A few months ago, Airborne Wind Europe issued a position paper outlining the role of innovative energy technologies in the context of the Clean Industrial Deal, presenting our expectations and key recommendations for its implementation. Today, with the publication of the Clean Industrial Deal and the Action Plan for Affordable Energy, the industry’s long-awaited proposals have arrived. We welcome a robust focus on decarbonisation, clean‐tech innovation and the recognition of circularity as a strategic priority to position the EU as a global leader in the circular economy.
While we commend these initiatives, it is crucial that all measures, including accelerated permitting processes, be implemented with innovative renewable energy technologies (iRETs) in mind. Accordingly, we offer the following detailed comments and recommendations to further enhance the framework and ensure that emerging technologies, particularly airborne wind energy (AWE), receive the targeted support necessary for their full deployment.
Focus on clean tech: We appreciate the Commission’s emphasis on the clean-tech sector as a critical driver of industrial transformation, competitiveness, and decarbonisation. AWE exemplifies this potential. Europe benefits from a robust ecosystem comprising approximately a dozen AWE technology developers and over 30 research institutes. Given that competitors such as China and the United States are actively integrating AWE into their national R&D plans, it is imperative that Europe safeguards its technological leadership and expertise.
Circularity: We welcome the Commission’s recognition of circularity as a strategic priority and its ambition to position the EU as a global leader in the circular economy. AWE is ideally suited to this vision, as it significantly reduces material input, lifecycle emissions and raw material dependence while strengthening European value creation and supply chains.
90% target for 2040: 90% target for 2040: We welcome the reference in the Clean Industrial Deal to the intermediate 2040 target of a 90% reduction in GHG emissions. We also welcome the inclusion of a new 32% electrification target by 2030, alongside the commitment to annually install 100 GW of renewable electricity capacity up to 2030. These targets are essential for delivering the 2040 ambition, but to fully support industrial decarbonization, we also need a clear and ambitious target for iRETs.
Action Plan for Affordable Energy: We endorse the Commission’s efforts to accelerate permitting for renewables through rapid legislative transposition, digitalisation, and enhanced reinforcement of national permitting authorities. We respectfully urge that these measures explicitly incorporate innovative renewable technologies, such as AWE. Moreover, the increased use of regulatory sandboxes for pioneering projects is recommended to facilitate the safe testing and refinement of permitting processes.
Industrial Decarbonisation Accelerator Act: We call for differentiation between general renewable energy deployment auctions and innovation-specific auctions (e.g., “pure-innovation auctions” as proposed in the NZIA) in public and private procurement. This distinction is essential to ensure a fair evaluation of novel technologies and to stimulate investments in solutions that drive decarbonisation and reinforce Europe’s industrial base. Pure innovation auctions should be technology-specific to ensure comparability of both criteria and tenders.
Funding: We welcome the Commission’s proposals, such as the Competitiveness and Innovation Funds and the dedicated Horizon Europe pilot call for fit-for-deployment projects, which prioritize projects with European added value and industrial decarbonisation. Nevertheless, we stress that innovative renewable technologies like AWE, which differ significantly from established solutions, require explicit recognition and tailored support. Accordingly, we urge that AWE be included in Horizon Europe, EIC programs, and the Innovation Fund, akin to the support already available for e.g. ocean energy.
Clean Industry State Aid Framework: We commend the proposal for a new Clean Industry State Aid Framework, which aims to enhance investment certainty through a five-year planning horizon for Member States. While the framework appropriately supports established technologies such as wind and solar, we insist that emerging technologies like AWE be explicitly incorporated. Such inclusion will signal robust investor confidence, elevate public awareness, and secure adequate manufacturing capacity for these innovative clean-tech solutions.
National Energy Climate Plans (NECPs): We agree that the NECPs are essential tools for ensuring EU target achievements and supporting strategic investment. In this regard, we encourage the European Commission to consider how Member States plan to support the deployment of innovative renewable technologies. A dedicated focus on innovation will help evolve NECPs into comprehensive strategic investment frameworks, thereby fostering investment predictability, consumer confidence, and market growth across both established and emerging clean technologies.
About Airborne Wind Europe
Airborne Wind Europe is the association of the European airborne wind energy industry, founded in 2018. It aims to help creating the political and regulatory framework for airborne wind energy in Europe and the member states. The association represents all European airborne wind energy system manufacturers as well as various research institutes and suppliers. In addition, more than 50 organisations along the supply chain are active world-wide.
Contact: Kristian Petrick, kristian.petrick@airbornewindeurope.org