU, and that input from the public is crucial in order to prevent noncompliance. Recommendation: Hold “late” tenders to ensure that projects have passed relevant permitting processes such as environmental impact assessments and appropriate assessments in a satisfactory manner. This will also improve the implementation rate. Recommendation: Use the sustainable investment taxonomy criteria as eligibility criteria to ensure that only the most sustainable projects receive funding through this EU mechanism - not only those funded by private sector contributions. Recommendation: Following the example of the Energy and Environment State Aid Guidelines, explicitly mention in the text of the Implementing Regulation the requirement to comply with sustainability provisions of EU legislation (e.g. that projects need to be in line with the Water Framework Directive (hydropower); the Environmental Impact Assessment Directive and Birds and Habitats Directives (all projects) and/or circular economy legislation and principles (all projects). Recommendation: Clarify how environmental, social and integrity due diligence will be carried out on the candidate projects. Explain how and at what stage the public will be able to raise any concerns about the use of EU funds to back the projects, bearing in mind the provisions of the Aarhus Convention. Community energy is not mentioned at all. Given their crucial role in sustainably increasing renewable energy capacity and in improving public support for energy transition, coupled with a lack of sufficient financing for their implementation in many countries of central and eastern Europe, prosumer and community energy projects deserve more attention in the draft. Recommendation: Specify how the Mechanism will ensure that small-scale and community energy projects will benefit from the mechanism and how the procedures will be made sufficiently simple to enable them to participate. One cost-effective and no-regret way to increase the share of renewable energy is to invest in demand-side energy savings in public and residential buildings, but this is not reflected in the draft. Recommendation: Consider opening up the mechanism to allow demand-side energy savings investments in public and residential buildings in host countries.
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Meeting with Valdis Dombrovskis (Executive Vice-President) and

24 Apr 2020 · Economic recovery, sustainable finance taxonomy, EIB energy lending policy, Just Transition Mechanism, Industrial Strategy, Integrating SDGs in the European Semester

Bankwatch Network demands exclusion of gas and nuclear

20 Apr 2020
Topic — The consultation defines which economic activities qualify as environmentally sustainable for investment purposes.
Message — Bankwatch urges excluding nuclear, waste incineration, and gas to protect environmental integrity. Including these activities would cause stakeholders to lose trust in the taxonomy's sustainability.12
Why — This ensures that EU financial resources are directed exclusively toward truly green projects.3
Impact — The gas and nuclear sectors would be denied the green label for financing.4
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Meeting with Thierry Breton (Commissioner) and Transport and Environment (European Federation for Transport and Environment) and

15 Apr 2020 · Priorities for the Coronavirus recovery

Response to Carbon Border Adjustment Mechanism

28 Mar 2020

Bankwatch strongly supports a carbon border tax for the electricity sector. The EU is not predicted to be a net importer of electricity in the coming years, but it does import electricity from, and exchange electricity with, countries on its borders such as Bosnia and Herzegovina, Serbia, Ukraine, Belarus and Russia, whose electricity sectors are heavily dependent on coal. For more details see: https://ember-climate.org/project/interconnectors-and-coal/ More interconnectors are in the pipeline, which could further increase this trend in the future. The Western Balkans and Ukraine are part of the Energy Community Treaty and are obliged to comply with the EU’s now superseded Large Combustion Plants Directive. However their power stations are far from compliant with this legislation, adding to the appalling air pollution problems in the countries, which also impact the EU. Serbia and Bosnia and Herzegovina even plan to build more new coal power plants, built by Chinese companies, financed by Chinese banks and not compliant with EU industrial emissions legislation or State aid rules, under the assumption that they can avoid paying carbon costs until they join the EU. (See https://bankwatch.org/wp-content/uploads/2019/12/China-Balkans-briefing_Dec-2019.pdf for details) Given that EU accession is not expected within the next few years at least, this is too long to wait. Action has to be taken now. The Energy Community Treaty Contracting Parties need to introduce a carbon price. Montenegro and Ukraine have already made some first steps, but there is little incentive for others to follow their steps, or for these countries to ensure that carbon prices are high enough to be a real deterrent, if they are also allowed to keep selling their electricity to the EU under the same conditions as now. In the electricity sector, a carbon border tax would encourage ETS countries to continue their phase-out of coal-based electricity. In non-ETS countries, if set at a level high enough to be a deterrent, a tax would help ensure that the life of power plants countries is not artificially prolonged and that new ones are clearly seen to be uneconomic. This way, it would implicitly address not only carbon emissions but also air pollution and other violations. The tax must also apply to Energy Community countries if they do not start to apply CO2 emissions pricing on their own at a level which serves as a real incentive to decarbonise. As these countries have access to the EU energy market, they need to comply with the same environmental standards, state aid rules, and carbon pricing in the energy sector. Failure to do so will distort the market, disadvantaging electricity generators in countries at the edge of the EU who have to face cheaper competition from more polluting plants. In addition, due to the EU’s increased efforts on climate, for countries planning to join the EU, it would be even harder to align with EU legislation in the future if work is not started on this now. Bankwatch supports the introduction of a carbon border tax in the electricity sector because it: - Encourages more countries to take ambitious climate measures - Can solve the problem of carbon leakage in the electricity sector - Removes unfair competition from non-compliant and highly polluting plants in countries neighbouring the EU - Can help to protect local economies by supporting electricity generators adhering to EU rules. - Fills in the gaps that the EU-ETS cannot fill, regarding trading with non-EU countries - Circumvents the EU’s failure so far to close legal loopholes in Energy Community countries that encourage new coal mines and power plants. The proceeds of any such tax must be used for a just and sustainable energy transition, and the tax must also mean an end to free ETS allowances for all sectors.
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

12 Mar 2020

CEE Bankwatch Network is the largest network of grassroots, environmental and human rights groups in central and eastern Europe, working on monitoring public finance institutions that are responsible for hundreds of billions of investments across the globe. A just transition, one that transforms our energy systems from dependence on polluting sources that damage human health and our planet into renewable, sustainable solutions, will have major environmental and social benefits, but is also almost sure to have major negative social impacts if sustainability criteria and planetary boundaries are not properly followed. While CEE Bankwatch Network welcomes the European Commission’s efforts to establish the Just Transition Fund (JTF), we advise that the Commission integrate the following two principles more thoroughly: 1. Bottom up approach to transition - transparency, ownership and efficiency 2. Decarbonisation of the transition and no lock-in of unsustainable practices Please see the full version in the attached PDF file.
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Meeting with Sofja Ribkina (Cabinet of Executive Vice-President Valdis Dombrovskis)

5 Feb 2020 · Sustainable Europe Investment Plan and Just Transition Mechanism

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and ClientEarth AISBL and

7 May 2019 · discussion on Struma Motorway, Bulgaria and Kresna Gorge case

Response to Common provisions on the ERDF, the ESF+, the CF, the EAFRD, the EMFF and AMIF, ISF and IBM

31 Jul 2018

Please find attached Bankwatch feedback on the CPR.
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Response to Legislative proposals for ERDF/CF, ETC (Interreg) and ECBC

30 Jul 2018

Please find Bankwatch's feedback attached.
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Meeting with Ann Mettler (Director-General Inspire, Debate, Engage and Accelerate Action) and Friends of the Earth Europe

18 Sept 2017 · Sustainable Development Goals

Meeting with Miguel Arias Cañete (Commissioner)

7 Jul 2017 · RENEWABLES IN PL & CONSUMERS' INVOLVEMENT

Meeting with Markus Schulte (Cabinet of Vice-President Günther Oettinger) and Climate Action Network Europe

20 Mar 2017 · EU budget

Meeting with Ioannis Latoudis (Cabinet of Commissioner Corina Crețu)

20 Mar 2017 · COHESION POLICY - NEXT MFF, etc.

Meeting with Miguel Gil Tertre (Cabinet of Vice-President Jyrki Katainen) and WWF European Policy Programme and Green Budget Europe AISBL

17 Mar 2016 · EU Semester

Meeting with Miguel Arias Cañete (Commissioner) and

17 Sept 2015 · Environment Council Preparation

Meeting with Miguel Arias Cañete (Commissioner) and

23 Jun 2015 · ETS review, Energy Union implementation and International Climate negotiations

Meeting with Paulina Dejmek Hack (Cabinet of President Jean-Claude Juncker) and Counter Balance

8 May 2015 · EFSI

Meeting with Frans Timmermans (First Vice-President) and Transport and Environment (European Federation for Transport and Environment) and

13 Feb 2015 · Meeting with Representatives of Green 10 on CWP 2015

Meeting with Corina Crețu (Commissioner)

27 Jan 2015 · CEE Bankwatch Network

Meeting with Miguel Arias Cañete (Commissioner) and

15 Jan 2015 · Follow-up to Lima and climate action diplomacy up to Paris / Energy Union (state of play)

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and Transport and Environment (European Federation for Transport and Environment) and

18 Dec 2014 · Energy Union

Meeting with Miguel Arias Cañete (Commissioner) and

13 Nov 2014 · Lima climate talks; climate and energy priorities