Euroopan yhteistä etua koskevista tärkeistä hankkeista annetun tiedonannon tarkistus

21.12.2020

Euroopan komission kyselylomakkeelle kirjoitettu kommentti.

Suomen luonnonsuojeluliitto (The Finnish Association for Nature Conservation) is the biggest environmental non-governmental NGO in Finland.

We warmly welcome the update of “Important Projects in the Common European Interest” (IPCEI) Communication to fulfil also all new environmental targets, as the Green Deal, Climate change and “Do Not Harm” principle.

The IPCEIs have been rare, and the criteria should be very strict also in the future. Just now we are worried about possible hydrogen IPCEIs and their relation to EU environmental targets. It is wiser, better and safer to develop renewable energy (except hydropower and biomass, because of their other sustainability problems).

Ex ante evaluations and mid term monitoring are essential in IPCEIs. Transparency and public participation are needed, too.

SMEs are important and sometimes very flexible actors in innovations. However, we doubt how active they can be in IPCEIs. Perhaps more resources and know how is needed, at least at the beginning of these projects.

We are looking forward to following this revision process.

On behalf of SUOMEN LUONNONSUOJELULIITTO RY

Tapani Veistola
head of nature conservation

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