DVF-Stellungnahme zur Änderung der Allgemeinen Gruppenfreistellungsverordnung AGVO in Bezug auf die Häfen (GBER Extension – second consultation)
DVF welcomes the Commission’s intention to clarify the application of state aid regulations in the ports and airports sector and to lower the administrative burden of notification requirements.
However, we believe the draft still needs significant improvement at important points.
Otherwise the GBER revision might have negative, far-reaching and unclear consequences for public investments in port-related transport infrastructures, especially with regard to seaports.
Questions we have relate to the definition of ports and ports infrastructure, the delineation of access infrastructure, the treatment of dragging, and the necessity to include provisions on concessions, rental and lease contracts.
The newly presented analytical grid for port infrastructure is helpful, but it leaves questions open, too. And most important: The analytical grid is not legally binding. The GBER itself has to provide for unambiguous definitions.