This article investigates the 2008 reform of the EU's environmental state aid guidelines, with an eye to determining the degree of external pressure and lobbying towards environmental state aid policies. What is found is a strikingly low level of external pressure on the policy field, not least on the part of the private sector. In fact, EU environmental state aid policy is largely the making of a few Commission officials, without much external interference. The article discusses possible reasons for this, and asks whether state aid policy-making might be marked less by clear and established stakeholder interests or stakeholders' utility maximizing, and more by stakeholders constrained by bounded rationality.