Vastused Euroopa Komisjoni küsimustele

Suur-Ameerika 1 / Tallinn 10122 / 626 2802/ [email protected] / www.kliimaministeerium.ee/

Registrikood 70001231

Kaur Kajak

Rahandusministeerium

Teie 19.03.2024 nr 12.1-3/455-3

Meie 26.03.2024 nr 21-2/24/477-5

Vastused Euroopa Komisjoni küsimustele (riigiabi

teatis SA.112221)

Austatud hr Kajak

Saadame vastused Euroopa Komisjoni küsimustele seoses riigiabi teatisega „TCTF: support for

connection to the transmission and distribution networks of renewable electricity generating

installations in industrial sites“, mis registreeriti komisjonis 29.01.2024 numbriga

SA.112221(2024/N).

Lugupidamisega

(allkirjastatud digitaalselt)

Rein Vaks

Energeetikaosakonna juhataja

energeetika ja maavarade asekantsleri ülesannetes

Lisa: Vastused Euroopa Komisjoni küsimustele

Tauno Hilimon, 625 6476

[email protected]

Answers to the questions regarding SA.112221 (2024/N) – Estonia TCTF: Support for connection to

the transmission and distribution networks of renewable electricity generating installations in

industrial sites

1. You indicate in your electronic notification at par. 3.3 that the measure is open to all sectors while

Annex 1states on page 2 that the measure is targeted to the manufacturing sector. Could you please

clarify if the measure is open to all sectors or limited to the manufacturing sector?

Answer: The notified measure (support under TCTF) will be open for manufacturing sector (NACE rev

2, C Manufacturing) only to ensure that the companies which were affected the most by the war would

the ones applying for the support. In detail:

• Aid based on the Regulation of the Minister of Climate (Annex I) is already open to all

companies located in or near industrial areas in line with GBER and de minimis aid regulations:

o Commission Regulation (EU) No 651/2014 of 17 June 2014 declaring certain categories

of aid compatible with the internal market in application of Articles 107 and 108 of the

Treaty, article 48;

o COMMISSION REGULATION (EU) 2023/2831 of 13 December 2023 on the application

of Articles 107 and 108 of the Treaty on the Functioning of the European Union to de

minimis aid.

• Aid in line with TCTF is planned to be granted only for manufacturing sector (NACE rev 2, C

Manufacturing). Manufactring sector was focused on as it is the sector that was the most

affected by the war.

2. You submitted in Annex I p. 5 that 'the objective to help a wider group of enterprises influenced

by the crisis is unattainable'. Could you please provide more information on why the measure is

limited to the manufacturing sector, rather than open to all undertakings?

Answer: The measure is limited to manufacturing sector because is has been hit the hardest by the

effects of the war. Details about the effects can be seen in Annex I of the notification (please see pages

2-3). To underline the main aspects:

• Overall decrease of GDP;

• Decreasing national consumption and low demand from main trading parners (especially

Nordics). Export decreased 12,1% in November 2023;

• Industrial confidence indicator in Estonia was -20,6 in December 2023 while EU average was -

9,0;

• In November 2023 Estonian manufacturing production decreased by -5.8% YoY and industrial

production exports decreased 7.6% YoY. Production was 23% lower than in same month 2021.

Since end of 2022 ca 6000 jobs (5% of total sector workforce) has been lost in manufacturing

sector;

• Electricity and gas prices have surged from 2020 as yearly average spot market prices increased

from 33,68 €/MWh in 2020 to 192,82 €/MWh in 2022 and decreased to 90,79 €/MWh, peaking

again in 2024 January (average price in first 10 days is 188 €/MWh due to low temperatures).

3. You specify in Annex 1 at p. 8 that the estimated number of beneficiaries is up to 10 entrepreneurs.

Could you clarify whether beneficiaries have already been selected? If this is not the case, could you

clarify how will the beneficiaries be selected? In particular, please provide additional information as

to the assessment methodology that will be used to evaluate the project applications under the

scheme.

Answer: The beneficiaries have not been selected. This number has been drawn up taking into account

the budget of the measure (9,1 million euros) and the possible size of the subsidy (up to 2,25 million

euros per entrepreneur). When all the projects applying for aid would get maximum amount of subsidy

then only 4 projects can get it. According to our knowledge so far, the average project will be around 2

to 3 MW in which case it is probable that around 10 companies can get the aid. In case around 10

companies would be applying for the subsidy then the amount per project would be around 800 to 900

thousand euros.

Assessment methodology: There will be an open call for support. If the applicant and the application

fulfill the requirements set in sections 10 and 11 of Annex II, then aid will be granted. The aid will be

granted in order of the applications submitted until the budget is full.

4. You submit that beneficiaries are 'undertakings in difficulty' as defined in the Guidelines on State

aid for rescuing and restructuring non-financial undertakings in difficulty (OJ C 249, 31.7.2014, p. 1).

We understand the aid does not qualify as 'solvency support' under point 36 of the TCTF. Please

confirm. Please explain how you have determined that the aid is granted to undertakings in difficulty,

or if this is simply a possibility based on as of yet unknown beneficiaries.

Answer: We confirm that the aid does not qualify as „solvency support“ under point 36 of TCTF. The

criterium that company eligible for aid can be in difficulty is simply a possibility based on as of yet

unknown beneficiaries.

5. Regarding your confirmation in Annex 1 section II point 1, please refer to the maximum aid limit

stated in Point 61 a TCTF, which requires that the overall aid does not exceed EUR 2.25 million per

undertaking per MS at any given point in time. We understand this leads to a maximum capacity of

the supported connection to be approx. 7.4 MW assuming the maximum amount of aid granted per

MW. Please confirm or correct.

Answer: We confirm that the overall maximum aid amount per undertaking does not exceed EUR 2.25

million at any given point of time (as referred to in point 61 a of TCTF). Please see § 10(4)(51) of Annex

II. Another threshold foreseen in the measure is the maximum aid ceiling of 305 thousand euro per

MW – please see§ 9(1) of Annex II. This criterium ensures that recovery and resilience plan target to

achieve 28 MW of capacity will be met. When company has a project of 10 MW then maximum aid will

be 2,25 million euros. When the project is 5 MW then the maximum aid will be 5 MW x 305 000 € =

1,525 million euros.

6. Please confirm that the undertakings eligible for aid under this measure did not benefit from any

other aid under point 61 d) TCTF.

Answer: We confirm that the undertakings eligible for aid under this measure did not benefit from any

other aid under point 61 d) TCTF.

7. We understand you intend to determine that the undertakings selected under the scheme are

"affected by the crisis" as required under section 2.1 TCTF by using the criteria stated on page 7 of

annex 1.

"In order to define an entrepreneur who is affected by the crisis in Ukraine:

• the prices of applicant´s two main raw material prices must have increased at least 50

percent on average in 2022 compared to the average price of 2021,

• or the unit price of the energy he uses has increased 2022 average at least 50 percent

compared to 2021 average unit price. If the entrepreneur meets this condition, it is eligible

to apply. The mentioned criteria must be proved by the applicants with documentary

evidence.

The two main raw materials used are considered as two basic raw materials. Together they must

make up at least 20 percent of the sales revenue of the year preceding the submission of the

application, including one basic raw material can also make up more than 20 percent."

Answers: Yes, these are the criteria.

8. Please explain how you intend to handle potential applications where the above-mentioned

criterion on the raw material prices are fulfilled, but the sales prices and revenues of the undertaking

have increased much stronger?

Answers: The overall condition of the manufacturing sector and additional criteria (50 percent increase

of raw materials price or 50 percent increase of energy price) ensures that revenues of the companies

have been negatively affected for majority of the cases.

9. Please explain whether the investment into the renewable generation assets themselves will be

subject to any form of state support.

Answer: Under this subsidy scheme renewable generation assets can not receive state support.

Renewable generation assets can receive state support from other subsidy schemes. The eligible costs

under the current measure are different than the eligible costs under other subsidy schemes where

renewable generation assets can receive aid. In any case cumulation rules stipulated in point 59 of TCTF

will be followed.