EREC, the European Renewable Energy Council, wrote to the Commission on the topic of reference plants. It wanted the Commission to allow renewable energy projects to scale the costs of a large conventional fossil plant to the size of the renewable energy demonstration, arguing that a marginal increase to the capacity of a planned conventional plant was a more realistic alternative investment than a stand-alone micro-scale fossil plant. EREC reasoned that this would allow renewable energy projects to present greater relevant costs.

The Commission replied that this would not be possible and pointed to applications for State Aid clearance brought by Member States where they had used gas-fired plants with capacities in the range 1, 5 and 20 MW for the reference investment.