RGI Statement: ‘Do No Significant Harm’ Technical Guidance under the Social Climate Fund

RGI, with our members, provided feedback to the European Commission’s public consultation on the ‘Do No Significant Harm’ Technical Guidance for the Social Climate Fund. We strongly believe that this tool, if effectively designed and implemented, has the potential to accelerate the energy transition and scale up proven technologies that will not only bring significant benefits to end users, but also to the decarbonisation trajectory and the energy system at large. For this to happen, the application of the DNSH principle, in conjunction with further safeguards envisaged in the SCF Regulation (Regulation (EU) 2023/955 of the European Parliament and of the Council) and applicable EU law, should follow a robust, holistic and forward-looking approach.

In this context, we are convinced that loopholes need to be closed to phase out fossil fuels. Simultaneously, we advocate for the European Commission and Member States to adopt a holistic approach for system and long-term benefits and support the creation of an effective tool to address multiple crises in the EU long-term budget. To achieve these three goals, requires the European Union to:

• The European Commission and Member States should adopt a holistic approach, ensuring socio-economic and environmental safeguards align with EU climate and environmental goals. The DNSH principle should be a minimum requirement for systemic improvements.
• The Social Climate Plans and Fund should focus on decarbonisation solutions, prioritising renewables-based direct electrification to meet EU climate and energy targets for 2030, 2040, and 2050.
• Energy system planning should be optimised to avoid inefficiencies and support decarbonisation, with regulatory frameworks enabling citizen empowerment and reduced energy demand.
• The DNSH principle in Social Climate Plans should align with national and regional plans, leveraging synergies to support investments in electricity infrastructure.
• The 2027-2034 Multiannual Financial Framework should prioritise renewables-based electrification and nature-positive solutions, with the DNSH principle as an eligibility requirement to ensure coherent and effective implementation across Member States.

For a more detailed overview of RGI’s response to the European Commission’s public consultation on the ‘Do No Significant Harm’ Technical Guidance for the Social Climate Fund please download the full statement below.