EUTurbines Response to the Consultation on the Draft Clean Industrial Deal State Aid Framework (CISAF)
08 May 2025
EUTurbines welcomes the ambition of CISAF to strengthen industrial competitiveness and accelerate decarbonisation via improved state aid rules. Especially the suggested fast-track approval procedure for capacity mechanisms could efficiently support Member States in ensuring a reliable and stable electricity supply. However, in many parts the draft CISAF introduces unnecessary complexity and disadvantages or even excludes solutions and technologies that could help decrease energy costs.
We urge a simplified, technology-neutral framework that gives Member States the flexibility to deploy the most suitable decarbonisation pathways.
Key recommendations:
- Support Capacity Mechanisms that fit to the specific needs of Member States
Using a target model approach as fast-track procedure may not exclude the possibility to introduce diverging capacity mechanisms that better match the needs of some Member States. Also, the exclusive use of the EERA methodology and values risks to not reflect existing national specificities. - Allow the use of RFNBOs in electricity generation
Generating electricity from stored renewable fuels during periods of scarce renewable generation increases the reliability and stability of the electricity system. - Simplify the framework and ensure technology neutrality
Avoid binding references to external legislation (e.g. RFNBO Delegated Act, EU Taxonomy) that add complexity and limit flexibility. - Ensure broad eligibility for non-fossil flexibility solutions
Recognise the role of all technologies using non-fossil fuels, including renewable-gas-fired turbines. - Support industrial decarbonisation with more flexibility
Enable off-site production, flexible operation, and remove strict efficiency or fuel-type constraints. - Enable hydrogen-ready technologies
Consider infrastructure availability and avoid restrictive conditions that undermine the transition. - Expand manufacturing aid eligibility beyond the NZIA list
Include key technologies like hydrogen-ready turbines and avoid disproportionate administrative burdens.
