ERCST’s Response to the French State Aid Notification for New Nuclear Capacity

Author: Andrei Marcu

This submission was prepared by ERCST in response to the European Commission’s invitation to submit comments under Article 108(2) TFEU on France’s proposed state aid measure to support the construction and operation of six new nuclear reactors.

The four main arguments in support of SA.119469 include:

• Nuclear’s systemic value — dispatchable, low-carbon generation that complements renewables, reduces fossil fuel exposure, and strengthens European energy sovereignty through domestic value chains
• Market failure justifies public support — the risk profile of nuclear projects (high upfront costs, long construction periods, regulatory uncertainty) exceeds what private markets can absorb; CfDs, PPAs, and preferential financing conditions are therefore warranted
• EDF’s integrated model is industrially sound — combining construction, operation, and commercialisation enables economies of scale, safety standardisation, and preservation of engineering expertise
• Competitive safeguards are adequate — EDF’s market share is expected to decline over time; the requirement to commercialise 60% of supported production through open wholesale markets limits distortions of competition