Technical support for RES policy development and implementation – simplification of permission andadministrative procedures for RES installations (RES Simplify) : final report.
Date: 2023-06-07
Institutions: Directorate-General for Energy
Subjects: EU energy policy, electrical energy, energy policy, energy production, energy supply, environmental protection, reduction of gas emissions, renewable energy, renewable resources, report, research and development, security of supply, solar energy, trans-European network, wind energy

Technical support for RES policy 
development and implementation – 
Simplification of permission and 
administrative procedures for RES 
installations (RES Simplify) 

Final report 

Written by eclareon, Oeko-Institut, WindEurope and SolarPower Europe  
April – 2023 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Directorate-General for Energy  
Directorate C — Green Transition and Energy System Integration 
Unit C.1 Renewables and Energy System Integration 

Contact: Vera Kissler 

E-mail:  Vera.KISSLER@ec.europa.eu 

European Commission 
B-1049 Brussels 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EUROPEAN COMMISSION 

Technical support for RES policy 
development and implementation – 
Simplification of permission and 
administrative procedures for RES 
installations (RES Simplify) 
Final report 

Directorate-General for Energy  

MJ-04-23-595-EN-N 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Manuscript completed in April 2023 

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This document has been prepared for the European Commission however it reflects the views only of the authors, and the 
European Commission is not liable for any consequence stemming from the reuse of this publication. More information on the 
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Print  
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ISBN 978-92-68-04200-7 
ISBN 978-92-68-04199-4 

doi:10.2833/38238 
doi:10.2833/894296 

MJ-04-23-595-EN-C 
MJ-04-23-595-EN-N 

Authors: Jurga Tallat-Kelpšaitė (eclareon), Robert Brückmann (eclareon), Jörn Banasiak (eclareon), Boris Valach (eclareon), 
Vlad  Surdea-Hernea  (eclareon),  John  Szabó  (eclareon),  Sunna  Kokkonen  (eclareon),  Dierk  Bauknecht  (Oeko-Institut), 
Dominik Seebach (Oeko-Institut), Moritz Vogel (Oeko-Institut), Guy Willems (WindEurope), Sabina Potestio (WindEurope), 
Dan Sokolov (SolarPower Europe), Jonathan Bonadio (SolarPower Europe), Naomi Chevillard (SolarPower Europe) 

Luxembourg: Publications Office of the European Union, 2023 

© European Union, 2023 

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Simplification of permission and administrative procedures for RES installations 

Table of Contents 

Abbreviations ...................................................................................................... 10 

List of Tables ....................................................................................................... 12 

List of Figures ...................................................................................................... 13 

Executive summary ............................................................................................. 16 

Introduction ....................................................................................................... 16 

Identified obstacles ........................................................................................... 16 

Process related barriers ............................................................................................. 16 
Conflicting public goods ............................................................................................. 17 
Third-party issues ...................................................................................................... 17 
Grid Issues ................................................................................................................. 17 

Best practice recommendations ........................................................................ 18 

Administrative communication and processes ........................................................... 20 
Guidance and best practice ....................................................................................... 20 
Central provision of information ................................................................................. 21 
Participation and acceptance measures .................................................................... 21 
Eased procedures ...................................................................................................... 22 
Clarified priority for RES in administrative processes ................................................ 22 
IT infrastructure .......................................................................................................... 23 
Additional technology specific recommendations ...................................................... 23 

Synthèse en langue française ............................................................................ 25 

Introduction ....................................................................................................... 25 

Obstacles identifiés ........................................................................................... 25 

Obstacles liés au processus administratif .................................................................. 25 
Biens publics conflictuels ........................................................................................... 26 
Problèmes liés aux tiers ............................................................................................. 26 
Problèmes liés au réseau .......................................................................................... 27 

Recommandations de bonnes pratiques .......................................................... 27 

Communication et processus administratifs .............................................................. 30 
Conseils et bonnes pratiques .................................................................................... 30 
Fourniture centralisée d'informations ......................................................................... 31 
Mesures de participation et d'acceptation .................................................................. 32 
Procédures simplifiées ............................................................................................... 32 
Clarification de la priorité accordée aux SER dans les processus administratifs ...... 33 
Infrastructure informatique ......................................................................................... 33 
Recommandations supplémentaires spécifiques à la technologie ............................ 34 

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Simplification of permission and administrative procedures for RES installations 

1. 

Introduction .................................................................................................. 36 

1.1. Objectives ................................................................................................... 36 

1.2. Short overview of methodology .................................................................. 38 

1.3. Structure of this report ................................................................................ 39 

2.  The mapping of permit granting and grid connection procedures and the 
development of performance indicators ........................................................... 41 

2.1. Objectives ................................................................................................... 41 

2.2. Methodology .............................................................................................. 41 

2.2.1. Research and drafting the National Reports .................................................... 41 
2.2.1.1.  Scope of examined processes ................................................................... 41 
2.2.1.2.  Geographic and technology scope ............................................................. 42 
2.2.1.3.  Research and validation of preliminary results .......................................... 44 
2.2.1.4.  Drafting the National Reports ..................................................................... 44 
2.2.2. Performance indicators .................................................................................... 45 
2.2.2.1.  Development of a preliminary set of performance indicators ..................... 45 

2.3. Key findings ............................................................................................... 46 

2.3.1. Onshore wind ................................................................................................... 46 
2.3.1.1. 
Introduction ................................................................................................ 46 
2.3.1.2.  Overview of the key process steps ............................................................ 49 
2.3.1.3.  Key barriers per process step .................................................................... 51 
2.3.1.3.1.  Process related issues ........................................................................... 51 
2.3.1.3.2.  Conflicting public goods ......................................................................... 53 
2.3.1.3.3.  Third-party issues ................................................................................... 55 
2.3.1.3.4.  Grid issues ............................................................................................. 57 
2.3.2. Offshore wind ................................................................................................... 58 
2.3.2.1. 
Introduction ................................................................................................ 58 
2.3.2.2.  Overview of the key process steps ............................................................ 59 
2.3.2.3.  Key barriers ................................................................................................ 59 
2.3.2.3.1.  Process related issues ........................................................................... 59 
2.3.2.3.2.  Conflicting public goods ......................................................................... 60 
2.3.2.3.3.  Third-party issues ................................................................................... 60 
2.3.2.3.4.  Grid issues ............................................................................................. 60 
2.3.3. Ground-mounted PV ........................................................................................ 61 
2.3.3.1. 
Introduction ................................................................................................ 61 
2.3.3.2.  Overview of the key process steps ............................................................ 62 
2.3.3.3.  Key barriers ................................................................................................ 63 
2.3.3.3.1.  Process related issues ........................................................................... 63 
2.3.3.3.2.  Conflicting public goods ......................................................................... 65 
2.3.3.3.3.  Third-party issues ................................................................................... 67 
2.3.3.3.4.  Grid issues ............................................................................................. 67 
2.3.4. Rooftop PV ...................................................................................................... 68 
2.3.4.1. 
Introduction ................................................................................................ 68 
2.3.4.2.  Overview of the key process steps ............................................................ 69 
2.3.4.3.  Key barriers ................................................................................................ 69 
2.3.4.3.1.  Process related issues ........................................................................... 69 
2.3.4.3.2.  Conflicting public goods ......................................................................... 70 
2.3.4.3.3.  Grid issues ............................................................................................. 70 
2.3.5. Hydropower ..................................................................................................... 70 
Introduction ................................................................................................ 70 
2.3.5.1. 

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Simplification of permission and administrative procedures for RES installations 

2.3.5.2.  Overview of the key process steps ............................................................ 72 
2.3.5.3.  Key barriers ................................................................................................ 73 
2.3.5.3.1.  Concession related issues ..................................................................... 74 
2.3.5.3.2.  Deterioration ban of the Water Framework Directive (WFD) .................. 75 
2.3.5.3.3.  Time-consuming and complex approval procedures.............................. 76 
2.3.5.3.4.  Repowering ............................................................................................ 77 
2.3.5.3.5.  Public opposition and resulting complaint procedures ........................... 78 
2.3.6. Geothermal ...................................................................................................... 78 
2.3.6.1. 
Introduction ................................................................................................ 78 
2.3.6.2.  Overview of the key process steps ............................................................ 79 
2.3.6.3.  Key barriers ................................................................................................ 79 
2.3.6.3.1.  Lack of access to information ................................................................. 80 
2.3.6.3.2. 
Incoherent legislation as legal basis to use the geothermal resource .... 80 
2.3.6.3.3.  Lack of appropriate land use planning ................................................... 80 
2.3.6.3.4.  Need for simple permitting for shallow geothermal ................................ 80 
2.3.6.3.5.  Complicated and lengthy licensing procedures for deep geothermal ..... 81 
2.3.6.3.6.  Harmonised guidance needed for permitting and EIA procedures ......... 82 
2.3.7. Solar thermal ................................................................................................... 82 
2.3.7.1. 
Introduction ................................................................................................ 82 
2.3.7.2.  Key barriers ................................................................................................ 83 
2.3.7.2.1.  Land use related issues ......................................................................... 84 
2.3.7.2.2.  Connection to district heating networks .................................................. 84 
2.3.7.2.3.  Seasonality issues ................................................................................. 85 
2.3.7.2.4.  Lack of long-term PPAs ......................................................................... 85 
2.3.8. Specific features aimed to ease administrative procedures ............................. 85 
2.3.8.1.  Simultaneous procedures .......................................................................... 86 
2.3.8.2.  One Stop Shop or a single contact point .................................................... 86 
2.3.8.3.  Application of “two plus one” and/ or “one plus one” rules ......................... 87 
2.3.8.4.  Simple notification procedure ..................................................................... 88 
2.3.8.5.  Pre-planning procedure .............................................................................. 89 
2.3.8.6.  Pre-application consultations ..................................................................... 90 
2.3.8.7.  Project acceptance measures .................................................................... 90 
2.3.8.8.  Measures to streamline litigation by third parties ....................................... 91 
2.3.8.9.  Summary .................................................................................................... 92 

3.  Monitoring of the Member States based on the performance indicators 93 

3.1. Methodology ............................................................................................... 93 

3.2. Key findings on performance indicators ..................................................... 94 

3.2.1. PV .................................................................................................................... 95 
3.2.2. Onshore wind ................................................................................................. 101 

4.  Dissemination and promotion of best practice ....................................... 108 

4.1. Objective .................................................................................................. 108 

4.2. Methodology ............................................................................................ 108 

4.3. Stakeholder engagement activities .......................................................... 109 

4.4. Key findings of dissemination activities .................................................... 112 

4.4.1. Brief summary ................................................................................................ 112 
4.4.2. Takeaways ..................................................................................................... 114 

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Simplification of permission and administrative procedures for RES installations 

5.  Monitoring  the  implementation  of  permit  granting  procedures  following 
the transposition of RED II ............................................................................... 117 

5.1. Methodology ............................................................................................. 117 

5.2. Findings of Member State monitoring ...................................................... 118 

5.2.1. One Stop Shop and digitalisation................................................................... 118 
5.2.2. Deadlines for permit granting ......................................................................... 119 
5.2.3. Repowering renewable energy installations .................................................. 120 
5.2.4. Renewable energy installations on artificial structures .................................. 121 
5.2.5. Simple notification for small-scale PV ............................................................ 121 

5.3. Additional measures ................................................................................ 122 

5.3.1. Overriding public interest principle ................................................................. 122 
5.3.2. Identification of suitable areas ....................................................................... 123 
5.3.3. Positive silence for renewable energy projects .............................................. 124 

6.  Recommendations and best practices in permitting procedures .......... 126 

6.1. Methodology ............................................................................................. 126 

6.2. Administrative communication and processes ......................................... 130 

6.2.1. Use of e-communication, including a mechanism for monitoring project 
progress ................................................................................................................... 130 
6.2.2. One Stop Shop / consolidation into one single application process .............. 132 
6.2.3. Clear roles and processes ............................................................................. 134 

6.3. Guidance and best practice ..................................................................... 136 

6.3.1. EU guidance document on implementation of relevant regulation provisions in 
arts. 15, 16 RED and art. 8 IEMD ............................................................................ 136 
6.3.2. Public provision of guidelines and documentation templates on the national 
level for authorities, project developers and stakeholders ....................................... 137 
6.3.3. Cooperative monitoring mechanism for the identification and removal of 
regulatory barriers .................................................................................................... 138 

6.4. Central provision of information ............................................................... 140 

6.4.1. Central independent information platform on regulation, processes, projects, 
participation ............................................................................................................. 140 
6.4.2. Online (GIS) database / maps including administrative restrictions and other 
relevant parameters ................................................................................................. 141 
6.4.3. Environmental preassessment by authorities / centralisation and publication of 
environmental data and assessments ..................................................................... 143 

6.5. Participation and acceptance ................................................................... 145 

6.5.1. Financial participation of affected municipalities ............................................ 145 
6.5.2. Early engagement in local information, dissemination, and discussion ......... 148 
6.5.3. Project independent moderator for stakeholder participation and problem 
resolution ................................................................................................................. 150 

6.6. Eased procedures .................................................................................... 153 

6.6.1. Eased procedures for the repowering of existing power plants ..................... 153 
6.6.2. Eased procedures for RES self-supply and small-scale RES ........................ 154 

6.7. Clarified priority for RES in administrative processes .............................. 156 

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Simplification of permission and administrative procedures for RES installations 

6.7.1. Political backing of RES: Integrated planning system from national to local 
level ......................................................................................................................... 157 
6.7.2. Define RES as public interest ........................................................................ 158 
6.7.3. Ensure that responsible authorities are fit for purpose .................................. 159 

6.8. Technology specific best practice ............................................................ 160 

6.8.1. Wind ............................................................................................................... 161 
6.8.2. Additional specifics for offshore wind ............................................................. 163 
6.8.3. Solar .............................................................................................................. 163 
6.8.4. Small hydropower .......................................................................................... 164 
6.8.5. Geothermal .................................................................................................... 165 
6.8.6. Solar thermal ................................................................................................. 167 

7.  Outline for the optimised processes and supporting IT infrastructure that 
are compliant with RED II ................................................................................. 169 

7.1. Objective and methodology ...................................................................... 169 

7.2. Relevance of best practice recommendations for individual steps of an 
optimised permission process ......................................................................... 170 

7.2.1. Introduction and general recommendations ................................................... 170 
7.2.2. Site selection ................................................................................................. 172 
7.2.3. Electricity production license.......................................................................... 173 
7.2.4. Pre-application process ................................................................................. 174 
7.2.5. Administrative authorisation process ............................................................. 175 
7.2.6. Grid connection permit process ..................................................................... 176 
7.2.7. Corporate legal-fiscal processes.................................................................... 178 

7.3. Relevance of best practice recommendations for an optimised 
implementation of RED II key requirements .................................................... 178 

7.4. IT infrastructure ........................................................................................ 182 

8.  Conclusions ................................................................................................ 185 

Annex ................................................................................................................. 187 

References ......................................................................................................... 188 

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Simplification of permission and administrative procedures for RES installations 

Abbreviations  

Acronym  Full name  

AESA 

APREN 

AT 

BE 

BG 

BSH 

CHP 

CO2 

CY 

CZ 

DE 

DGAC 

DGEG 

DHS 

DK 

DKK 

DREAL 

DSO 

ECJ 

EDF 

EE 

EEA 

EED 

Agencia Estatal de Seguridad Aérea – Spanish Aviation Safety Agency 

Associação Portuguesa de Energias Renováveis – Portuguese Renewable Energy Association 

Austria  

Belgium 

Bulgaria 

Bundesamt für Seeschifffahrt und Hydrographie - German Maritime Agency 

Combined heat and power 

Carbon dioxide 

Cyprus 

Czechia 

Germany  

La Direction générale de l’Aviation civile - French Civil Aviation Authority 

Direção-Geral de Energia e Geologia - Portuguese Directorate-General of Energy and Geology 

District heating system  

Denmark 

Danish krone 

Direction régionale de l'Environnement, de l'Aménagement et du Logement - French Regional 
Directorate for the Environment, Planning and Housing 

Distribution system operator 

European Court of Justice 

Electricité de France  

Estonia 

European Economic Area 

Energy Efficiency Directive 

EGEC 

European Geothermal Energy Council 

EIA 

EIS 

ERO 

ES 

EU 

EUR 

FEP  

FI 

FR 

GIS 

GR 

Environmental impact assessment 

Environmental impact statement 

Polish Energy Regulatory Office 

Spain 

European Union 

Euro 

Flächenentwicklungsplan - Area development plan  

Finland 

France 

Geoinformation system(s) 

Greece 

GSHP 

Ground source heat pump 

HR 

HU 

Croatia 

Hungary 

10 

 
 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

IE 

IEMD 

INES 

IT 

IWEA 

LCA 

LT 

LU 

LV 

Mio 

MS 

MT 

Ireland 

Internal Electricity Market Directive  

Information system on Sensitive Spaces in Environmental Impact Assessments 

Italy 

Irish Wind Energy Association  

Life Cycle Assessment  

Lithuania 

Luxembourg 

Latvia 

Million 

Member State 

Malta 

NACE 

Nomenclature statistique des activités économiques dans la Communauté européenne - Statistical 
Classification of Economic Activities in the European Community 

NECP 

National Energy and Climate Plan 

NIMBY  

Not in my backyard  

NGO 

NL 

NVE 

OSS 

PI 

PL 

PPA 

PT 

PV 

RED  

RED II 

RES 

RES-E 

RO 

SE 

SEIA 

SHIP 

SI 

SK 

Non-governmental organisation 

The Netherlands  

Norges vassdrags- og energidirektorat - Norwegian Water Resources and Energy Directorate 

One Stop Shop 

Performance indicator 

Poland 

Power purchase agreement 

Portugal 

Photovoltaic  

Renewable Energy Directive  

(recast) Renewable Energy Directive  

Renewable energy sources 

Electricity generated from renewable energy sources  

Romania 

Sweden 

Strategic environmental impact assessment 

systems for industrial processes 

Slovenia 

Slovakia 

SSTES 

Seasonal solar thermal storage 

TSO  

UNEF 

UTES 

WEA 

WFD 

Transmission system operator  

Unión Española Fotovoltaica (Spanish Photovoltaic Union) 

Underground thermal energy storage 

Wind Energy Ireland 

Water Framework Directive  

11 

 
 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

List of Tables  

Table 2-1: Technologies covered for the mapping of permitting procedures in the 27 
EU Member States, Iceland and Norway (Source: RES Simplify) ................. 43 

Table  2-2:  Overview  of  performance  indicators  for  RES-E  permitting  procedures 
(Source: RES Simplify) .................................................................................. 46 

Table 2-3: Concessions for hydropower in European countries (Morgan, 2021). . 74 

Table 3-1: Overview over responses received on the performance indicator “overall 
efficiency  of  permission  process”  (selection  list  for  optional  answers:  “High 
efficiency (less time than the RED II limits)”; “Satisfactory efficiency (within the 
time  of  the  RED  II  limits)”;  “Moderate  efficiency  (more  time  than  the  RED  II 
limits)”; “Poor efficiency (considerably more time than the RED II limits)”; “No 
answer”) ........................................................................................................ 95 

Table 4-1: Implemented stakeholder engagement activities under the RES Simplify 
project ........................................................................................................... 95 

Table 7-1: Overview over specific key requirements from the RED II (art. 15) with 
respect 
to  admission  procedures  and  best  practice  recommendations 
supporting the respective RED II requirements ........................................... 178 

Table 7-2: Overview over specific key requirements from the RED II (art. 16) with 
respect 
to  admission  procedures  and  best  practice  recommendations 
supporting the respective RED II requirements ........................................... 180 

Table 7-3: Overview over specific key requirements from the RED II (art. 17) with 
respect 
to  admission  procedures  and  best  practice  recommendations 
supporting the respective RED II requirements ........................................... 182 

12 

 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

List of Figures  

Figure  0-1:  Overview  of  best  practice  and  further  recommendations  to  enhance 
permission procedures .................................................................................. 19 

Figure  0-2:  Overview  of  additional  technology-specific  best  practice  and  further 
recommendations to enhance permission procedures .................................. 20 

Figure 1-1: Overview of an impact of administrative barriers on RES technologies, 
based on REveal database ........................................................................... 37 

Figure 1-2:  Task structure of the RES Simplify project (Source: RES Simplify) .. 40 

Figure 2-1: Methodology for the research (Source: RES Simplify) ....................... 41 

Figure  2-2:  Share  of  technologies  in  2020–2030  RES-E  deployment,  based  on 
NECPs .......................................................................................................... 43 

Figure 2-3: National targets for wind power development (Source: NECP) .......... 47 

Figure  2-4:  Development  of  wind  power  capacities  2009-2019 

(Source: 
EurObserv’ER & eclareon) ............................................................................ 47 

Figure  2-5:  Installed  wind  capacities  across  EU  MS  2009-2019  (Source: 
EurObserv’ER & eclareon) ............................................................................ 48 

Figure  2-6:  Overview  of  share  of  administrative  &  grid  issues  (Source:  REveal 
database) ...................................................................................................... 49 

Figure  2-7:  Traffic  light  assessment  of  project  implementation  process  steps  for 
onshore wind (Source: RES Simplify) ........................................................... 50 

Figure  2-8:  Overview  of  process-related  issues  for  onshore  wind  (Source:  RES 
Simplify) ........................................................................................................ 52 

Figure 2-9: Overview of issues concerning conflicting public goods for onshore wind 
(Source: RES Simplify) .................................................................................. 54 

Figure 2-10: Overview of third-party issues for wind onshore (Source: RES Simplify)
 ...................................................................................................................... 56 

Figure  2-11:  Overview  of  process-related  issues  for  wind  onshore  (Source:  RES 
Simplify) ........................................................................................................ 57 

Figure  2-12:  Traffic  light  assessment  of  project  implementation  process  steps  for 
offshore wind (Source: RES Simplify) ........................................................... 59 

Figure 2-13: National targets for solar power development (Source: NECP) ....... 61 

13 

 
 
 
Simplification of permission and administrative procedures for RES installations 

Figure  2-14:  Development  of  solar  PV  capacities  2009-2019 

(Source: 
EurObserv’ER & eclareon) ............................................................................ 62 

Figure  2-15:  Traffic  light  assessment  of  project  implementation  process  steps  for 
ground-mounted PV (Source: RES Simplify) ................................................. 62 

Figure 2-16: Overview of process-related issues for ground-mounted PV (Source: 
RES Simplify) ................................................................................................ 64 

Figure  2-17:  Overview  of  issues  related  to  conflicting  public  goods  for  ground-
mounted PV (Source: RES Simplify) ............................................................. 66 

Figure 2-18: Overview of grid issues for ground-mounted PV (Source: RES Simplify)
 ...................................................................................................................... 67 

Figure  2-19:  Traffic  light  assessment  of  project  implementation  process  steps  for 
rooftop PV (Source: RES Simplify) ................................................................ 69 

Figure 2-20: Evolution of yearly production and installed capacity of hydropower in 
Europe since 2005 (Source: Hydropower-Europe, 2021; Hydropower & Dams 
World Atlas 2020) .......................................................................................... 70 

Figure  2-21:  Generation  and  extension  potential  of  hydropower  in  the  European 
countries  (Source:  Hydropower-Europe,  2021;  Hydropower  &  Dams  World 
Atlas 2020) .................................................................................................... 71 

Figure 2-22: National targets for hydropower development (Source: NECP) ....... 72 

Figure  2-23:  Traffic  light  assessment  of  project  implementation  process  steps  for 
small hydropower (Source: RES Simplify) ..................................................... 73 

Figure 2-24: Shares of the European solar thermal market (newly installed capacity); 
Solarthermalworld.org, 2020 ......................................................................... 83 

Figure  2-25:  Specific  features  to  ease  administrative  procedures  in  the  27  EU 
Member States .............................................................................................. 86 

Figure 3-1: Headline of the RES Simplify survey and exemplary question ........... 93 

Figure  3-2:  Indicative  results  of  overall  perceived  efficiency  of  PV  permitting 
processes (n = 24) in European Member States ........................................... 96 

Figure  3-3:  Indicative  results  of  overall  perceived  efficiency  of  PV  permitting 
processes  (n  =  24)  and  possibilities  for  stakeholder  participation  (n  =  22)  in 
European Member States ............................................................................. 97 

Figure  3-4:  Indicative  results  of  overall  perceived  efficiency  of  PV  permitting 
processes (n = 24) and average process duration (n = 39) in European Member 
States ............................................................................................................ 98 

Figure 3-5: Overall perceived effectiveness of PV permitting procedures (n = 26) in 
European Member States ............................................................................. 99 

14 

 
 
Simplification of permission and administrative procedures for RES installations 

Figure  3-6:  Overall  perceived  effectiveness  of  PV  permitting  procedures  (n  =  26) 
and project approval rate (n = 44) in European Member States .................. 100 

Figure 3-7: Deployment of PV in 2017, 2018 and 2019 in relation to linear target-
compliant  trajectory  to  reach  the  2030  PV  capacity  goals  defined  in  the 
Integrated National Energy and Climate Plans (NECPs) ............................ 101 

Figure  3-8:Indicative  results  of  overall  perceived  efficiency  of  onshore  wind 
permitting processes (n = 23) in European Member States and the UK ..... 102 

Figure  3-9:  Indicative  results  of  overall  perceived  efficiency  of  onshore  wind 
permitting processes (n = 23) and possibilities for stakeholder participation (n = 
21) in European Member States and the UK ............................................... 103 

Figure  3-10:  Indicative  results  of  overall  perceived  efficiency  of  onshore  wind 
permitting  processes  (n  =  23)  and  average  process  duration  (n  =  35)  in 
European Member States ........................................................................... 104 

Figure 3-11: Overall perceived effectiveness of onshore wind permitting procedures 
(n = 23) in European Member States and the UK ....................................... 105 

Figure 3-12: Overall perceived effectiveness of onshore wind permitting procedures 
(n = 23) and project approval rate (n = 28) in European Member States and the 
UK ............................................................................................................... 106 

Figure  3-13:  Deployment  of  wind  onshore  in  2017,  2018  and  2019  in  relation  to 
linear target-compliant trajectory to reach the 2030 wind capacity goals defined 
in the Integrated National Energy and Climate Plans (NECPs) ................... 107 

Figure  6-1:  Screenshot  of  an  exemplary  miro  board  that  was  used  during  the 
stakeholder workshops ................................................................................ 128 

Figure  6-2:  Overview  over  general  best  practice  recommendations  in  order  to 
enhance permission procedures ................................................................. 130 

Figure  6-3:  Overview  over  additional 

technology-specific  best  practice 
recommendations ........................................................................................ 130 

Figure 6-4: Overview over prioritisation of different good practice recommendations 
by consulted stakeholders in the technology-specific workshops ................ 161 

Figure 7-1: Overview over relevant process steps for admission procedures .... 170 

15 

 
 
 
Simplification of permission and administrative procedures for RES installations 

Executive summary  

Introduction  

EU  Member  States  have  introduced  ambitious  targets  for  the  deployment  of  renewable 
energy installations. They have chosen to rely on wind and PV to meet these targets in the 
power sector, both of which have seen growth in most countries. However, most Member 
States did not constantly deploy renewable energy technologies but rather in a back-and-
forth manner in the past ten years leading a number of markets to underperform compared 
to their potential.  

The main reason for the underperformance of renewables were non-technical barriers, such 
as the lack of business cases, weak support schemes, market entry barriers, administrative 
obstacles and grid related issues. In the past years, administrative (and grid) obstacles have 
become an increasingly important and pressing matter. Already today, administrative and 
grid issues make up about 46% of all identified barriers and this is expected to rise in the 
future.  For  some  technologies,  such  as  wind  power  and  PV,  a  trend  is  emerging  where 
administrative  barriers  become  even  more  crucial  than  policy  barriers  related  to  support 
schemes. Business cases are less dependent on support schemes, as the production costs 
of the technologies decline and corporate off-takers enter the market by signing corporate 
power purchase agreements (PPAs). As these market shifts occur, other barriers such as 
administrative barriers become more visible and relevant. For this reason, the findings and 
recommendations below are of particular importance.  

Identified obstacles 

The  Consortium  structures  the  obstacles  it  identified  in  the  European-wide  mapping 
research conducted in the period from November 2020 until July 2021 as follows: 

Process related barriers 

The  most  common  barriers  related  to  the  administrative  process  for  renewable  energy 
projects are bureaucratic burdens, non-transparent processes, a lack of legal coherence as 
well  as  an  incomplete  and  vague  framework  and  guidelines  that  lead  to  different 
interpretations of existing legislation by the competent authorities.  

In some countries, the lack of adequate spatial planning is a particularly severe issue. This 
can  manifest  either  because  spatial  plans  do  not  designate  land  for  renewable  energy 
projects and therefore developers need to change for what the land can be used, which 
takes a substantial amount of time and extends the duration of the entire project. The other 
key issue is when authorities use zoning to prohibit the deployment of certain technologies, 
such as wind power. Distance restrictions are a particularly severe barrier which make the 
deployment of wind power almost impossible in certain regions. Finally, if the responsible 
authorities  design  spatial  plans  insufficiently,  stakeholders  who  intend  to  prevent  the 
planned projects can impede them by legally contesting the overlying spatial plans. 

Another wide-spread barrier is a lack of experienced staff. The problem is either that there 
are not enough public clerks to process applications and/or the staff in question lacks the 
necessary  experience  or  technical  skills  to  execute  these  tacks.  The  latter  is  a  larger 
problem in regions that implemented less renewable energy projects. 

A  further  issue  is  that  most  EU  countries  have  not  digitalised  permitting;  therefore, 
applications still require a lot of paperwork. 

16 

 
 
 
Simplification of permission and administrative procedures for RES installations 

The lack of simplified procedures for repowering is another obstacle mostly in the case of 
onshore wind and hydropower projects. Repowering these technologies, even with minor 
changes,  is  subject  to  the  same  extensive  approval  procedures  as  developing  new 
installations in almost all Member States.  

Conflicting public goods  

Conflicting  public  goods  are  the  second  main  obstacle  for  the  deployment  of  renewable 
installations. This is particularly the case for wind power, geothermal power and hydropower 
as well as solar PV. 

The  most  prominent  conflicting  public  good  related  issues  are  conflicting  environmental 
regulations  (biodiversity  and  protection  of  endangered  species  and  protection  of  water 
bodies), land use conflicts and military/ air defence issues. Military/ air defence issues are 
relevant for wind power projects, but are mainly an issue in North-Eastern Europe. In the 
case  of  hydropower  and  geothermal,  problems  stem  from  conflicts  with  the  Water 
Framework Directive. Moreover, these conflicts can ensue with environmental groups and 
individual actors but also with public authorities at different levels. 

Industry  stakeholders  generally  acknowledge  the  value  of  the  above-mentioned  public 
goods. Their criticism is directed at the processes which balance public goods. This is also 
the starting point for the recommendations of the Consortium, as described below. 

Third-party issues 

Third-party issues refer to barriers that are related to the lack of support from policy decision 
makers  or  ostentatious  opposition  from  public  or  private  institutions,  or  public  itself.  The 
latter’s resistance is frequently directed at specific renewable energy projects, but in certain 
regions or Member States this can target renewable deployment in general.  

The motivation for such opposition varies on a broad scale. By and large, one can identify 
three motives for resistance: (i) individual (and often well-founded) opposition by particularly 
affected groups of people (for example neighbours or environmental groups with a specific 
concern), (ii) commercially interested groups whose protests are mainly related to financial 
gains, (iii) organised groups of protesters who oppose certain technologies or renewable 
energies in general. These groups are usually quite small, but disproportionally loud and 
can therefore, to some extent, steer public opinion.  

Third-party issues can lead to conflicts in court as well. In such cases, overloaded judicial 
structures can aggravate these barriers, especially since art. 16 (7) RED II does not take 
into account the delays due to judicial proceedings when instituting specific deadlines for 
administrative processes.  

Grid Issues 

Issues  related  to  grid  connections  and  operation  procedures  are  less  prevalent  than 
administrative  issues.  Still,  they  can  have  a  severe  impact  and  halt  overall  renewable 
energy deployment in some Member States.  

The main grid connection issues very often result from inadequate grid capacities, which 
prompt discussions and negotiations over how one can connect to the grid and at what cost. 
These lead to project delays. 

Another challenge to renewable energy deployment stems from conflicts with distribution 
and transmission grid operators over the interpretation of technical regulations, the access 
to data or the distribution of connection costs.  

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Simplification of permission and administrative procedures for RES installations 

The solar thermal industry is also confronted with certain obstacles when it seeks to connect 
installations  to  district  heating  networks.  These  barriers  are  primarily  due  to  unclear 
regulations on how to connect, leaving the operators of district heating systems room for 
interpretation and discretion. Another issue for heat based renewable sources is that the 
heat they produce cannot be transported over longer distances. Therefore, they are less 
flexible in terms of where they can connect to the grid, making connection issues even more 
pressing.  

Best practice recommendations 

Based  on  the  desktop  research  and  intense  discussions  with  stakeholders  to  map  the 
Europe-wide  processes  and  obstacles  impeding  the  diffusion  of  renewables,  the 
Consortium  developed  a  set  of  recommendations  based  on  best  practices.  These  are 
broadly  applicable  to  address  major  administrative  barriers,  underpinning  effective  and 
efficient  RES  installation  permitting.  This  set  of  recommendations  is  also  considered 
appropriate  to  provide  guidance  and  support  for  Member  States  when  implementing 
requirements stipulated by arts. 15, 16 and 17 RED II. 

We group recommendations into the following six categories: 1 

•  Administrative communication and processes, 
•  Guidance and best practice, 
•  Central provision of information, 
•  Participation and acceptance measures, 
•  Eased procedures, 
•  Clarified priority for RES in administrative processes, 
• 

IT infrastructure. 

Furthermore, 
recommendations. 

research  underpins  additional 

technology-specific  best  practice 

An overview of the given recommendations is provided in Figure 0-1 and in Figure 0-2. 

The individual recommendations are further outlined below. 

1 Many of the best practice recommendations are not designed to address a single barrier type described above, but can help 
overcome several. Therefore, best practice recommendations do not necessarily follow the grouping outlined above. 

18 

 
 
 
 
Simplification of permission and administrative procedures for RES installations 

Administrative 
communication and 
processes

Use of e-
communication, 
including monitoring 
of progress

One Stop Shop

Clear roles and 
processes

Guidance and best 
practice

Central provision of 
information

EU guidance 
document for MS

Central independent 
information platform

Public provision of 
guidelines and 
templates on national 
level 

Monitoring 
mechanism for 
identification and 
removal of barriers

Onine (GIS) 
database/maps

Central environmental 
information: pre-
assessment and 
provision of 
information

Clarified priority for 
RES in administrative 
processes

Political backing of 
RES, incl. 
local/regional 
planning

Participation and 
acceptance measures

Eased procedures

Enhance participation 
of citizens

for repowering of 
existing plants

Financial local 
participation

for RES self-supply 
and small scale RES

Define RES as public 
interest

Ensure that 
authorities are fit for 
purpose

Early engagement

Independent 
facilitation of 
stakeholder 
consultation and 
participation

Conflcit resolution 
mechanisms

Figure 0-1: Overview of best practice and further recommendations to enhance permission procedures 

19 

 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

Wind

Hydro

Geothermal

Solarthermal

Activities to 
reduce military 
and aeronautical 
conflicts

Adaptation of the 
Water Framework 
Directive

Delegated Act on 
Geothermal 
Energy

RES priority 
access also for 
heating grids

Priorisation of 
suitable areas for 
heat use 

Figure 0-2: Overview of additional technology-specific best practice and further recommendations to enhance 
permission procedures 

Administrative communication and processes 

Use  of  e-communication,  including  a  mechanism  for  monitoring  project  progress: 
Digitalisation eases procedures for applicants and authorities alike. Officials can sort, store 
and  review  digital  documents  easily,  and  share  them  between  the  parties  involved.  This 
would allow applicants to see in what stage their application currently is. This accelerates 
the permitting process and provides transparency.  

One Stop Shop / consolidation into one single application process: Applicants can contact 
a  One  Stop  Shop  (OSS)  to  obtain  all  permissions  for  their  project.  That  OSS  can  either 
provide permissions or act as a contact point to facilitate the entire process, as defined in 
art. 16 (1) RED II. Depending on technology and size, the OSS can be either technology-
specific  and/or  have  limited  regional  competences.  In  any  case,  it  should  be  clear  for  a 
project developer to know which OSS it must approach. OSS should be introduced as an 
option  for  applicants,  allowing  them  alternatively  to  directly  contact individual  authorities. 
This way applicants can benefit from their own experience and personal contacts.  

Clear  roles  and  processes:  Project  developers,  responsible  authorities  and  other 
if  procedures  and  respective 
stakeholders  can  only  provide  permits  smoothly, 
responsibilities are clearly defined and transparent to all parties involved. Amongst others, 
the definition of the process should include a clear sequential description of the application 
process,  individual  responsibilities,  an  overview  of  required  documentation,  and  clearly 
defined deadlines for each step. 

Guidance and best practice 

EU guidance document on implementation of relevant regulation provisions in arts. 15, 16 
RED  and  art.  8  IEMD:  Member  States  have  to  interpret  and  further  specify  the  different 
requirements which are imposed by both the recast Renewable Energy Directive (RED II) 
and  the  IEMD  (Internal  Electricity  Market  Directive)  to  provide  an  appropriate  regulatory 
framework for RES deployment. Additional EU-wide guidance can support Member States 
to  find  regulatory  solutions  which  fit  their  specific  needs.  This  also  enhances  the 
harmonisation  of  rules  and  regulations,  reducing  the  barriers  developers  face  when 
undertaking projects in other EU countries. 

Public  provision  of  guidelines  and  documentation  templates  on  the  national  level  for 
authorities,  project  developers  and  stakeholders:  Guidelines 
for  authorities  and 
stakeholders act as a helping hand when it comes to the realisation of renewable projects. 
They inform and describe the RES-E permitting process and thus increase expertise and 

20 

 
 
 
Simplification of permission and administrative procedures for RES installations 

knowledge amongst all parties involved. Stakeholders can follow a clear cook-book recipe 
and have direct access to the standard ingredients (templates for all application documents 
etc.) they have to use during project permitting.  

Cooperative monitoring mechanism for the identification and removal of regulatory barriers: 
Authorities,  project  developers  and  other  stakeholder  should  cooperate  in  a  formalised 
process  to  identify  regulatory  barriers  for  RES  installations  and  develop  appropriate 
solutions. This can be systematically supported by IT infrastructure which processes and 
monitors applications. Structured monitoring helps identify typical patterns and those steps 
which  are  lengthy  or  ineffective.  A  structured  analysis  of  the  performance  of  permission 
procedures should be enhanced by EU-wide reporting obligations. This would focus on the 
efficiency and effectiveness of RES permitting processes in Member States.  

Central provision of information 

Central independent information platform on regulation, processes, projects, participation: 
A central independent information platform on the installation of new RES plants could be 
an appropriate and reliable source of information for all parties involved in the planning and 
permitting of new plants. The proposed information platform could target all parties involved, 
including authorities, project developers and external stakeholders. Thus, it would ensure 
that  all  of  those  involved  have  access  to  the  same  references  and  have  the  same 
expectations on the process. 

Online  (GIS)  database  /  maps  including  administrative  restrictions  and  other  relevant 
parameters:  A  key  element  of  good  practice  recommendations  is  the  introduction  of  an 
online database which can ideally be accessed as a set of GIS maps. These would easily 
allow project developers to assess how suitable specific areas and sites are for their project 
and  what  restrictions  they  have  to  anticipate.  The  maps  should  include  information  on 
administrative  restrictions,  existing  environmental  assessments  and  data,  aviation  and 
military  interests  and  grid  availability.  The  introduction  of  such  a  GIS  map  would  allow 
planners  to  focus  on  promising  areas.  This  would  lead  to  higher  efficiency  of  planning 
procedures and accordingly lower cost of RES deployment. Authorities are relieved as their 
applicants  are  better  prepared,  and  they  do  not  have  to  deal  with  requests  relating  to 
restricted areas. 

Environmental  preassessment  by  authorities 
/  centralisation  and  publication  of 
environmental  data  and  assessments:  Authorities  can  undertake  environmental  scoping 
and gather information on possible environmental impacts. Existing information would be 
widely  shared.  By  doing  so,  they  can  advise  planners  where  a  negative  environmental 
impact is probable, impeding the realisation of a project, and where this would not be an 
issue.  

Participation and acceptance measures 

Financial  participation  of  affected  municipalities:  Support  and  acceptance  by  the  local 
population and administration can be enhanced by ensuring that they benefit economically 
from new RES plants. This can be achieved by allowing municipalities to financially benefit 
from projects, e.g. in the form of a payment per kWh from the RES producer. Income should 
be bound to specific public policy measures that benefits citizens as well, like social services 
(e.g. kindergarten, health services) or infrastructure (e.g. streets or public transportation).  

Early engagement in local information, dissemination, and discussion: Citizens and other 
stakeholders’  acceptance  of  projects  plays  a  vital  role  in  renewable  expansion.  The 
acceptability of projects can be increased with the right participatory approach. On a general 
level,  such  activities  should  inform  the  public  on  the  relevance  of  renewable  energy  in 
fighting climate change and related threats. With respect to specific projects, participation 

21 

 
 
Simplification of permission and administrative procedures for RES installations 

has to begin with the launch of a project and allow stakeholders to influence its concept 
rather than just confronting them with final plans and decisions.  

Project  independent  moderator  for  stakeholder  participation  and  problem  resolution: 
Independent moderators facilitate communication between local communities and project 
planners. They help solve disputes during the planning and realisation of RES projects. This 
way,  planners  can  realise  projects  with  less  regional  opposition  and  allow  developers  to 
avoid lawsuits. Moderators must be neutral towards parties and familiar with the regional 
circumstances. This way they are accepted by planners and local communities alike. 

Eased procedures 

Eased  procedures  for  the  repowering  of  existing  power  plants:  New  permissions  and 
assessments  should  only  be  mandated  to  address  possible  new  impacts  of  repowering 
projects. Authorities must take the existing impact of an old installation as a baseline in the 
case  of  an  environmental  assessment.  This  can  be  the  case  when  they  consider  the 
protection  of  species,  for  instance.  Furthermore,  when  defining  requirements  on 
compensation measures an authority expects for the negative effects an installation has on 
a landscape, the authority should include those that the developer has already provided for 
the existing installation. 

Refurbishments  should  be  allowed  within  specific  capacity  limits  without  the  project 
developer having to obtain further permissions. That is, if the installation’s impact on the 
environment is not expected to substantially change. The expected ecological impacts of 
changes  and  therefore  the  applicability  of  simplified  procedures  can  be  subject  to  an 
assessment  by  local  authorities  (or  at  least  authorities  which  are  familiar  with  the  local 
context). 

Eased  procedures  for  RES  self-supply  and  small-scale  RES:  Easing  and  simplifying 
procedures for projects is a simple approach to speed up permitting. It helps planners and 
authorities alike and increases the speed at which projects are realised. By simply reducing 
the number of necessary permits for projects, developers need to prepare less documents. 
Authorities  on  the  other  hand  receive  less  applications  and  can  therefore  use  their 
resources  to  permit  large  and  important  projects.  Eased  procedures  for  RES  self-supply 
and  small-scale  RES  streamline  the  necessary  checks  and  balances  between  project 
planners  and  authorities.  This  can  be  implemented  due  to  the  limited  impact  these 
installations are to have on the environment and energy systems. 

Clarified priority for RES in administrative processes 

Political  backing  of  RES:  Integrated  planning  system  from  national  to  local:  A  general 
planning  strategy  can  enhance  local  and  regional  involvement.  Such  a  strategy  includes 
breaking  down  national  targets  to  the  regional  and  local  levels.  Measures  should  be 
implemented to legally ensure the availability of sufficient land area for a target-compliant 
RES development (e.g. x% of national area is allocated to wind power). This could feature 
regional targets, but would leave decisions about specific locations in the hands of local 
actors. 

Define RES as public interest: The permission to develop RES projects depends on how 
their  environmental  benefit  relates  to  any  potential  negative  impact  stemming  from  their 
installation and operation. In order to clarify the high value of renewables in fighting climate 
change  on  the  global  level,  renewables  should  be  legally  defined  as  a  matter  of  public 
interest. Ideally, this status could be regulated by EU legislation rather than only on the level 
of Member States. 

Ensure that responsible authorities are fit for purpose: Authorities should be put in a position 
that they can make robust decisions on applications within the required deadlines or even 

22 

 
 
Simplification of permission and administrative procedures for RES installations 

faster. Key measures include that a sufficient number of staff should be assigned to deal 
with applications. Furthermore, responsible staff have to be trained to have a sufficient level 
of expertise to evaluate permissions. This can be supported by central, possibly national, 
departments, for instance. These would be staffed with experts that can assist their regional 
or local colleagues on specific issues.  

IT infrastructure 

Optimised  processes  require  adequate  IT  infrastructure.  RED  II  contains  a  number  of 
requirements  that  necessitate  this.  Some  of  these  issues  have  already  been  addressed 
above, but are presented here in a structured way, focusing specifically on IT infrastructure. 

1.  Provide information to applicants 

IT  infrastructure  should  support  applicants’  access  to  requisite  information.  This  entails 
establishing necessary repositories of data where necessary information is collected and 
made available. This should cover a range of issues that are all accessible through a single 
platform. This way IT infrastructure supports the development of single contact points. 

2.  Facilitate information flow from applicants to authorities 

Besides channelling information from authorities to applicants, IT infrastructure should also 
facilitate information flow in the other direction. Most importantly, developers should be able 
to  submit  application  documents  digitally,  but  such  a  platform  could  enable  further 
communication from the applicant. 

The  two-way  communication  between  applicants  and  authorities  (requirements  to  both 
provide information to the applicant and to facilitate the information flow from applicants to 
authorities)  should  be  combined  in  one  central  platform.  This  should  ensure  that  all 
information is in one place for a project at hand. 

IT infrastructure should be the basis for a single contact point, but should not become a 
black box for applicants.  

3.  Optimal processes within authorities 

Finally,  IT  infrastructure  should  not  only  support  interaction  between  authorities  and 
applicants, but also contribute to the effective and efficient processing of applications within 
the authorities. 

Some  of  the  above-mentioned  features  can  increase  internal  efficiency  and  therefore  IT 
solutions  should  be  designed  to  support  these  objectives.  First,  the  central  platform  can 
also  be  used  as  knowledge  management  system  for  the  involved  authorities.  Second,  a 
tracking system can make the process transparent for both applicants and those experts 
working within authorities. 

Additional technology specific recommendations 

Wind  

The European Commission should initiate best practice guidelines for Member States on 
measures  to  reduce  conflicts  with  military  and  aeronautical  interests:  These  include 
investments  into  additional  high  technology  infrastructure,  including  additional  radars  or 
high-performance  radars,  or  the  support  of  radars  compatible  with  wind  turbines. 
Operational  improvements  can  also  be  made  by  governments,  by  introducing  measures 
that provide the military with the ability to remotely control wind power plants. With respect 
to the permission procedure, stakeholders have also proposed that it would be helpful if the 
military would not either accept or refuse projects, but could make its decision conditional 
and request changes, if the circumstances allow for this. 

23 

 
 
Simplification of permission and administrative procedures for RES installations 

The Consortium also recommends that a cross-border cooperation between Member States 
should be enhanced for offshore wind. This can be achieved by establishing appropriate 
administration structures (like a joint One Stop Shop) per sea basin. 

Small hydropower 

Adaptation of the Water Framework Directive: There should be a better alignment of the 
renewable energy and environmental goals in RED II and the Water Framework Directive, 
so that it becomes clear to which extent Member States can consider hydropower projects 
to be of overriding public interest as defined in the WFD. This would provide an anchor as 
to whether responsible authorities can grant them licenses. 

Geothermal 

A  Delegated  Act  for  Geothermal  Licenses  and  Permits:  A  Delegated  Act  regulating  the 
provision of geothermal licenses and permits is strongly proposed to streamline the various 
facets of permitting. For this purpose, art. 15 RED II should be amended. Stakeholders have 
requested that such a Delegated Act outline harmonised rules on licensing and permitting 
geothermal projects. 

RES priority access and feed-in for heating grids: It is recommended that, similarly to RES 
electricity installations, RES heat installations should also be provided with a priority access 
for a grid connection and the feed-in of energy. The general priority for RES heat could be 
supplemented by an obligation to increase RES shares when developers expand district 
heating systems. 

Priority  of  suitable  areas  for  heat  use:  RES  heat  production  can  be  increased  by  pre-
assessing  suitable  areas  for  RES  heat  and  granting  it  priority  to  access  district  heating 
systems. This is especially important in urban areas and when installations are near district 
heating pipelines. Such pre-assessments and clear priorities would facilitate negotiations 
on land-use rights, and the land usable by project developers would increase. 

24 

 
 
 
 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

Synthèse en langue française 

Introduction  

Les  États  membres  de  l'UE  ont  fixé  des  objectifs  ambitieux  pour  le  déploiement 
d’installations  d'énergie  renouvelable.  Ils  ont  choisi  de  s'appuyer  sur  l'éolien  et  le 
photovoltaïque  pour  atteindre  ces  objectifs  dans  le  secteur  de  l'électricité,  qui  sont  deux 
technologies qui ont connu une croissance dans la plupart des pays. Cependant, la plupart 
des États membres n'ont pas déployé ces technologies d'énergie renouvelable de manière 
constante, mais plutôt de manière fluctuante au cours des dix dernières années, ce qui a 
conduit un certain nombre de marchés à ne pas atteindre leur plein potentiel.  

La  sous-performance  des  énergies  renouvelables  s'explique  principalement  par  des 
obstacles  non  techniques,  tels  que  l'absence  d'analyses  de  rentabilité,  la  faiblesse  des 
régimes de soutien, les barrières à l'entrée sur le marché, les obstacles administratifs et les 
problèmes liés au réseau. Au cours des dernières années, les obstacles administratifs (et 
liés  au  réseau)  sont  devenus  une  question  de  plus  en  plus  importante  et  urgente. 
Aujourd'hui déjà, les problèmes administratifs et de réseau représentent environ 46 % de 
tous  les  obstacles  recensés  et  ce  chiffre  devrait  augmenter  à  l'avenir.  Pour  certaines 
technologies, telles que l'énergie éolienne et photovoltaïque, on observe une tendance où 
les obstacles administratifs deviennent encore plus cruciaux que les obstacles politiques 
liés aux régimes de soutien. Les analyses de rentabilité dépendent moins des régimes de 
soutien, car les coûts de production des technologies diminuent et les entreprises entrent 
sur le marché en signant des accords d'achat d'électricité (d’entreprise) (AAE). Au cours de 
ces  changements  de  marché,  d'autres  obstacles,  tels  que  les  obstacles  administratifs, 
les 
deviennent  plus  visibles  et  pertinents.  C'est  pourquoi 
recommandations ci-après revêtent une importance particulière. 

les  conclusions  et 

Obstacles identifiés 

Le Consortium structure les obstacles qu'il a identifiés lors de la recherche cartographique 
menée à l'échelle européenne entre novembre 2020 et juillet 2021 comme suit: 

Obstacles liés au processus administratif 

Les obstacles les plus courants liés au processus administratif pour les projets d'énergie 
renouvelable sont les charges bureaucratiques, les processus non transparents, le manque 
de cohérence juridique ainsi qu'un cadre et des lignes directrices incomplets et vagues qui 
entraînent  différentes  interprétations  de 
les  autorités 
la 
compétentes.  

législation  existante  par 

Dans  certains  pays,  l'absence  de  planification  spatiale  adéquate  est  un  problème 
particulièrement grave. Cela peut se manifester soit par le fait que les plans d'aménagement 
du  territoire  ne  désignent  pas  de  terrains  pour  les  projets  d'énergie  renouvelable,  par 
conséquent,  les  promoteurs  doivent  modifier  les  conditions  d'utilisation  du  terrain  ce  qui 
prend  beaucoup  de  temps  et  prolonge  la  durée  du  projet  dans  son  ensemble.  L'autre 
problème majeur est celui des autorités qui utilisent le zonage pour interdire le déploiement 
de  certaines  technologies,  comme  l'énergie  éolienne.  Les  restrictions  de  distance 
constituent  un  obstacle  particulièrement  important  qui  rend  le  déploiement  de  l'énergie 
éolienne presque impossible dans certaines régions. Enfin, si les autorités responsables 
conçoivent des plans spatiaux insuffisamment détaillés, les parties prenantes qui souhaitent 

25 

 
 
 
Simplification of permission and administrative procedures for RES installations 

empêcher la réalisation des projets prévus peuvent les entraver en contestant légalement 
les plans d'aménagement du territoire correspondants. 

Un  autre  obstacle  très  répandu  est  le  manque  de  personnel  expérimenté.  Le  problème 
réside soit dans le fait qu'il n'y a pas assez de fonctionnaires pour traiter les demandes, soit 
que  le  personnel  en  question  manque  de  l’expérience  ou  des  compétences  techniques 
nécessaires  pour  exécuter  ces  tâches.  Ce  dernier  point  est  un  problème  plus  important 
dans les régions qui ont mis en œuvre moins de projets d'énergie renouvelable. 

Un autre problème est que la plupart des pays de l'UE n'ont pas numérisé les permis par 
conséquent, les demandes nécessitent encore beaucoup de documents papiers. 

L'absence de procédures simplifiées pour le rééquipement est un autre obstacle, surtout 
dans le cas des projets éoliens terrestres et hydroélectriques. Dans presque tous les États 
membres, le rééquipement de ces technologies, même avec des modifications mineures, 
est  soumise  aux  mêmes  procédures  d'approbation  étendues  que  le  développement  de 
nouvelles installations. 

Biens publics conflictuels 

Les conflits de biens publics constituent le deuxième obstacle principal au déploiement des 
installations renouvelables. C'est particulièrement le cas pour l'énergie éolienne, l'énergie 
géothermique et hydraulique, ainsi que pour l'énergie solaire photovoltaïque. 

Les  problèmes  les  plus  importants  liés  aux  conflits  entre  biens  publics  sont  les 
réglementations  environnementales  contradictoires  (biodiversité,  protection  des  espèces 
menacées et protection des plans d'eau), les conflits d'utilisation des terres et les problèmes 
liés à la défense militaire et aérienne. Les questions militaires/de défense aérienne sont 
pertinentes  pour  les  projets  d'énergie  éolienne,  mais  elles  concernent  principalement 
l'Europe  du  Nord-Est.  Dans  le  cas  de  l'hydroélectricité  et  de  l’énergie  géothermique,  les 
problèmes proviennent de conflits avec la directive-cadre sur l'eau. En outre, ces conflits 
peuvent survenir avec des groupes environnementaux, des acteurs individuels, mais aussi 
avec les autorités publiques à différents niveaux. 

Les  acteurs  du  secteur  reconnaissent  généralement  la  valeur  des  biens  publics 
susmentionnés. Leurs critiques portent sur les processus d’équilibrage des biens publics. 
C'est également le point de départ des recommandations du Consortium, telles que décrites 
ci-dessous. 

Problèmes liés aux tiers 

Les problèmes liés aux tiers font référence aux obstacles liés au manque de soutien des 
décideurs politiques ou à l'opposition ostentatoire d’institutions publiques ou privées, ou du 
public  lui-même.  La  résistance  de  ces  derniers  est  souvent  dirigée  contre  des  projets 
spécifiques  d'énergie  renouvelable, mais  dans  certaines  régions  ou  États  membres,  elle 
peut cibler plus généralement le déploiement des énergies renouvelables. 

Les  motivations  de  cette  opposition  varient  considérablement.  Dans  l’ensemble,  on  peut 
identifier trois motifs de résistance : (i) l'opposition individuelle (et souvent bien fondée) de 
groupes de personnes particulièrement affectées (par exemple des voisins ou des groupes 
environnementaux  ayant  une  préoccupation  spécifique),  (ii)  des  groupes  d’intérêt 
commercial dont les protestations sont principalement liées à des gains financiers, (iii) des 
groupes  organisés  de  protestataires  qui  s'opposent  à  certaines  technologies  ou  aux 
énergies renouvelables en général. Ces groupes sont généralement assez petits, mais ils 
se  font  disproportionnellement  entendre  et  peuvent  donc,  dans  une  certaine  mesure, 
influencer l'opinion publique.  

26 

 
 
Simplification of permission and administrative procedures for RES installations 

Les problèmes liés aux tiers peuvent également entraîner des conflits devant les tribunaux. 
Dans de tels cas, des structures judiciaires surchargées peuvent aggraver ces obstacles, 
d'autant plus que l'art. 16 (7) de la directive RED II ne tient pas compte des retards dus aux 
procédures  judiciaires  lors  de  l’établissement  de  délais  spécifiques  pour  les  procédures 
administratives. 

Problèmes liés au réseau 

Les problèmes liés aux connexions au réseau et aux procédures d'exploitation sont moins 
fréquents  que  les  problèmes  administratifs.  Néanmoins,  ils  peuvent  avoir  un  impact 
important et stopper le déploiement global des énergies renouvelables dans certains États 
membres.  

Les principaux problèmes de connexion au réseau résultent très souvent de l'insuffisance 
des capacités du réseau, ce qui donne lieu à des discussions et des négociations sur la 
manière de se connecter au réseau et sur les coûts associés. Cela entraîne des retards 
dans les projets. 

Un  autre  défi  au  déploiement  des  énergies  renouvelables  découle  des  conflits  avec  les 
opérateurs  de  réseaux  de  distribution  et  de  transport  concernant  l'interprétation  des 
réglementations  techniques,  l'accès  aux  données  ou  la  répartition  des  coûts  de 
raccordement. 

L'industrie du solaire thermique est également confrontée à certains obstacles lorsqu'elle 
cherche à raccorder des installations aux réseaux de chauffage urbain. Ces obstacles sont 
principalement  dus  au  manque  de  clarté  des  réglementations  sur  les  modalités  de 
raccordement, qui laissent aux opérateurs des systèmes de chauffage urbain une marge 
d'interprétation  et  d'appréciation.  Un  autre  problème  pour  les  sources  de  chaleur 
renouvelables est que la chaleur qu'elles produisent ne peut pas être transportée sur de 
longues distances. Elles sont donc moins flexibles en termes de lieux de raccordement au 
réseau, ce qui rend les problèmes de connexion encore plus pressants. 

Recommandations de bonnes pratiques 

Sur  la  base  de  la  recherche  documentaire  et  des  discussions  intenses  avec  les  parties 
prenantes pour cartographier les processus et les obstacles à travers l’Europe qui entravent 
la  diffusion  des  énergies  renouvelables,  le  Consortium  a  élaboré  une  série  de 
recommandations basées sur les meilleures pratiques. Celles-ci sont largement applicables 
pour aborder les principales barrières administratives, en soutenant l'efficacité et l'efficience 
des autorisations d'installation des SER. Cet ensemble de recommandations est également 
considéré comme approprié pour guider et soutenir les États membres lors de la mise en 
œuvre des exigences stipulées par les articles 15, 16 et 17 de la directive RED II. 

Nous regroupons les recommandations dans les six catégories suivantes :  

●  Communication et processus administratifs, 

●  Conseils et meilleures pratiques, 

●  Fourniture centralisée d'informations, 

●  Mesures de participation et d'acceptation, 

●  Procédures simplifiées, 

●  Clarification de la priorité accordée aux SER dans les processus administratifs, 

● 

Infrastructure informatique. 

27 

 
 
 
Simplification of permission and administrative procedures for RES installations 

En  outre,  la  recherche  sous-tend  d'autres  recommandations  de  meilleures  pratiques 
spécifiques à chaque technologie. 

Les Figures 0-1 et 0-2 donnent un aperçu des recommandations formulées. 

Les recommandations individuelles sont détaillées ci-dessous. 

28 

 
 
Simplification of permission and administrative procedures for RES installations 

Communication et 
processus 
administratifs 

Conseils et bonnes 
pratiques 

Fourniture centralisée 
d'informations 

Utilisation de la 
communication 
électronique, y compris le 
suivi des progrès 

Document d'orientation 
de l'UE pour les États 
membres 

Plate-forme centrale 
d'information 
indépendante 

  Guichet unique 

 Rôles et processus clairs 

Mise à disposition 
publique de lignes 
directrices et de modèles 
au niveau national 

Mécanisme de suivi pour 
l'identification et la 
suppression des 
obstacles 

 Base de données/cartes 
en ligne (SIG) 

Informations 
environnementales 
centrales : pré-évaluation 
et fourniture 
d'informations 

Mesures de 
participation et 
d'acceptation 

 Procédures assouplies 

Clarification de la 
priorité accordée aux 
SER dans les processus 
administratifs 

Soutien politique aux 
SER, y compris la 
planification 
locale/régionale 

 Définir le SER comme 
étant d'intérêt public 

Veiller à ce que les 
autorités soient 
adaptées à leur 
mission 

Renforcer la 
participation des 
citoyens 

pour la remise à 
niveau des centrales 
existantes 

  Participation 
financière locale 

pour l'auto-
approvisionnement en 
SER et les SER à petite 
échelle 

 Engagement précoce 

Facilitation 
indépendante de la 
consultation et de la 
participation des 
parties prenantes 

  Mécanismes de 
résolution des conflits 

Figure  0-1:  Aperçu  des  meilleures  pratiques  et  autres  recommandations  pour  améliorer  les  procédures 
d'autorisation 

29 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

Éolienne 

 Hydroélectricité 

  Géothermie 

Activités visant à 
réduire les conflits 
militaires et 
aéronautiques 

Adaptation de la 
directive-cadre sur 
l'eau 

 Acte délégué sur la 
géothermie 

Solaire 
thermique 

Accès prioritaire aux 
SER également pour 
les réseaux de 
chauffage 

Priorité aux zones 
appropriées pour 
l'utilisation de la 
chaleur 

Figure  0-2:  Aperçu  des  meilleures  pratiques  supplémentaires  spécifiques  à  une  technologie  et  autres 
recommandations visant à améliorer les procédures d'autorisation 

Communication et processus administratifs 

Utilisation  de  la  communication  électronique,  y  compris  un  mécanisme  de  suivi  de 
l'avancement  du  projet:  La  numérisation  facilite  les  procédures  pour  les  demandeurs 
comme pour les autorités. Les fonctionnaires peuvent trier, stocker et examiner facilement 
les documents numériques et les partager entre les parties concernées. Les demandeurs 
peuvent ainsi savoir où en est leur demande. Cela accélère le processus d'autorisation et 
assure la transparence.  

Guichet  unique  /  consolidation  en  un  seul  processus  de  demande:  Les  demandeurs 
peuvent  s'adresser  à  un  guichet  unique  (GU)  pour  obtenir  toutes  les  autorisations 
nécessaires à leur projet. Ce guichet unique peut soit fournir les autorisations, soit agir en 
tant que point de contact pour faciliter l'ensemble du processus, tel que défini à l'article 16 
(1) RED II. En fonction de la technologie et de la taille, le GU peut être spécifique à une 
technologie  et/ou  avoir  des  compétences  régionales  limitées.  Dans  tous  les  cas,  le 
développeur de projet doit savoir clairement à quel GU il doit s'adresser. Les GU devraient 
être  présentés  comme  une  option  pour  les  demandeurs,  leur  permettant  de  contacter 
directement  les  autorités  individuelles.  De  cette  manière,  les  demandeurs  peuvent 
bénéficier de leur propre expérience et de leurs contacts personnels. 

Rôles et des processus clairs: Les développeurs de projets, les autorités responsables et 
les autres parties prenantes ne peuvent délivrer les autorisations de manière fluide que si 
les procédures et les responsabilités respectives sont clairement définies et transparentes 
pour toutes les parties concernées. La définition de la procédure doit notamment inclure 
une  description  claire  et  séquentielle  du  processus  de  demande,  des  responsabilités 
individuelles, un aperçu de la documentation requise et des délais clairement définis pour 
chaque étape. 

Conseils et bonnes pratiques 

Document  d'orientation  de  l'UE  sur  la  mise  en  œuvre  des  dispositions  réglementaires 
pertinentes des art. 15, 16 et 17 RED II et art. 8 de la directive sur le marché intérieur de 
l'électricité:  les  États  membres  doivent  interpréter  et  préciser  les  différentes  exigences 
imposées  à  la  fois  par  la  directive  révisée  sur  les  énergies  renouvelables  (RED  II)  et  la 
directive  sur  le  marché  intérieur  de  l'électricité  (IEMD)  afin  de  mettre  en  place  un  cadre 
réglementaire approprié pour le déploiement des SER. Des orientations supplémentaires à 
l'échelle de l'UE peuvent aider les États membres à trouver des solutions réglementaires 
adaptées à leurs besoins spécifiques. Cela renforce également l'harmonisation des règles 

30 

 
 
 
 
 
 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

et  des  réglementations,  réduisant  ainsi  les  obstacles  auxquels  les  développeurs  sont 
confrontés lorsqu'ils entreprennent des projets dans d'autres pays de l'UE. 

Mise à disposition publique de lignes directrices et de modèles de documentation au niveau 
national pour les autorités, les développeurs de projets et les parties prenantes: Les lignes 
directrices destinées aux autorités et aux parties prenantes constituent une aide précieuse 
pour  la  réalisation  de  projets  d'énergies  renouvelables.  Elles  informent  et  décrivent  le 
processus  d'autorisation  de  l'électricité  des  SER  et  renforcent  ainsi  l'expertise  et  les 
connaissances de toutes les parties concernées. Les parties prenantes peuvent suivre des 
instructions claires et ont un accès direct aux éléments standards (modèles pour tous les 
documents de demande, etc.) qu'elles doivent utiliser lors de l'autorisation du projet.  

Mécanisme  de  suivi  coopératif  pour  l'identification  et  la  suppression  des  obstacles 
réglementaires: Les autorités, les développeurs de projets et les autres parties prenantes 
devraient  coopérer  dans  le  cadre  d'un  processus  formalisé  afin  d'identifier  les  obstacles 
réglementaires  aux  installations  des  SER  et  d'élaborer  des  solutions  appropriées.  Ce 
processus  peut  être  systématiquement  soutenu  par  une  infrastructure  informatique  qui 
traite et contrôle les demandes. Un suivi structuré permet d'identifier les scénarios typiques 
et les étapes qui sont longues ou inefficaces. Une analyse structurée de la performance 
des  procédures  d'autorisation  devrait  être  renforcée  par  des  obligations  de  rapport  à 
l'échelle  de  l'UE.  L'accent  serait  mis  sur  l'efficacité  et  l’efficience  des  processus 
d'autorisation des SER dans les États membres. 

Fourniture centralisée d'informations 

Plateforme centrale d'information indépendante sur la réglementation, les processus, les 
projets  et  la  participation:  Une  plateforme  d'information  centrale  et  indépendante  sur 
l'installation de nouvelles centrales des SER pourrait constituer une source d'information 
appropriée et fiable pour toutes les parties impliquées dans la planification et l'autorisation 
de  nouvelles  centrales.  La  plateforme  d'information  proposée  pourrait  cibler  toutes  les 
parties  concernées,  y  compris  les  autorités,  les  développeurs  de  projets  et  les  parties 
prenantes externes. Elle permettrait ainsi à toutes les parties concernées d'avoir accès aux 
mêmes références et d'avoir les mêmes attentes en ce qui concerne le processus. 

Base  de  données  /  cartes  en  ligne  (SIG)  comprenant  les  restrictions  administratives  et 
d'autres paramètres pertinents: Un élément clé des recommandations de bonnes pratiques 
est l'introduction d'une base de données en ligne qui peut idéalement être consultée sous 
la  forme  d'un  ensemble  de  cartes  SIG.  Ces  cartes  permettraient  aux  développeurs  de 
projets  d'évaluer  facilement  dans  quelle  mesure  des  zones  et  des  sites  spécifiques 
conviennent à leur projet et quelles sont les restrictions qu'ils doivent anticiper. Les cartes 
devraient contenir des informations sur les restrictions administratives, les évaluations et 
données environnementales existantes, les intérêts aériens et militaires et la disponibilité 
du  réseau.  L'introduction  d'une  telle  carte  SIG  permettrait  aux  planificateurs  de  se 
concentrer  sur  les  zones  prometteuses.  Il  en  résulterait  une  plus  grande  efficacité  des 
procédures de planification et, par conséquent, une réduction du coût de déploiement des 
SER. Les autorités seraient soulagées car leurs demandeurs seraient mieux préparés et 
elles n'auraient pas à traiter de demandes relatives à des zones restreintes. 

Pré-évaluation  environnementale  par  les  autorités  /  centralisation  et  publication  des 
données  et  évaluations  environnementales:  Les  autorités  peuvent  procéder  à  une 
évaluation  environnementale  et 
impacts 
recueillir  des 
environnementaux  possibles. Les informations existantes seraient largement partagées. 
Ce  faisant,  elles  peuvent  conseiller  les  planificateurs  sur  les  impacts  environnementaux 
négatifs probables qui pourraient entraver la réalisation d'un projet, et sur les zones où cela 
ne poserait pas de problème. 

informations  sur 

les 

31 

 
 
 
Simplification of permission and administrative procedures for RES installations 

Mesures de participation et d'acceptation 

Participation  financière  des  municipalités  concernées:  Le  soutien  et  l'acceptation  de  la 
population  et  de  l'administration  locales  peuvent  être  renforcés  en  veillant  à  ce  qu'elles 
bénéficient économiquement des nouvelles installations de SER. Cela peut être réalisé en 
permettant aux municipalités de bénéficier financièrement des projets, par exemple sous la 
forme d'un paiement par kWh de la part du producteur de SER. Les revenus devraient être 
liés à des mesures de politique publique spécifiques qui profitent également aux citoyens, 
comme  les  services  sociaux  (par  exemple,  les  garderies,  les  services  de  santé)  ou  les 
infrastructures (par exemple, les rues ou les transports publics). 

Engagement  précoce  dans  l'information,  la  diffusion  et  la  discussion  au  niveau  local: 
L'acceptation  des  projets  par  les  citoyens  et  les  autres  parties  prenantes  joue  un  rôle 
essentiel dans l'expansion des énergies renouvelables. L'acceptabilité des projets peut être 
accrue  grâce  à  une  approche  participative  appropriée.  D'une  manière  générale,  ces 
activités devraient informer le public sur l'importance des énergies renouvelables dans la 
lutte contre le changement climatique et les menaces qui y sont liées. En ce qui concerne 
les  projets  spécifiques,  la  participation  doit  commencer  dès  le  lancement  d'un  projet  et 
permettre  aux  parties  prenantes  d'influencer  son  concept  plutôt  que  de  simplement  les 
confronter aux plans et décisions finaux. 

Modérateur indépendant du projet pour la participation des parties prenantes et la résolution 
des  problèmes:  Les  modérateurs  indépendants  facilitent  la  communication  entre  les 
communautés locales et les planificateurs de projets. Ils aident à résoudre les conflits au 
cours  de  la  planification  et  de  la  réalisation  des  projets  de  SER.  De  cette  manière,  les 
planificateurs peuvent réaliser des projets avec moins d'opposition régionale et permettre 
aux  développeurs  d'éviter  les  litiges.  Les  modérateurs  doivent  être  neutres  vis-à-vis  des 
parties et bien connaître le contexte régional. Ils sont ainsi acceptés par les planificateurs 
et les communautés locales. 

Procédures simplifiées 

Simplification des procédures pour le rééquipement des centrales électriques existantes: 
De  nouvelles  autorisations  et  évaluations  ne  devraient  être  requises  que  pour  traiter  les 
éventuels nouveaux impacts des projets de réhabilitation. Les autorités doivent prendre en 
compte  l'impact  existant  d'une  ancienne  installation  comme  référence  dans  le  cas  d'une 
évaluation environnementale. Cela peut être le cas lorsqu'elles considèrent la protection 
des  espèces,  par  exemple.  En  outre,  lors  de  la  définition  des  exigences  en  matière  de 
mesures de compensation attendues pour les effets négatifs qu'une installation a sur un 
paysage, l'autorité devrait inclure celles que le développeur a déjà prévues pour l'installation 
existante. 

Les remises à niveau devraient être autorisées dans des limites de capacité spécifiques 
sans que le développeur du projet ne doive obtenir de nouvelles autorisations à condition 
que  l'impact  de  l'installation  sur  l'environnement  ne  soit  pas  censé  changer  de  manière 
significative. Les impacts écologiques attendus des modifications et donc l'applicabilité des 
procédures simplifiées peuvent faire l'objet d'une évaluation par les autorités locales (ou du 
moins par des autorités qui connaissent bien le contexte local). 

Procédures simplifiées pour l'auto-approvisionnement en SER et les SER à petite échelle: 
L'assouplissement  et  la  simplification  des  procédures  pour  les  projets  constituent  une 
approche simple pour accélérer l'octroi des permis. Cela facilite la tâche des planificateurs 
et des autorités et accélère la réalisation des projets. En réduisant simplement le nombre 
d'autorisations nécessaires pour les projets, les développeurs doivent préparer moins de 
documents.  De  leur  côté,  les  autorités  reçoivent  moins  de  demandes  et  peuvent  donc 
consacrer leurs ressources à l’autorisation de projets importants et de grande envergure. 
L'assouplissement  des  procédures  pour  l'auto-approvisionnement  en  SER  et  les  SER  à 

32 

 
 
Simplification of permission and administrative procedures for RES installations 

petite échelle rationalise les contrôles et les équilibres nécessaires entre les planificateurs 
de  projets  et  les  autorités.  Ces  procédures  peuvent  être  mises  en  œuvre  en  raison  de 
l'impact limité de ces installations sur l'environnement et les systèmes énergétiques. 

Clarification  de  la  priorité  accordée  aux  SER  dans  les 
processus administratifs 

Soutien politique des SER: Système de planification intégré, du niveau national au niveau 
local  :  Une  stratégie  générale  de  planification  peut  renforcer  la  participation  locale  et 
régionale. Une telle stratégie comprend la déclinaison des objectifs nationaux aux niveaux 
régional et local. Des mesures devraient être mises en œuvre pour garantir légalement la 
disponibilité  d'une  superficie  suffisante  pour  le  développement  d'une  SER  conforme  aux 
objectifs (par exemple, x % de la superficie nationale est allouée à l'énergie éolienne). Ces 
mesures  pourraient  comporter  des  objectifs  régionaux,  mais  laisseraient  les  décisions 
concernant les sites spécifiques aux mains des acteurs locaux. 

Définir les SER comme étant d'intérêt public: L'autorisation de développer des projets de 
SER  dépend  du  rapport  entre  leurs  avantages  environnementaux  et  tout  impact  négatif 
potentiel  découlant  de  leur  installation  et  de  leur  exploitation.  Afin  de  clarifier  la  valeur 
élevée des énergies renouvelables dans la lutte contre le changement climatique au niveau 
mondial,  les  énergies  renouvelables  devraient  être  légalement  définies  comme  une 
question d'intérêt public. Dans l'idéal, ce statut pourrait être réglementé par la législation 
européenne plutôt qu'au seul niveau des États membres. 

Veiller à ce que les autorités responsables soient aptes à remplir leur mission: les autorités 
doivent être en mesure de prendre des décisions solides sur les demandes dans les délais 
impartis,  voire  plus  rapidement.  Parmi  les  mesures  clés,  citons  l'affectation  d'un  nombre 
suffisant  d'agents  au  traitement  des  demandes.  En  outre,  le  personnel  responsable  doit 
être formé afin de disposer d'un niveau d'expertise suffisant pour évaluer les autorisations. 
Cela peut être soutenu par des services centraux, éventuellement nationaux, par exemple. 
Ceux-ci seraient composés d'experts capables d'aider leurs collègues régionaux ou locaux 
sur des questions spécifiques. 

Infrastructure informatique 

Des processus optimisés nécessitent une infrastructure informatique adéquate. La directive 
RED II contient un certain nombre d'exigences à cet égard. Certaines de ces questions ont 
déjà été abordées plus haut, mais elles sont présentées ici de manière structurée, en se 
concentrant spécifiquement sur l'infrastructure informatique. 

1.  Fournir des informations aux demandeurs 

L'infrastructure  informatique  doit  faciliter  l'accès  des  demandeurs  aux  informations 
requises. Cela implique la mise en place de référentiels de données où les informations 
nécessaires  sont  collectées  et  mises  à  disposition.  Cela  devrait  couvrir  une  série  de 
questions  accessibles  via  une  plateforme  unique.  De  cette  manière,  l'infrastructure 
informatique favorise la mise en place de points de contact uniques. 

2.  Faciliter le flux d'informations entre les demandeurs et les autorités 

En  plus  de  canaliser  les  informations  des  autorités  vers  les  demandeurs,  l'infrastructure 
informatique  devrait  également  faciliter  le  flux  d'informations  dans  l'autre  sens.  Plus 
important  encore,  les  développeurs  devraient  pouvoir  soumettre  leurs  documents  de 
demande de manière numérique, mais une telle plateforme pourrait également permettre 
au demandeur une communication ultérieure. 

La  communication  bidirectionnelle  entre  les  demandeurs  et  les  autorités  (exigences 
relatives à la fourniture d'informations au demandeur et à la facilitation du flux d'informations 

33 

 
 
Simplification of permission and administrative procedures for RES installations 

entre  les  demandeurs  et  les  autorités)  devrait  être  combinée  au  sein  d'une  plateforme 
centrale.  Cela  devrait  garantir  que  toutes  les  informations  relatives  à  un  projet  soient 
réunies en un seul endroit.  

L'infrastructure informatique doit être à la base d'un point de contact unique, mais ne doit 
pas devenir une boîte noire pour les demandeurs. 

1.  Processus optimaux au sein des autorités 

Enfin,  l'infrastructure  informatique  doit  non  seulement  favoriser  l'interaction  entre  les 
autorités et les demandeurs, mais aussi contribuer au traitement efficace et efficient des 
demandes au sein des autorités. 

Certaines des caractéristiques susmentionnées peuvent accroître l'efficacité interne et, par 
conséquent, les solutions informatiques devraient être conçues pour soutenir ces objectifs. 
Tout  d'abord,  la  plateforme  centrale  peut  également  servir  de  système  de  gestion  des 
connaissances  pour  les  autorités  concernées.  Deuxièmement,  un  système  de  suivi  peut 
rendre le processus transparent à la fois pour les demandeurs et pour les experts travaillant 
au sein des autorités. 

Recommandations 
technologie 

supplémentaires 

spécifiques  à 

la 

Énergie éolienne 

La  Commission  européenne  devrait  élaborer  des  lignes  directrices  sur  les  meilleures 
pratiques  à  l'intention  des  États  membres  concernant  les  mesures  visant  à  réduire  les 
conflits  avec  les  intérêts  militaires  et  aéronautiques:  Ces  mesures  comprennent  des 
investissements dans des infrastructures de haute technologie supplémentaires, y compris 
des radars supplémentaires ou des radars à haute performance, ou le soutien de radars 
compatibles avec les éoliennes. Des améliorations opérationnelles peuvent également être 
apportées par les gouvernements, en introduisant des mesures qui donnent aux militaires 
la  possibilité  de  contrôler  à  distance  les  centrales  éoliennes.  En  ce  qui  concerne  la 
procédure d'autorisation, les parties prenantes ont également proposé que l’approbation ou 
le refus de projets par les militaires ne soit pas définitif mais qu'ils puissent conditionner leur 
décision et demander des modifications si les circonstances le permettent. 

Le Consortium recommande également de renforcer la coopération transfrontalière entre 
les États membres pour l'éolien en mer. Ceci peut être réalisé en établissant des structures 
administratives appropriées (comme un guichet unique commun) par bassin maritime. 

Petites centrales hydroélectriques 

Adaptation de la directive-cadre sur l'eau: Il faudrait mieux aligner les objectifs en matière 
d'énergie renouvelable et d'environnement de la RED II et de la directive-cadre sur l'eau, 
de sorte qu'il soit clair dans quelle mesure les États membres peuvent considérer les projets 
hydroélectriques comme étant d'un intérêt public supérieur, tel que défini dans la directive-
cadre sur l'eau. Cela permettrait de déterminer si les autorités compétentes peuvent leur 
accorder des licences. 

Géothermie 

Un acte délégué pour les licences et permis géothermiques: Il est fortement recommandé 
de mettre en place un acte délégué réglementant la délivrance de licences et de permis 
géothermiques afin de rationaliser les différentes facettes de l'octroi de permis. À cette fin, 
l'art.  15  RED  II  devrait  être  modifié.  Les  parties  prenantes  ont  demandé  qu'un  tel  acte 
délégué définisse des règles harmonisées pour l'octroi de licences et de permis pour les 
projets géothermiques. 

34 

 
 
Simplification of permission and administrative procedures for RES installations 

Accès prioritaire aux SER et alimentation des réseaux de chauffage: Il est recommandé 
que, comme pour les installations électriques de SER, les installations thermiques de SER 
bénéficient d'un accès prioritaire aux raccordements aux réseaux et à l’injection d'énergie. 
La  priorité  générale  accordée  à  la  chaleur  de  SER  pourrait  être  complétée  par  une 
obligation d'augmenter la part des SER lorsque les promoteurs développent des réseaux 
de chauffage urbain. 

Priorité aux zones appropriées pour l'utilisation de la chaleur: La production de chaleur des 
SER  peut  être  augmentée  en  évaluant  au  préalable  les  zones  adaptées  à  la  chaleur  de 
SER  et  en  leur  accordant  la  priorité  d'accès  aux  réseaux  de  chauffage  urbain.  Ceci  est 
particulièrement important dans les zones urbaines et lorsque les installations sont proches 
des  canalisations  de  chauffage  urbain.  De  telles  évaluations  préalables  et  des  priorités 
claires faciliteraient les négociations sur les droits d'utilisation des terrains, et les terrains 
utilisables par les développeurs de projets augmenteraient. 

35 

 
 
 
 
Simplification of permission and administrative procedures for RES installations 

1. Introduction 

This is the final report under contract ENER/C1/2019-479/SI2.831723 “Technical support 
for  RES  policy  development  and  implementation  –  Simplification  of  permission  and 
administrative  procedures 
the 
Assignment). It was prepared for DG ENER of the European Commission by eclareon in 
cooperation with the Oeko-Institute, WindEurope, and SolarPower Europe largely based on 
work conducted between 2020–2022.  

installations  (RES  Simplify)”  (hereafter  – 

for  RES 

1.1. Objectives  

The European Union is committed to moving away from a fossil fuel-based energy system 
and ensuring a clean, competitive, and reliable energy supply for European citizens and 
businesses.  The  EU’s  long-term  commitment  to  achieve  climate-neutrality  and  reduce 
greenhouse gas emissions by 80–95% compared to 1990 levels until 2050, as supported 
by the President of the European Commission Ursula Von der Leyen and translated into 
Climate Law, carries important implications for the current energy system. The Commission 
shows the nature of these changes in its Roadmap for moving to a competitive low-carbon 
economy in 2050 2.  

The 2030 EU target to meet the provisionally agreed 42.5% of final energy consumption 
from renewable sources is based on each Member State meeting its individual targets. In-
turn, this allows the EU to meet its legally binding overall target. Member States are obliged 
to  provide  detailed  roadmaps  describing  how  they  will  meet  their  targets.  These  are 
provided  through  the  National  Energy  and  Climate  Plans  (NECPs),  which  Regulation 
2018/1999  on  the  Governance  of  the  Energy  Union  and  Climate  Action 3  requires  and 
defines. NECPs contain sectoral targets, the technology mix Member States intend to use 
to meet demand as well as the measures taken and regulatory frameworks introduced to 
facilitate the realisation of the Member State-specific renewable energy target.  

The  European  Commission’s  2020  Renewable  Energy  Progress  Report 4  showed  that  a 
large share of the relevant measures in Directive 2009/28/EC on the promotion of the use 
of energy from renewable sources (RED) 5 have been successfully implemented in the EU 
Member States. What is more, the 2022 Report on the Achievement of the 2020 Renewable 
Energy Targets 6 confirmed that measures have been successful and the EU met its targets. 
Nonetheless, there were still a number of obstacles that continue to hinder the deployment 
of  renewable  energy  sources  and  thus  jeopardise  the  EU’s  ability  to  achieve  its  2030 
renewable energy target. The REveal database 7 illustrates that almost 25% of all existing 
barriers  are  connected  to  administrative  and  grid  connection  processes.  Such  barriers 
appear  in  all  EU  markets.  Their  overwhelming  majority  (83%)  affect  renewable  energy 
installations in the power sector, 13% in the heat sector, and 4% in the transport sector.  

Wind and solar power installations were the technologies which are by far the most affected 
by administrative barriers (see Figure 1-1), according to the REveal database (2020). 44% 

2 COM(2011) 112 of 8 March 2011.   

3 REGULATION (EU) 2018/1999 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 11 December 2018 on the 
Governance of the Energy Union and Climate Action. 

4 https://ec.europa.eu/energy/sites/ener/files/renewable_energy_progress_report_com_2020_952.pdf. 

5 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A32009L0028. 

6 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:52022DC0639. 

7 https://www.renewables-networking.eu/reporting. 

36 

 
 
 
 
Simplification of permission and administrative procedures for RES installations 

of all barriers related to administrative and grid connection processes exclusively impact 
onshore (the majority) and offshore wind projects. Another 23% of these barriers only affect 
PV, biomass installations (including biogas) are impacted by 18%, while other technologies 
(hydropower,  ocean  energy,  biofuels,  geothermal,  electric  vehicle  and  solar-thermal)  are 
affected by less than 5%.  

23%

18%

44%

Wind power

Solar power

Biomass

Hydro & Ocean

Biofuels

5%

4%

Geothermal

3%

EV

2%

Solarthermal

1%

Figure 1-1: Overview of an impact of administrative barriers on RES technologies, based on REveal database 

The European Union established a framework to meet the 2030 renewable energy target 
with  Directive  2018/2001  on  the  promotion  of  the  use  of  energy  from  renewable  energy 
(RED II) 8, which it followed by introducing a revision of the Directive9 and the REPowerEU 
Plan10. Arts. 15, 16, and 17 of RED II instruct Member States to simplify and accelerate the 
administrative and grid connection procedures for renewable energy projects. Regulation 
2018/1999 also requires Member States to “limit administrative complexity for all relevant 
stakeholders”  (art.  3  par.  3  Regulation  2018/1999).  Thus,  a  comprehensive  EU-level 
framework to facilitate the diffusion of renewables by eliminating barriers that unnecessarily 
hinder their expansion is available, but its implementation is still on its way. 

The aim of this report is to provide insights on the most prominent obstacles which impeded 
the diffusion of renewable energy technologies. It specifically narrows in on the permitting 
and grid connection procedures, which pose a major threat to EU renewable energy and, 
thereby, climate objectives 11. It shows that much has to be done, despite the availability of 
an EU framework and political will on behalf of Member States. The report also discusses 
examples  of  best  practices  Member  States,  Iceland  and  Norway  devised  and  deployed. 
Moreover, it discusses general recommendations based on the research conducted. The 
Consortium sought to condense findings and single out best practices that offered general 
policy  guidance.  We  grouped  good  practices  into  six  different  categories  –  or  “fields  of 
action” – to condense the lessons learnt into more general recommendations. The authors 
of  this  report  believe  that  these  can  address  prevalent  barriers  hindering  new  and 
repowered  renewable  energy  installations.  Finally,  the  report  also  outlines  how  Member 
States  can  streamline  processes  and  introduce  IT  infrastructure  that  comply  with 
requirements imposed by RED II.  

8 DIRECTIVE (EU) 2018/2001 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 11 December 2018 on the 
promotion of the use of energy from renewable sources (recast). 

9 https://commission.europa.eu/document/2caaf8e2-df20-4bdb-bde0-384599b1e82e_en. 

10 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM%3A2022%3A230%3AFIN&qid=1653033742483. 

11 Note that the research on barriers described in the RES Simplify report was completed in July 2021. 

37 

 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

1.2. Short overview of methodology  

The  objective  of  this  study  was  to  establish  an  understanding  of  how  the  approval 
procedures for renewable energy installations can be improved. To this end, the Consortium 
extensively mapped the permitting and grid connection procedures of relevant renewable 
energy  technologies  in  target  countries  (i.e.,  the  27  EU  Member  States,  Norway,  and 
Iceland) in the period from November 2020 until July 2021. This provided insights on the 
most  important  steps  and  permit  requirements  involved  in  the  execution  of  a  renewable 
energy project. It also identified the most significant obstacles when requesting approvals 
from competent authorities or a grid connection permit.  

Research  encompassed  key  steps  necessary  to  develop  renewable  energy  projects 
including, but not limited to, site selection, the issue of the electricity production license, the 
pre-application process, administrative authorisation, obtaining a grid connection, corporate 
legal-fiscal processes, and other relevant steps.  

The Consortium mapped procedures and obstacles for onshore and offshore wind, rooftop 
and ground-mounted photovoltaics, hydropower, solar thermal, and geothermal (including 
heat pumps). The technologies analysed were selected based on the 2030 country-specific 
targets in the NECPs and the growth potential of individual renewable energy technologies 
during this period. Researchers selected the most pertinent technologies based on these 
sources and then traced the barriers hindering their deployment. 

Alongside  identifying  obstacles,  the  Consortium  identified  practices  in  the  administrative 
and grid connection procedures in target countries that can be considered best practices.  
Task 2 of the Assignment (see section 65) analysed these in detail to understand which can 
be  applied  in  the  case  of  other  Member  States  as  well  as  other  process  steps  or 
technologies.   

Prior to conducting the mapping, the Consortium developed draft performance indicators 
(PIs).  These  were  intended  to  help  identify  bases  of  comparison,  so  that  the  respective 
regulation could be further analysed in other cases and used as a best practice reference. 

The Consortium collected data in four-steps: (1) desktop research, (2) expert interviews, (3) 
an online survey, and (4) stakeholder workshops. These streams of data informed country 
reviews.  Desktop  research  covered  the  analysis  of  primary  and  secondary  sources, 
including relevant legislation, official government documents, websites and press releases, 
media articles, other experts’ analyses and, to a certain extent, the academic literature. The 
project  team  also  conducted  interviews  with  the  national  stakeholders  in  all  EU  Member 
States,  Norway,  and  Iceland.  Interviewees  included  experts  affiliated  with  national 
ministries,  authorities,  renewable  energy  associations,  project  developers,  as  well  as 
environmental and aviation organisations. Expert interviews were the key source of data for 
the identification of obstacles and good practices in permitting procedures, but these were 
informed and contextualised by preceding desktop research. 

The  consortium  complemented  data  on  performance  indicators  collected  through  expert 
interviews  with  an  online  survey  targeting  national  stakeholders.  As  a  final  step, 
stakeholders discussed and validated preliminary results of the mapping task in workshops. 
These  discussions  provided  additional  insights  regarding  the  issues  and  best  practices 
stakeholders encounter during the permitting and grid connection procedures for renewable 
energy installations.  

The Consortium produced 29 National Reports 12 based on the desktop research and expert 
interviews, which are annexed to this report (Annex 1).  

12 The national reports were produced in the period from November 2020 until July 2021.  

38 

 
 
 
Simplification of permission and administrative procedures for RES installations 

Permitting best practices were initially based on a literature review. For this, relevant studies 
and  other  publications  from  different  European  countries  were  evaluated.  Additional 
information  was  gathered  through  the  online  survey  and  the  stakeholder  interviews. The 
data collected was the basis for a best practice long list, containing all the best practices we 
identified. This was assessed to select best practices which are considered to be broadly 
transferrable  and  applicable,  while  they  may  have  the  biggest  potential  to  speed  up 
permitting. The short list was the basis for stakeholder workshops with representatives of 
the key renewable energy technologies addressed in this project. These workshops showed 
the need for a highly interactive format to stimulate feedback, and trigger input on additional 
general and technology-specific best practices, which were discussed, validated, and rated. 

Best practices identified and the overall RES Simplify project results were disseminated and 
promoted (Task 3) through a series of 52 activities. Such an endeavour aimed to engage 
and  influence  public  policy  makers  with  the  aim  of  triggering  necessary  measures  to 
accelerate and facilitate permitting and grid connection procedures in EU Member States. 
Moreover, dissemination activities involved private industry stakeholders and civil society 
groups  to  collect  additional  ideas  and  suggestions  for  the  development  of  new  policy 
initiatives to further optimise the permitting process at the EU and national level relevant 
under Task 5. 

In  parallel  to  dissemination  activities  (Task  3),  the  Consortium  monitored  the  legislative 
activity of EU Member States in transposing arts. 15, 16 and 17 of RED II. In the initial stage, 
researchers  with  extensive  knowledge  of  national  policy  frameworks  conducted  desktop 
research and interviews with energy policy experts from national governments with the aim 
of identifying changes in national permitting frameworks resulting from these three RED II 
articles.  Monitoring  was  carried  out  between  April  and  December  2022.  In  addition, 
information  on  the  implementation  of  arts.  15,  16,  17  RED  II  was  provided  by  national 
renewable energy associations at the final stage of the monitoring task. The benchmarking 
exercise identified a number of good practices for each step of the permit granting process 
and assessed countries still lag behind in the effective implementation of RED II and why 
this is the case. 

Best practice recommendations are based on the results of the mapping of administrative 
procedures (including barriers and good practices) in the EU-27, Norway, and Iceland (Task 
1) as well as the further input collected through the dissemination activities (Task 3) and 
monitoring the implementation of arts. 15, 16 and 17 of the RED II in the EU countries (Task 
5). This supports Member States by providing them with best practice recommendations in 
general, while some focus on specific process steps. Based on best practice and further 
literature research, an outline for the deployment of a supporting IT infrastructure was also 
developed in this report. 

1.3. Structure of this report 

This report follows mostly the task structure of the Assignment of the European Commission 
(see Figure 1-2).  

39 

 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

TASK 1  

TASK 2 

Mapping & development of 
performance indicators 

MS Monitoring & identification 
of good practice 

TASK 3 

Dissemination & promotion of good practice 

TASK 5 

Monitoring 
implementation of 
permit granting 
procedures   

TASK 4 

Outline for optimised processes & supporting IT infrastructure 

Figure 1-2:  Task structure of the RES Simplify project (Source: RES Simplify) 

The subsequent sections present the key results of the RES simplify project: 

•  Section 2 describes findings of the mapping of permit granting and grid connection 

procedures and the development of performance indicators (Task 1);  

•  Section 3 presents the results of the monitoring of the Member States based on 

performance indicators (Task 2); 

•  Section  4  provides  an  overview  on  dissemination  activities  and  promotion  of 
identified good practices in permitting and grid access procedures, in line with the 
developed stakeholder engagement plan (Task 3); 

•  Section 5 sheds light on recent developments in permit granting procedures in EU 
Member  States,  following  the  transposition  of  arts.  15,  16  and  17  of  the  RED  II, 
including additional measures (Task 5); 

•  Section  6  scrutinises  the  results  of  the  good  practice  identification  undertaking 

(Task 2); 

•  Section  7  puts  emphasis  on  the  outlined  optimised  process  and  supporting  IT 

infrastructure (Task 4); 

•  Section 8 summarises the conclusions of the RES Simplify project.  

Detailed country-specific information can be found in 29 National Reports (Annex 1). 

40 

 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

2. The mapping of permit granting and grid connection 
procedures  and  the  development  of  performance 
indicators  

2.1. Objectives  

The  main  objectives  of  Task  1  of  the  Commission’s  Assignment  included:  (1)  the 
preparation of a methodology for the mapping of administrative and permitting procedures 
for relevant renewable energy technologies in EU Member States, Norway and Iceland; (2) 
establishing a stakeholder network for the mapping and the subsequent dissemination in 
Task 3; (3) mapping the permitting procedures; and (4) the development of performance 
indicators (PIs). 

2.2. Methodology  

2.2.1. Research and drafting the National Reports  

As  regards  the  practical  undertaking  of  the  mapping  of  permit  granting  procedures  and 
development of performance indicators, Figure 2-1 briefly summarises the methodology the 
Consortium  used  to  ensure  high  quality  results  in  all  target  countries  for  the  mapping  of 
permit granting procedures and the development of performance indicators.  

Step 1: 
Preparation
Final definition of 
research scope

Development of a 
research methodology 
& outline of draft PIs

Pilot research & 
training of eclareon's 
country experts

PI refinement

Step 2: Mapping
Research 
management

Desktop research to 
collect & validate 
existing information

Activate national 
research network & 
stakeholder interviews

Drafting national 
reports & PI 
finalisation 

Step 3: Revision
Experienced team 
members review 
results

Second internal review 
of results by the 
Consortium 

Feedback & review of 
results by external 
national experts 

Figure 2-1: Methodology for the research (Source: RES Simplify) 

2.2.1.1. Scope of examined processes  

The mapping covered the entire permit granting procedures for renewable energy projects 
in the 27 EU Member States and two EEA countries (Norway and Iceland). Based on its 
experience,  the  Consortium  distinguished  between  the  following  process  steps  that  are 
essential for developing renewable energy projects:  

•  Site selection, i.e. the acquisition of the project site (by purchasing or leasing it) and 
any steps necessary to make it legally suitable to host an installation (e.g. initiate 
changes  with  regard  to  local  development  plans  and  zoning,  possibly  including 
Strategic Environmental Impact Assessments (SEIA) etc.). 

41 

 
 
 
 
Simplification of permission and administrative procedures for RES installations 

•  Electricity production license obtainment, i.e. the necessary processes to obtain a 
license to produce electricity. Note that different countries have a different name for 
this license, such as electricity production license, electricity generation license or 
exploitation authorisation. 

•  Pre-application, i.e. the process before submitting an application for a permit to the 
competent  authority,  during  which  the  authority  provides  advice  on  how  the 
developer should apply successfully. 

•  Administrative authorisation, i.e. all processes that pertain to the developer obtaining 
a  license  to  construct  a  renewable  energy  installation,  (e.g.  a  building  permit,  an 
environmental permission including an Environmental Impact Assessment (EIA) or 
a technology-specific permission, for example, a water use permit for hydro-power 
plants or a radar permit for wind power plants). 

•  Grid connection permit, i.e. the formal process to obtain the permission to connect 
the installation to the electricity grid as well as additional processes necessary to 
realise a grid connection. 

•  Corporate legal-fiscal, i.e. all necessary processes to incorporate (if this is legally 
required), become a member of a certain association, to become liable for taxation, 
or  to  become  exempted  from  taxation  –  such  requirements  are  particular 
burdensome for smaller and decentralised installations. 

•  Other relevant, country specific processes that do not fit into the categories listed 

above.  

2.2.1.2. Geographic and technology scope 

The mapping focused on 29 target countries: the 27 EU Member States and the two EEA 
countries (Iceland and Norway). 

To narrow the scope of data that researchers collected during the mapping task, the scope 
of the technologies examined was limited to the two to four most relevant renewable energy 
technologies in each EU Member State. For Norway and Iceland, the permitting procedures 
were mapped for only one key renewable energy technology – hydropower in Norway and 
geothermal in Iceland.  

The target countries’ relevant technologies were selected from the following categories:  

•  wind onshore and offshore;  
•  photovoltaic (rooftop and ground mounted); 
•  concentrated solar power (CSP); 
•  hydropower (small and industrial);  
•  solar thermal; 
•  geothermal technologies and heat pumps;  
•  biogas;  
•  biomass based heat and powerplants. 

Some of these technologies were prevalent in almost all countries, such as wind power or 
photovoltaics  (PV),  while  others  were  only  deployed  in  few,  such  as  geothermal  or 
hydropower.  

The Consortium selected relevant technologies based on the NECPs of target countries. 
Researchers  assessed  which  technologies  are  essential  for  countries  to  achieve  their 
national  targets,  and  they  excluded  the  technologies  that  are  not  affected  by  the 
administrative and permitting issues at the beginning of the research already. NECPs were 

42 

 
 
Simplification of permission and administrative procedures for RES installations 

examined in relation to the national technology mix and renewable energy targets for 2030 
(see Figure 2-2) to identify which technologies will play the greatest role in the country’s 
energy mix by 2030 and which technologies have the greatest growth potential by the end 
of this decade.  

Figure 2-2: Share of technologies in 2020–2030 RES-E deployment, based on NECPs 

Table 2-1 on the next page demonstrates which technologies were mapped in the target 
countries. 

Table 2-1: Technologies covered for the mapping of permitting procedures in the 27 EU Member States, 
Iceland and Norway (Source: RES Simplify) 

43 

 
 
 
 
Simplification of permission and administrative procedures for RES installations 

2.2.1.3. Research and validation of preliminary results 

Researchers  gathered  country-specific  data  in  several  steps:  (1)  desktop  research,  (2) 
expert interviews, (3) online survey and (4) sectoral stakeholder workshops.  

As a first step, the Consortium conducted desktop research. The country-based review drew 
upon  a  range  of  primary  and  secondary  sources  including  relevant  legislation,  official 
government documents, websites and press releases, media articles, expert sources and, 
to  some  extent,  academic  literature.  The  most  important  source  of  information  to  map 
permitting  and  grid  connection  procedures  in  the  target  countries  were  legal  sources, 
including laws, ordinances and legal guidelines. In particular, national documents (national 
and regional level) which transposed EU acts were examined by the research team. Another 
important  data  source  were  handbooks  and  guidelines  that  describe  how  of  renewable 
energy projects can be developed in target countries. 

In addition to the desktop research, the Consortium conducted numerous interviews with 
national  stakeholders  in  all  target  countries  including  national  ministries,  authorisation 
bodies, renewable energy associations, project developers as well as environmental and 
aviation associations or organisations. Expert interviews were the key source of information 
to identify key obstacles and good practices. They also provided the quantitative data for 
performance indicators (e.g. process duration, approval rates, etc.).  

For the collection of country-specific quantitative data on the performance indicators, the 
Consortium  launched  an  online  survey  targeting  the  representatives  of  wind  and  solar 
power  sectors.  These  representatives  also  circulated  the  survey  among  European 
associations and project developers. The goal was to gather data from stakeholders that 
are  in  direct  contact  with  permitting  authorities  and  in  this  way  gain  an  insight  into  the 
situation developers face on the ground. 

To validate the qualitative and quantitative data collected through desktop research, expert 
interviews  and  the  online  survey,  the  Consortium  organised  stakeholder  workshops  with 
representatives of wind and solar power, hydropower, solar thermal and geothermal energy 
sectors.13  These  workshops  provided  an  additional  source  of  information,  especially  with 
regard  to  prevailing  barriers  and  good  practices  in  the  permitting  and  grid  connection 
procedures.   

2.2.1.4. Drafting the National Reports  

Based on the validated research results, the Consortium drafted 29 National Reports in the 
period from November 2020 until July 2021 that describe country-specific results. National 
Reports describe permitting and grid connection processes, identified obstacles and good 
practices, as well as other pertinent findings (Annex 1).  

The National Reports structure national findings along the procedural steps distinguished 
by the Consortium. This conveys our findings in a sequential and thereby comprehensible 
manner. In addition, the reports contain a traffic light assessment indicating how severely 
individual process steps are affected by the barriers detected during the mapping. This is 
based  on  the  Consortium’s  assessment  based  on  the  expert  interviews  and  desktop 
research. The National Reports also discuss the use of IT in administrative and permitting 
processes  as  well  as  the  complaint  procedures  of  permits  requested  and  pending 
procedural  decisions.  Finally,  the  reports  provide  information  on  the  existence  of  certain 
specific features to ease administrative and permitting procedures (e.g. One Stop Shop) or 

13 No stakeholder workshop was organised with the biomass industry, as permitting and grid connection issues are not relevant 
for the biomass sector, according to the Bioenergy Europe.  

44 

 
 
 
Simplification of permission and administrative procedures for RES installations 

national  contact  point,  implementation  of  “two  plus  one” 14  or  “one  plus  one”  rules 15,  pre-
application  consultation,  measures  to  streamline  litigation  by  third  parties,  etc.)  and 
quantitative data on the predefined performance indicators for Task 2 of the Assignment.    

2.2.2. Performance indicators 

The performance indicators were developed based on a three-step methodology: 

2.2.2.1. Development of a preliminary set of performance indicators 

Performance  indicators  of  RES  Simplify  were  defined  to  indicate  in  which  countries  the 
permitting of renewable electricity (RES-E) is functioning well. They were the basis for the 
evaluation of permitting best practices. We assume that Member States with high rates of 
renewable  deployment  have  well-designed  administrative  and  permitting  processes. 
Understanding how these processes are designed and how they can be transferred to other 
Member States is a part of Task 2, described in section 3. 

The  defined  indicators  covered  the  performance  of  processes  and  they  gathered 
information  on  the  specificities  of  a process.  This  means  that  indicators  not  only  yielded 
information  on  how  well  processes  function,  but  they  also  captured  the  reason  for  their 
success. Therefore, information researchers gathered on well-functioning processes also 
provided insights on best practices. 

The  basis  for  the  definition  of  indicators  were  the  tender  specifications  and  a  further 
screening of relevant documents.  

Indicators cover the efficiency and effectiveness of procedures. Efficiency covers the speed 
of  a  process.  During  efficient  processes,  authorities  can  take  decisions  quickly,  and 
processes take little time to be finished.  

Effectiveness  describes  how  well  authorities  come  to  a  clear  decision.  The  goal  of  a 
permitting process should be to provide project developers with concrete answers. This can 
be  positive  and  suggest  that  a  project  is  legally  permitted.  This  allows  for  developers  to 
proceed with their project and litigation can only emerge as an issue if parties involved were 
negligent. Authorities can also take a negative decision and reject the developer’s request 
for a permit. This may occur, if documents are insufficient or show that the project should 
not be realised. Without “black or white” decisions, developers face uncertainty. It becomes 
unclear if they can realise or if they need to adjust their initial plans. 

The following Table 2-2 gives a structured overview over the performance indicators that 
were defined to analyse efficiency and effectiveness of permitting procedures. 

14 According to Art. 16 (4) RED II, the permit-granting process for power plants shall not exceed two years, including all relevant 
procedures of competent authorities. Due to extraordinary circumstances, this two-year period may be extended by up to one 
year.  

15 According to Art. 16 (5) RED II, the permit-granting process shall not exceed one year for installations with an electrical 
capacity of less than 150 kW. Due to extraordinary circumstances, this one-year period may be extended by up to one year. 
In addition, the length of repowering procedure of existing renewable energy plants shall not exceed one year. Also here, this 
one-year period can be extended due to extraordinary circumstances, e.g. on grounds of overriding safety reasons where the 
repowering project impacts substantially on the grid or the original capacity, size or performance of the installation (Art. 16 (6) 
RED II).   

45 

 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

Table 2-2: Overview of performance indicators for RES-E permitting procedures (Source: RES Simplify) 

s
s
e
n
e
v
i
t
c
e
f
f

E

y
c
n
e
i
c
i
f
f

E

Project Developers 

Stakeholders 

Project approval rates & legal challenges 

Stakeholder interests 

How high or low are project approval rates? 
How high is the % of projects that are legally challenged? 

Yearly installed renewable capacities 

What share of the yearly necessary capacity expansion has 
been reached in preceding years? 

Are Stakeholders 
taken into account 
when projects are 
permitted? 

Deadlines and total process duration 

Stakeholder interests 

Do deadlines exist in the overall process or individual process 
steps? 

How long does the overall process and/or individual steps 
take? 

Can stakeholders 
participate without 
any barriers? 

Costs of administrative procedures 

What are the costs for developers to deal with administrative 
procedures? 

Transparency  of  administrative  and  grid  connection 
procedures and the resources of authorities 

Are processes understandable? Do planners know the state of 
their application? 

One Stop Shop 

What is the number of authorities and grid operators that must 
be contacted? 

Alongside  effectiveness  and  efficiency,  the  Consortium  defined  indicators  gauging 
stakeholder  participation,  since  this  can  also  have  a  significant  impact  on  renewable 
deployment. Stakeholder participation is linked to the increased acceptability of renewable 
energy projects. Opportunities for their participation, therefore, can help support renewable 
deployment as litigation occurs less frequently. 

These indicators described permitting procedures. They indicated efficiency and provided 
information on whether facilitative institutions (e.g. a One Stop Shop) was present in target 
countries. Beyond the evaluation of single indicators, their combination was also possible. 
This provided an overview of the overall process and could give an idea of possible effects 
due to the shape of the process.  

2.3. Key findings  

2.3.1. Onshore wind  

2.3.1.1. 

Introduction 

Research  on  onshore  wind  was  the  most  expansive  of  all  technologies  since  it  covered 
almost all EU Member States. Wind power can be deployed in nearly all regions of the EU, 
since countries have adequate resources (i.e. wind) to support the technology and it is an 
economically competitive source of energy as well. As a consequence, all NECPs (aside 
from  Hungary  and  Malta)  foresee  a  robust  growth  in  wind  power,  both  in  onshore  and 
offshore, particularly in Member States such as Latvia, Estonia, the Netherlands, Ireland, 
Finland, Belgium and Germany. Figure 2-3 provides an overview of the planned installed 
capacities  across  the  whole  EU,  which  underlines  the  ambitious  deployment  plans  of 
governments.  

46 

 
 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

LV
EE
NL
IE
FI
BE
DE
LT
FR
SK
ES
PL
GR
RO
DK
LU
PT
AT
IT
CZ
HR
SI
BG
CY
MT
HU

99%

96%

88%

72%
72%
71%

67%

29%

47%

41%

39%
38%
38%
38%

33%
31%
31%
30%
29%

24%
23%

17%

18%

16%

9%
9%
7%

84%
82%

77%

100%

94%

12%

14%

6%

24%
7%

28%

33%

54%

53%

43%

51%

48%

52%

52%

69%

61%

55%

73%
74%

32%

49%

11%

7%

9%
13%
6%
15%

8%

11%

7%

8%
7%

9%

0%

20%

40%

60%

80%

100%

Wind

Solar PV

Solar CSP

Hydro

Biomass

Geothermal

Other

Figure 2-3: National targets for wind power development (Source: NECP) 

This  positive  outlook  stands  in  contrast  to  historic  deployment.  Figure  2-4  illustrates  the 
development  of  newly  installed  capacities  from  the  past  ten  years.  These  figures 
demonstrate  that  EU-wide  deployment  of  new  wind  power  capacities  was  somewhat 
unstable and particularly weak since 2017, especially in the case of onshore wind.  

0,3

10,6

W
G
n

i
y
t
i
c
a
p
a
C

14,0

12,0

10,0

8,0

6,0

4,0

2,0

0,0

0,5

0,2

2,4

1,4

1,5

0,0

0,6

8,4

9,3

7,5

1,1

7,5

9,6

9,4

9,7

10,5

1,5

1,7

8,6

7,1

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Onshore

Offshore

Figure 2-4: Development of wind power capacities 2009-2019 (Source: EurObserv’ER & eclareon) 

47 

 
 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

What is more, the deployment of wind power in the past ten years was concentrated in a 
few countries. Figure 2-5 illustrates the geographical distribution of wind power deployment 
across the EU. It shows that more than 75% of all new wind power capacities were installed 
in merely six Member States and 32% of total growth took place in Germany. This stark 
concentration  of  deployment  limited  to  a  few  markets  can  only  be  explained  to  a  limited 
degree  with  economic  strength,  power  demand,  or  the  size  of  the  respective  Member 
States. In a sense it is puzzling that Member States with the highest targets for wind power 
(Latvia, Estonia, the Netherlands, and Ireland) have shown the lowest deployment in the 
past ten years. Thus, they need to substantially boost deployment. 

Figure 2-5: Installed wind capacities across EU MS 2009-2019 (Source: EurObserv’ER & eclareon) 

These  results  are  somewhat  surprising,  considering  that  the  prices  for  wind  power  have 
gone down significantly in most Member States due to a strong decrease of financing and 
installations costs. The recent deployment figures in markets like Sweden and Finland also 
show  that  strong  investments  in  wind  power  are  possible  even  if  the  existing  support 
schemes are insufficient to stimulate diffusion or there is simply no scheme in place because 
of  new  investment  opportunities  through  power  purchase  agreements  (PPAs).  Past 
research indicates that administrative and grid issues play an increasing role as roadblocks 
for wind power deployment. The REveal database, a comprehensive database of more than 
1,000  barriers  to  renewable  power  deployment,  shows  that  almost  half  of  the  identified 
barriers were connected to administrative or grid issues, as Figure 2-6 below summarises. 
It is essential to better understand what kind of administrative and grid barriers occur and 
under which conditions in order to support the continued diffusion of wind power.  

48 

 
 
 
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Administrative & 
Grid Issues
46%

Other
54%

Figure 2-6: Overview of share of administrative & grid issues (Source: REveal database) 

2.3.1.2. Overview of the key process steps  

Figure 2-7 provides a breakdown and assessment of relevant process steps that must be 
tackled by investors in Member States to realise wind power projects. These do not provide 
a detailed description of the actual steps necessary to technically realise and implement 
individual wind power projects in the respective Member States 16. Instead, it matches the 
severity of barriers based on our research to indicate which project phases are considered 
particularly  problematic  in  which  Member  State.  At  such  general  level,  the  processes 
investors  must  execute  to  complete  a  project  are  quite  similar  in  Member  States. 
Researchers identified seven main processes: site selection, electricity production license, 
application  preparation  process,  administrative  authorisation,  grid  connection  permit, 
corporate legal-fiscal, and other. Of these, site selection, administrative authorisation, and 
obtaining a grid connection permit were required in all Member States; electricity production 
licensing was necessary almost everywhere; corporate legal-fiscal steps were required in 
about half of all Member States; lastly, application preparation processes and other steps 
were only required in a few Member States.  

16 Belgium is represented twice in this overview since regional difference between Flanders (BE1) and Wallonia (BE2) were 
so large that the two regions had to be treated as two different markets.  

49 

 
 
 
 
Simplification of permission and administrative procedures for RES installations 

Figure 2-7: Traffic light assessment of project implementation process steps for onshore wind (Source: RES 
Simplify) 

The colour code distinguishes between  

•  Member States that were not covered in the research because there are no wind 

power projects and thus no experience from project developers (black), 

•  Process steps that did not exist in a Member State (white), 
•  Process steps that did not contain any barriers (green), 
•  Process steps where project developers merely faced minor barriers (yellow), 
•  Process steps that brought about moderate barriers (red), 
•  Process  steps,  that  could  not  be  concluded  successfully  because  they  contained 

such severe barriers (purple) and  

•  Project steps that could not be concluded because severe barriers in earlier process 

steps made the project impossible (shaded black and white).  

The  overview  of  the  Member  States  reveals  that  the  most  problematic  step  was 
administrative  authorisation:  There  was  only  one  Member  State,  Denmark,  where  no 
barriers were identified that were connected to administrative procedures. In more than half 
of all Member States, moderate or even severe barriers were found. In Estonia, Romania 
and  Slovenia,  the  administrative  barriers  were  so  severe  that  project  development  was 
effectively  blocked.  In  Estonia  and  Slovenia,  these  severe barriers  were  due  to  a  mix  of 
lengthy  procedures  and  public  protests  against  wind  power  projects.  In  Romania, 
administrative  authorisation  was  effectively  rendered  impossible  because  of  complex 
procedures  without  a  timeline,  lack  of  communication  by  the  authorities  and  different 
application of the laws in communities.  

The  second  most  problematic  process  step  was  grid  connection.  As  with  administrative 
authorisations, there were at least some barriers in almost all Member States but overall, 
these barriers were less severe. The main exception was Slovakia where an existing grid 
moratorium effectively banned any deployment of wind power (and other renewable power) 
projects at the time of the mapping.  

Another relevant (and problematic) step was site selection. Barriers were identified in fewer 
Member States in contrast to administrative and grid barriers. Still, in a third of the Member 

50 

 
 
 
Simplification of permission and administrative procedures for RES installations 

States moderate barriers or severe barriers occured. In Latvia, for instance, municipalities 
effectively prevented zoning of wind power projects, which renders further process steps 
impossible and thereby impedes the diffusion of the technology. In other Member States, 
issues  of  site  selection  were  typically  linked  to the  lack  of  available  sites,  in  most  cases 
because of conflicting public goods that will be discussed below.  

2.3.1.3. Key barriers per process step  

Across  all  Member  States,  almost  350  barriers  were  identified  that  hinder  onshore  wind 
deployment. These barriers can be categorised in four groups:  

•  process-related issues,  
•  conflicting public goods,  
• 
third party issues and  
•  grid issues.  

The separation into these four groups was very often not entirely clear because there were 
interdependencies between them. Still, this grouping will allow for a better understanding of 
barrier  characteristics,  identification  of  good  and  best  practices,  as  well  as  allow  for  the 
formulation of tangible and effective recommendations.  

2.3.1.3.1. 

Process related issues 

“Process-related issues” encompasses barriers that are mainly caused by the way in which 
administrative and grid processes are executed. The following map provides an overview, 
which barriers were present in which Member States.  

51 

 
 
 
Simplification of permission and administrative procedures for RES installations 

Figure 2-8: Overview of process-related issues for onshore wind (Source: RES Simplify) 

They represent the majority of all identified barriers for onshore wind, almost half of them 
fall  under  this  category.  Of  these  barriers,  about  a  third  (58)  were  connected  to  barriers 
related to bureaucratic issues, which were identified in 22 out of the 27 Member States 
(with no particular geographic distribution). Bureaucratic issues have the following structural 
elements:  Lengthy  and  complex  procedures;  additional,  unexpected,  and  burdensome 
requirements (such as expert reports) that must be submitted during the permitting process; 
a  large  number  of  authorities  that  have  to  be  approached  and  involved;  the  lack  of 
communication by authorities; and rules that force project permitting to be restarted due to 
minor changes of the technical design.  

This barrier was not only a problem because the realisation of the wind power projects may 
take longer than expected, but such delays can prevent project developers from realising 
entire  wind  power  projects.  In  some  Member  States  (e.g.  Estonia,  Finland,  Italy,  or 
Sweden), it was reported that administrative procedures take so long that by the time the 
administrative process is concluded, the project might not be economically viable anymore 
because the technology has become obsolete. This risk was further aggravated in Member 
States with auction-based support schemes. In these cases, if a concluded administrative 
process was a requirement for placing a bid, then developers may have missed their chance 
to participate in tenders. In such cases (in Italy, for example) project developers could miss 
their chance to establish viable business models.  

In Bulgaria or Ireland, further interdependencies with grid connection procedure steps made 
the process’ implications more complex, because the grid connection procedure must have 
been concluded within six months. Project developers were then forced to work sequentially 
(and not in parallel) and a delay in the administrative process could result in a delayed grid 
connection process. Such delays increased risks for the project developer and increased 
the costs of the project.  

The  second  largest  identified  group  of  barriers  revolved  around  non-transparent 
processes. This barrier reflects processes with insufficiently documented guidelines, but it 
also includes issues such as authorities not communicating with each other and demanding 
documents that cannot be obtained at that stage of the given process (as in Romania). Non-
transparent  processes  could  also  stem  from  a  power-imbalance  between  the  project 
developer vis-a-vis the administrative authority or the grid operator. Such imbalances could 
materialise in decisions by the authority that could not be retraced or comprehended (e.g. 
Bulgaria), data that was decisive for the administerial decision which were not revealed by 
the  authority  or  the  grid  operator  (as  in  Belgium,  Germany),  discretion  which  allowed 
authorities  to  interpret  laws  inconsistently  without  explanation  (e.g.,  Romania)  and  that 
prevented project operators to file an appeal when authority decisions are delayed (e.g. in 
Poland). 

The  third  largest  process-related  issue  was  connected  to  the  staffing  problems  of 
authorities and grid operators. The challenge was either that authorities were understaffed, 
and their technical experts were overwhelmed leading to delays or that respective staff lacks 
expertise – the issue could be a combination of both. Staffing issues were predominantly a 
problem in large Member States, as it was reported in Germany, France, Italy, Spain (where 
the problem is larger at national level than at regional level), and Poland (both local and 
central level), and in wealthier Member States, such as Austria, Denmark, Luxemburg, and 
Sweden.  

Lack  of  expertise  was  often  reported  in  nascent  wind  power  markets  such  as  Bulgaria, 
Estonia,  Finland,  Ireland  or  Romania.  Here,  the  lack  of  expertise  was  often  due  to 
inexperience and occured at the local level or is in relation to complex technical questions 
(e.g.  environmental  conflicts).  Considering  the  demand  for  experts  by  the  wind  power 
industry and the difference in salaries, it was an additional challenge to keep experienced 
staff  working  in  the  public  sector.  Staffing  issues  aggravated  other  barriers  because 

52 

 
 
Simplification of permission and administrative procedures for RES installations 

authorities did not have enough time to structure, align, and coordinate their work allowing 
for smooth execution of administrative processes. 

Insufficient spatial planning was a serious process-related issue that hampered onshore 
wind deployment. A typical problem was when there was no spatial planning or that existing 
plans  did not sufficiently account for (current) development (as in Cyprus). The opposite 
and  more  common  problem  was  that  spatial  plans  were  used  to  restrict  or  prevent  wind 
power projects (Austria, Czechia, Germany, Greece, and also Latvia, the Netherlands and 
Portugal).  

Even if spatial planning processes were used to enable wind power development, problems 
could occur. Project developers reported that the spatial planning process can take too long, 
as  was  reported  in  Austria,  Denmark,  Finland,  Germany.  On  the  other  hand,  careful 
preparation of plans was necessary to ensure that spatial plans can be upheld when legally 
contested.  After  all,  flawed  legal  bases  of  spatial  plans  could  create  a  high  level  of 
uncertainty that deters investors, as reported in Romania. An additional problem was that 
spatial plans that were enacted at regional and local level differ from each other or from 
national  targets.  Such  disparities  further  impeded  processes  (Italy,  Spain,  Ireland).  This 
could also coincide with splintered ownership, since more neighbours and stakeholders had 
to be involved. This issue was highlighted in Latvia and Slovakia, but this was probably a 
problem also in other post-soviet states, where land was re-allocated during the transition 
in the 1990s. 

2.3.1.3.2. 

Conflicting public goods 

If  process-related  issues  aggregated  barriers  that  are  connected  to  the  “how”  of 
administrative process, the group of conflicting public goods focused on the “what”. It covers 
barriers,  where  wind  power  projects  collided  with  other  (legitimate)  public  goods.  These 
public goods were in most cases:  
•  Environmental issues,  
•  Land use conflicts,  
•  Aviation and military conflicts.  

The  following  map  provides  an  overview,  which  barriers  were  present  in  which  Member 
States. 

53 

 
 
Simplification of permission and administrative procedures for RES installations 

Figure 2-9: Overview of issues concerning conflicting public goods for onshore wind (Source: RES Simplify) 

Environmental issues were identified in 23 Member States, which makes this group the 
second most prevalent after bureaucratic issues. In some Member States, it was also one 
of the most severe barriers (e.g. Cyprus, Germany, Lithuania, Slovenia, Sweden). Barriers 
under this group can be the result from conflicts over the protection of a single species (such 
as the famous red kite in Germany or bats in Austria) or the protection of the environment 
in general. These conflicts can ensue with environmental groups. However, quite often they 
took place with or even between different public entities, such as environmental authorities, 
agencies and ministries.  

Another focal point of many conflicts was the EIA that had to be conducted either during the 
administrative process of an individual project or as a SEA during the preceding planning 
process. The EIA originates from EU law and deadlines established by RED II shall apply 
without prejudice to them (art. 16 (7) RED II). Since a complete EIA required in most cases 
census  involving  all  seasons,  an  EIA  has  become  a  main  reason  for  extended  project 
realisation  periods  (in  Germany,  for  example,  it  added  about  two  years  to  the  process). 
However,  in  some  Member  States,  the  EIA  was  connected  with  specific  national 
requirements, such as a municipal veto in Sweden, which was the actual impediment. Also, 
there was a broad consensus among project developers that a balance with environmental 
goods  in  general  is  necessary,  as  is  the  need  for  EIAs  in  particular.  In  fact,  project 
developers were often rather concerned about specific details linked to EIAs, for example 
that EIAs diverged from Member State to Member State or that data from these were not 
available in publicly available repositories.  

Land use conflicts were almost as common as environmental issues (they were identified 
in 20 Member States), but it seems that they were less severe in most cases. The conflicts 
were  mainly  about  agriculture  land  and  urban  settlements.  Although,  in  certain  Member 

54 

 
 
 
Simplification of permission and administrative procedures for RES installations 

States  (like  Italy)  it  was  about  other  issues,  specifically  tourism.  Nevertheless,  these 
conflicts pushed new wind power projects further out into environmentally protected zones, 
which aggravated the above-described environmental issues. In other countries (such as 
Belgium),  it  has  also  led  to  speculation  over  attractive  sites.  This  caused  a  substantial 
increase in land prices with a spill over into agricultural land and consequently damaging 
the reputation of wind power.  

Aviation and military conflicts generally emerged due to the impact of wind power plants 
on  civil  and  military  radar  systems,  but  they  had  a  wider  scope,  including  issues  with 
neighbours  because  of  signal  lights  on  wind  power  plants.  These  conflicts  were  less 
prevalent than land-use conflicts, for instance, since they were only common in nine to ten 
Member  States.  However,  in  a  surprisingly  high  number  of  these  countries  (Estonia, 
Finland, Germany, and Lithuania), they were considered as one of the most severe barriers 
to wind power development. In this barrier, the geographical allocation was distinct, since 
most Member States where this issue was identified are located in the North-East of the EU 
(thus closer to the border with Russia).  

As  with  environmental  issues,  the  main  criticism  was  not  about  a  priority  of  aviation  or 
defence  interests  per  se,  but  rather  about  the  matter  being  addressed  in  an  adequate 
manner, such as through investment into modern radar equipment that resolves this issue 
(Lithuania).  A  more  procedural  criticism  was  that  military  boards  can  take  decisions  that 
obstruct the operations of a plant at a very late point of a project’s development, when a lot 
of resources have already been committed, or even after the project has been permitted 
(Finland,  France  and  Sweden).  Experts  also  noted  the  lack  of  harmonised  regulation 
between the Member States in this realm.  

2.3.1.3.3. 

Third-party issues 

Third-party issues refer to barriers in which the relationships between project developers 
and  other  stakeholders  (both  public  and  private)  were  central  (i.e.  the  “Who”).  As  with 
conflicting public goods, these barriers were less widespread than bureaucratic issues, but 
their impact could be highly severe for individual projects and the industry more broadly. 

The  map  on  the  next  page  provides  an  overview,  which  barriers  were  present  in  which 
Member States. 

55 

 
 
Simplification of permission and administrative procedures for RES installations 

Figure 2-10: Overview of third-party issues for wind onshore (Source: RES Simplify) 

The  most  common  barriers  in  this  context  were  connected  to  the  lack  of  political  and 
public interest in onshore wind projects. Such barriers were identified in 16 EU Member 
States and described barriers linked to public institutions being passive and not reforming 
administrative processes (for example in Czechia, regions in France, Germany, Sweden or 
Finland – the latter is constrained by the Finnish constitution). Cases have also emerged 
where public institutions took steps to actively hinder onshore wind projects, for example 
through preventive planning (see above) or regulations that defined the necessary distance 
between wind power projects and urban dwellings – these may also be dependent on the 
height of the wind power plants (as in Bavaria). Such conflicts may have occured at national 
and regional level, but more often they manifested at local level. For this reason, rules that 
allow  municipalities  to  benefit  from  wind  power  projects  in  their  territory  created  a 
particularly  important  incentive  to  demolish  barriers.  Very  often,  however,  there  was  no 
political interest to overcome barriers due to public resistance.  

Public resistance was identified in twelve EU Member States. There is no clear regional 
pattern  visible.  Instead,  public  resistance  was  widespread  in  a  number  of  countries  and 
manifested  in  the  public  protests  of  private  stakeholders.  The  motivation  of  the  protests 
differed and could encompass protest for very specific reasons (for example environment), 
a  NIMBY  (“not  in  my  backyard”)  attitude,  and  hostility  towards  renewable  energies  in 
general or wind power in particular. In most cases such protests were organised in a bottom-
up manner. However, during the research, cases (for example in Estonia and Germany) 
came up where the protests were led by organised groups of non-locals. It goes beyond the 
scope of this research to assess how common such organised protesters are, but it would 
be  very  important  for  a  broad  understanding  to  look  in  more  detail  at  such  groups,  their 
impact in terms of prevented installations and strategies to address such protests.  

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Third-party complaints are connected to the barrier of public resistance (above), but refers 
to  wind  onshore  projects  being  legally  contested,  be  it  in  court  or  in  administrative 
processes.  Such  issues  were  reported  in  ten  Member  States  (mainly  Northern  and 
Western), in four of them (Denmark, Finland, Ireland and Slovenia) they caused barriers 
that  were  considered  particularly  severe.  The  main  reason  why  these  barriers  are 
considered so severe is that they can substantially delay projects, especially since art. 16 
(7) RED II applies, which means that extension due to judicial proceedings do not count 
against the deadlines determined by the RED II. In Finland and Ireland, the impact of third-
party complaints was particularly strong because the right to complain was not limited to 
persons who were actually affected by the wind power plants. This allowed individuals to 
hinder wind power plants throughout the country for a very broad set of reasons, including 
ideological or even commercial ones. This issue was further aggravated if the court system 
is overwhelmed, which was reported as a particular challenge in Denmark.  

2.3.1.3.4. 

Grid issues 

Grid issues differ from the above-described barriers because they have a specific focus on 
the  process  step  of  grid  connection.  Most  of  these  barriers  were  linked  to  insufficient 
capacities,  but  another  important  barrier  was  due  to  communication  issues  with  grid 
operators. The following map provides an overview, which barriers were present in which 
Member States. 

Figure 2-11: Overview of process-related issues for wind onshore (Source: RES Simplify) 

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Simplification of permission and administrative procedures for RES installations 

The most common barrier (in 13 Member States) concerned issues regarding the cost of 
a  grid  connection,  especially  when  the  connection  required  an  expansion  of  the  grid. 
Depending on the legally regulated allocation of costs, wind developers could face huge 
sums. Other project developers complained about the lack of transparency when costs were 
calculated (as in Spain), changing rules for calculating tariffs, or prohibitive tariffs negatively 
impacting projects that were not involved in support schemes (Romania).  

Barriers related to grid infrastructure were highlighted in 13 Member States. This barrier 
refers  to  insufficient  grid  capacities  and  the  problems  that  resulted  from  it.  This  barrier 
seemed  particularly  serious  in  Spain,  where  several  identified  barriers  fell  under  this 
category.  One  important  reason  for  lacking  capacities  was  that  the  planning  of  the 
infrastructural  development  was  not  launched  in  time  (as  in  Austria).  Another  important 
issue  was  also  speculation:  market  actors  have  an  incentive  to  hoard  and  sell  grid 
connection  permits  when  grid  capacities  decline.  Such  behaviour  was  an  unintended 
consequence  of  current  Spanish  government’s  decision  to  accelerate  renewable  energy 
deployment. Similar problems of reserved capacities were also reported in Austria, Estonia 
and  Hungary.  These  issues  are  well  known  for  at  least  ten  years,  but  still  have  to  be 
addressed  (RES  Integration,  2011).  One  way  of  addressing  this  issue  is  to  introduce  a 
deadline  until  when  the  project  must  be  ready  for  construction.  This  solution  has  been 
introduced in Latvia, however the duration of the period of six months was criticised as being 
too short. 

TSO  (transmission  system  operator)/DSO  (distribution  system  operator)  problems 
included  barriers  where  conflicts  occured  with  the  grid  operator.  Such  issues  were  less 
common  (in  nine  Member  States)  but  could  have  detrimental  consequences  (in  four 
Member States). This is the case in Slovakia, where the distribution grid operators have 
formulated  a  grid  moratorium  for  any  installations  larger  than  10  kW,  which  rendered 
effectively  all  deployment  impossible.  Other  barriers  in  this  context  were  information 
asymmetry and delayed communication which impeded a number of projects (Greece).  

2.3.2. Offshore wind  

2.3.2.1. Introduction  

Offshore  wind  power  development  has  significantly  increased  in  the  past  years,  due  to 
plummeting generation costs and ambitious plans in the NECPs. The actual development 
is  still  limited  to  a  smaller  number  of  markets,  but  a  number  of  Member  States  have 
announced to focus on its deployment. Still, for the time being, this assessment focused on 
those countries where projects have been developed. Figure 2-12 below gives an overview 
of these Member States and an assessment of relevant process steps.  

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2.3.2.2. Overview of the key process steps 

Figure 2-12: Traffic light assessment of project implementation process steps for offshore wind (Source: RES 
Simplify) 

The evaluation of offshore wind processes was much better than those of onshore wind in 
the  same  Member  States.  With  the  exception  of  Sweden  and,  to  some  extent,  Ireland, 
process steps in most Member States were considered relatively easy and unproblematic. 
The  most  striking  example  was  the  Netherlands,  where  no  significant  barriers  were 
identified across all process steps. But Belgium was similar in the sense that the overall 
process was administered at federal level and has been evaluated quite positively by project 
developers. Development in Poland was still in its infancy and thus it was too early to be 
fully evaluated at the time of the mapping.  

The  structure  of  process  steps  is  similar  to  onshore  wind  and  the  barriers  link  to: 
administrative  authorisation,  grid  connection  and  site  selection.  It  is  hard  to  tell  why  the 
administrative process of offshore projects was considered easier than those onshore. On 
the one hand, it is actually surprising, considering that offshore was still technically more 
challenging, while project developers and public authorities have had less time to gather 
experience. On the other hand, the administrative process for offshore wind was designed 
from scratch and could benefit from experience with onshore wind.  

2.3.2.3. Key barriers  

The  structure  of  the  description  of  barriers  will  follow  the  structure  of  onshore  wind  and 
cover the following categories:  
•  process-related issues,  
•  conflicting public goods,  
• 
third party issues and  
•  grid issues.  

2.3.2.3.1. 

Process related issues 

Process  related  issues  were  identified  in  all  examined  Member  States.  They  were 
particularly problematic in Sweden, where researchers identified about a third of all barriers 

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within this category and four of them were particularly severe. Several barriers occurred in 
Denmark, albeit none of them were particularly severe. Furthermore, fewer and less severe 
barriers were reported in Germany and Ireland.  

As  with  onshore  wind,  most  process-related  issues  were  connected  to  bureaucratic 
issues.  In  Sweden,  the  main  point  of  hindrance  was  the  large  number  (around  ten)  of 
uncoordinated permits required by authorities. These are similar in the issues with which 
they deal and require similar assessments but can still result in contradicting decisions. This 
lack of legal coherence could cause problems both for project developers and investors in 
terms  of  cost  and  completion  schedules  of  projects.  This  barrier  was  aggravated  by 
authorities’ inexperienced staff, who struggled with executing processes.  

The  main  barrier  in  Germany  was  that  developers  have  to  complete  a  large  number  of 
comprehensive  expert  reports.  In  Denmark,  bureaucratic  issues  usually  only  occured  in 
Open Door processes, which is a specific type of auction with a stronger initiative for the 
project developer in contrast to the so-called Government Call for Tenders. In case of the 
Open Door process their length and the discretion of authorities were the main barriers.  

Another  barrier  that  was  reported  relatively  often  in  Belgium,  Germany  and  Ireland 
concerned the lack of a sufficient legal framework. In Germany, this was only a problem 
in the case of coastal offshore, which did not fall under the authority and legal framework of 
the federal scheme, but those of the regions.  

2.3.2.3.2. 

Conflicting public goods 

As indicated earlier, conflicting public goods were much less of an issue than in case of 
onshore wind. The only barriers that were identified (both severe though) were in Sweden 
and Germany. In Sweden, the municipal veto was integrated in the EIA and was estimated 
to be responsible for approximately 40% of wind power project rejections. The main barrier 
in Germany was the limited number of sites because of other competing interests, such as 
nature conservation, fishing, shipping and military interests.  

2.3.2.3.3. 

Third-party issues  

Third-party complaints were a common issue in Sweden, Germany and Denmark. In the 
case  of  the  latter,  they  were  regarded  as  particularly  severe  because  appeals  could  be 
formulated against many different administrative decisions and processing time at the board 
of appeals is prolonged.  

In Sweden, the main third-party issues were connected to the lack of political and public 
interest.  Most  barriers  were  linked  to  an  unwillingness  to  overcome  impediments  and 
improve current processes. Necessary actions could include providing greater flexibility with 
regards to turbine placing in the so-called “box model” or the introduction of a single contact 
point that covers both the administrative and the grid connection process. This fell short 
because of a quite narrow interpretation of the RED II.  

2.3.2.3.4. 

Grid issues 

Grid  issues  were  relevant  in  Sweden  and  in  Ireland,  but  they  constituted  a  particularly 
pressing issue in Germany at the time of the mapping. The main reason for this was that 
the grid development is feared to become a bottleneck for future offshore deployment. One 
problem according to the literature was the quasi-monopolistic structure of grid operators in 
the  Baltic  Sea  and  North-Sea  area.  This  caused  high  connection  and  grid  development 
costs  for  project  developers  and  end-consumers.  However,  due  to  the  limited  space  at 
German’s coastline it was difficult to allow German wind offshore developers to provide their 
own grid development. In Ireland, the main issue was grid operators curtailing offshore wind 
power output, increasing investor risks.  

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2.3.3. Ground-mounted PV 

2.3.3.1. Introduction 

Solar PV is one of the most used renewable energy technologies across the EU and its 
share in the renewable energy mix is expected to drastically increase. Figure 2-13 provides 
an overview of the additional installed capacities Member States have indicated they would 
reach in their NECPs over the period 2020-2030. All Member States expected to deploy PV 
and in 15 out of 27 more than 50% of their planned renewable energy installations were set 
to  be  solar  PV.  Governments  favoured  it  across  the  board,  including  Southern  Member 
States  such  as  Malta,  Bulgaria  and  Cyprus  with  ample  solar  radiation,  Member  States 
where wind was not planned to be deployed such as Hungary and Czechia, and even in 
Northern Member States such as Denmark, Lithuania or Poland.  

MT
HU
SI
BG
CY
CZ
IT
DK
LU
PT
LT
FR
GR
RO
ES
PL
SK
DE
AT
BE
IE
HR
NL
FI
EE
LV

100%

94%

84%

82%

77%

74%
73%

69%

61%

55%
54%
53%
52%
52%
51%

48%

43%

33%

29%
28%

24%

18%

12%

17%

6%

2%
1%

29%

16%

72%

96%
99%

9%

9%

7%

9%

8%
7%

23%
24%

31%

30%

31%

47%

41%

38%

33%

38%

38%

39%

67%

71%

72%

88%

32%

49%

8%

11%

6%
15%
9%
13%

11%

7%

7%

7%

14%

0%

20%

40%

60%

80%

100%

Solar PV Wind

Solar CSP

Hydro

Biomass

Geothermal

Other

Figure 2-13: National targets for solar power development (Source: NECP) 

As is the case with wind onshore, this quite positive outlook stands in contrast to the past 
ten years of PV development. Figure 2-14, below, depicts installed solar PV capacities in 
the past 10 years. Following a strong period of growth between 2010-2012, the deployment 
of PV drastically fell until 2018, when it slowly began to recover.  

61 

 
 
 
 
Simplification of permission and administrative procedures for RES installations 

W
G
n

i
y
t
i
c
a
p
a
C

25,0

20,0

15,0

10,0

5,0

0,0

19,8 21,1

16,0

9,1

5,9

4,5

4,2

3,9

4,8

15,1

7,3

2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Figure 2-14: Development of solar PV capacities 2009-2019 (Source: EurObserv’ER & eclareon) 

This  disruption  of  PV  deployment  was  mainly  due  to  discontinued  support  schemes, 
retroactive changes in regulation and other unfavourable turns in policies. Still, recent years 
have been more supportive of the technology and have brought about its strong rebound. 
This was partially due to renewed ambitions from some Member States (such as Spain) 
and a continuous spread of decentralised installations. In addition, continuously declining 
costs  and  other  market  developments  have  supported  new  business  models  that  were 
partially independent of classic support schemes. Administrative and grid access barriers 
were the key obstacles for PV in general, but especially in the case of projects that did not 
rely on support schemes.  

2.3.3.2. Overview of the key process steps 

The six process steps discussed above applied to ground-mounted PV as well.  

AT BE1BE2 BG CY CZ DE DK EE ES FR GR HR HU IE IT LT MT NL PL PT RO SI SK

Site selection

Electricity production 
licence
Application 
preparation process
Administrative 
authorization

Grid connection permit

Corporate legal-fiscal

Other

2

2

2

3

1

1

2

2

1

4

1

1

4

4

1

2

2

2

3

1

2

1

3

3

2

2

3

2

1

2

1

1

2

1

1

2

2

1

2

3

2

1

2

3

1

2

1

2

3

1

2

2

2

3

2

2

2

1

3

2

1

3

2

3

3

1

1

1

1

3

1

1

3

3

3

1

2

1

1

2

1

3

1

2

2

2

3

2

2

1

1

2

1

2

2

3

3

2

1

2

3

3

1

1

3

4

1

2

1

3

2

1

1  Flanders

No barriers identified

Severe barriers identified

2  Wallonia

Minor barriers identified

Process step not relevant

Moderate barriers identified

No projects implemented

Figure 2-15: Traffic light assessment of project implementation process steps for ground-mounted PV (Source: 
RES Simplify) 

The traffic light assessment of the Member States highlights that for ground-mounted PV, 
the most difficult steps were obtaining administrative authorisation and a grid connection 

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Simplification of permission and administrative procedures for RES installations 

permit.  Only  Ireland  and  Latvia  reported  administrative  authorisation  as  a  non-issue. 
Researchers  found  minor  issues  in  Belgium  (Flanders),  Denmark  and  Croatia,  amongst 
others. Moderate barriers were reported in numerous Member States, mainly in Central or 
Southern Europe.  

The situation was the direst in Slovakia with regards to a grid connection permit. Here, there 
was a de facto moratorium for new, larger RES installations, including ground-mounted PV, 
at  the  time  of  the  mapping.  Moderate  barriers  were  encountered  across  Member  States 
from Austria to Italy and Hungary to Greece. Sometimes, the difficulties originated from a 
combination of barriers. This was the case in Hungary, for instance, where developers faced 
potentially  high  grid  connection  costs,  inexperienced  and/or  inflexible  DSOs,  a  nearly 
saturated grid and slow grid development.  

Minor  barriers  were  encountered  in  almost  all  Member  States  regarding  site  selection. 
Ground-mounted  PV  was  competing  with  other  forms  of  land  use  in  areas  with  a  high 
population density. This was mentioned as one of the main reasons Flanders, Belgium saw 
close  to  no  development  in  ground-mounted  PV.  Meanwhile,  ground-mounted  PV  often 
clashed with the interests of the agricultural sector in Austria and Greece.  

Some  barriers  were  also  reported  in  connection  to  corporate  legal-fiscal  and  electricity 
production licenses in some Member States. These two process steps were not relevant in 
roughly half of the Member States.  

2.3.3.3. Key barriers  

Similarly to the previous sections on onshore and offshore wind, this section on the most 
significant  barriers  ground-mounted  PV  faced  is  divided  into  four  sections  based  on  the 
barrier type (process-related, conflicting public goods, third party issues, and grid issues).  

2.3.3.3.1. 

Process related issues 

Parallel to onshore wind, the majority of encountered barriers are classified under process 
related  issues.  The  following  map  provides  an  overview,  which  barriers  were  present  in 
which Member States. 

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Figure 2-16: Overview of process-related issues for ground-mounted PV (Source: RES Simplify) 

The largest sub-category of process-related issues connected to ground-mounted PV was 
bureaucracy, which accounted for 53 barriers across Member States. Bureaucracy could 
bring  about several  different  issues,  for  example  lengthy  permitting  processes  (Portugal, 
Slovenia), a large set of separate permits whose processes were not particularly compatible 
and harmonised (Cyprus, Italy), and a confusing or unclear legislative and policy framework 
(Croatia, Czechia). These administrative issues led to prolonged and expensive permitting 
procedures, which slowed ground-mounted PV projects significantly or even kept investors 
from  realising  them.  Bureaucratic  issues  have  been  reported  in  connection  with  several 
process  steps:  site  selection,  administrative  authorisation  and  grid  connection.  In  many 
cases, bureaucracy was intertwined with other process-related issues. 

As ground-mounted PV installations take up large areas of land, several barriers have been 
listed under the sub-category of insufficient spatial planning across EU Member States. 
In Cyprus, the lack of appropriate planning of renewable energy sources (RES) has led to 
high uncertainty for project developers as any authority could halt a project at any given 
point of the permitting process. What is more, the Ministry of Agriculture, Rural Development 
and the Environment has suspended all integrated environmental authorisation processes 
for renewable energy installations at the time of the mapping due to the lack of a coherent 
RES spatial planning framework.  

Serious obstacles were also identified in other Member States. In Bulgaria, ground-mounted 
PV installations could only be constructed on what was classified as “industrial land”, limiting 
site selection options. In Denmark, the spatial planning process of a large PV installation 
could  take  up  to  4  years.  This  was  an  especially  pervasive  issue  for  small  project 
developers, which could not progress with another project as they were awaiting planning 
decision. This large delay was caused by the lack of designated spaces for RES; instead, 

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spatial planners waited for renewable energy developers to signal what they should provide 
for renewable energy installations in the existing plan.  

The  most  severe  barrier  for  some  Member  States  was  connected  to  the  lack  of  legal 
coherence and lack of guidelines. In Czechia, building authorities across the country had 
vastly  different  interpretations  of  land  use  and  building  regulations  when  it  comes  to 
constructing  PV  installations  –  this  was  flagged  over  a  decade  ago  (Ecorys,  2010). 
Differences  in  the  interpretation  of  legal  documents  was  reported  as  a  serious  issue  in 
Romania  as  well,  where  some  authorities  required  documents  at  a  stage  when  these 
documents have not been issued by other authorities. In Spain, there was incompatibility 
between  the  two  levels  of  permitting  authorities:  regional  and  local  for  projects  with  a 
capacity under 50 MW, and national for larger projects.   

Staffing  problems  (see  2.3.1.3.1)  were  frequently  mentioned  by  experts  in  relation  to 
ground-mounted  PV  permitting  processes.  Competent  authorities  frequently  lacked  the 
expertise  or  sufficient  capacities  to  process  applications  efficiently.  Shortage  of  staff  for 
processing applications for ground-mounted PV was also identified in Poland, Italy, France, 
Slovenia,  and  Croatia.  Croatian  experts  noted  that  the  competent  permitting  authorities 
have increased their level of expertise on renewable energy technologies lately, reaching a 
satisfactory level, but that the shortage of staff still led to delays.   

2.3.3.3.2. 

Conflicting public goods  

A total of 46 ground-mounted PV barriers detected fall under the category of conflicting 
public  goods.  The  map  on  the  next  page  provides  an  overview,  which  barriers  were 
present in which Member States. 

Most of these barriers were either related to land use conflicts or the environment. The 
latter was identified in twelve Member States. The length, requirements and costs of EIA 
procedures form similar barriers as with onshore wind, see section 2.3.1.3.2. Further issues 
vary  by  type  and  severity.  In  Lithuania,  national  EIA  legislation  and  its  interpretation 
guidelines  did  not  define  what  constitutes  a  “significant  visual  impact”  when  permitting  a 
renewable energy installation, resulting in incoherent EIA conclusions. This vague definition 
posed  a  substantial  challenge  for  project  developers,  as  they  did  not  have  guidelines  to 
follow. Meanwhile, renewable energy projects, mainly onshore wind and ground-mounted 
PV, were virtually blocked by environmental concerns in Cyprus.  

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Figure 2-17: Overview of issues related to conflicting public goods for ground-mounted PV (Source: RES 
Simplify) 

In Germany, the environmental impacts of underground cables were likely to be examined 
more closely in the future, which is likely to impose further costs on project developers and 
slow  the  grid  connection  process.  EIA  processes  were  not  only  criticised  by  RES 
developers, but also by environmentalist organisations. In the latter case, it was typically an 
issue of EIA’s not being stringent enough. In France, there was increasing resistance to 
onshore wind and ground-mounted PV projects, with those opposed to them arguing that 
environmental  assessments  were  not  conducted  thoroughly  and  too  many  renewable 
energy  projects  were  realised  in  a  close  proximity  to  one-another,  degrading  the  local 
environment.   

As  a  land  intensive  technology,  ground-mounted  PV  installation  developers  continuously 
faced challenges over land use conflicts across Member States. In some regions of the 
Czechia,  regional-level  strategic  planning  documents  were  too  restrictive  to  renewable 
energy technologies – mainly to onshore wind and ground-mounted PV – even if the natural 
conditions would be ideal for these technologies. 

One of the most common barriers was the conflict over whether the land should be used for 
agriculture or ground-mounted PV. For example, in Germany, PV installations erected on 
arable land frequently did not qualify to receive renumeration under the Renewable Energy 
Act (Erneuerbare-Energien-Gesetz - EEG). This weighs on the growth of ground-mounted 
PV. Greece, in turn, has witnessed arguments between projects developers and pastoral 
farmers,  who  were  both  interested  in  similar  land  areas.  Hungarian  renewable  energy 
developers  faced  high  land  prices due  agricultural  subsidies,  while  repurposing  of  other, 
less fertile land, was not always possible or required intensive lobbying. 

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2.3.3.3.3. 

Third-party issues 

In comparison to wind power projects, third-party issues were less a problem for ground 
mounted PV.  

The  complex  public  resistance  and  third-party  complaints  were  an  issue  in  seven 
Member States, namely Belgium, Bulgaria, Croatia, Denmark, Estonia, Greece, Germany, 
Hungary,  Ireland,  Italy,  Lithuania,  Romania,  Slovakia,  and  Slovenia.  In  Denmark,  main 
barriers – third-party complaints concerning EIA process and reluctance from municipalities 
to engage in planning – were not as pronounced as they were for wind projects. The same 
applies for the NIMBY-phenomena in Estonia and Germany – it was present, but not as 
pervasive as with wind. In Croatia, France, and Slovenia, on the other hand, public protests 
– mainly over the use of land – also concerned ground mounted solar projects.  

A lack of public and political interest was identified in even fewer Member States (six). 
An example was Hungary, where construction codices were not updated although their up-
to-date versions would be necessary to streamline permitting. Another example was Italy, 
where public consultation processes did not sufficiently engage local communities at the 
time of the mapping.  

2.3.3.3.4. 

Grid issues 

Grid  issues  posed  a  substantial  barrier  for  ground-mounted  PV.  Most  of  the  identified 
barriers, however, were indirectly connected to administrative processes and only fall within 
the scope of this study to a limited extent. The map on the next page provides an overview, 
which barriers were present in which Member States. 

Figure 2-18: Overview of grid issues for ground-mounted PV (Source: RES Simplify) 

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Simplification of permission and administrative procedures for RES installations 

The main issues were linked to conflicts with grid operators. This type of barrier hindered 
the deployment of ground-mounted PV in Bulgaria, Czechia, Denmark, Germany, Greece, 
Hungary,  Slovakia,  and  Spain.  In  Slovakia,  DSOs  have  introduced  a  grid  connection 
moratorium that made the deployment of installations larger than 10 kW at the time of the 
mapping  impossible.  In  other  markets,  the  actions  of  grid  operators  were  not  quite  this 
drastic, but could still seriously impede the diffusion of the technology. The main problems 
in  that  context  were  information  asymmetry  between  the  developers  and  the  DSOs  on 
technical issues (Germany and Hungary), delays in communication and other actions that 
are needed to conclude the connection (Czechia, Denmark, Greece) as well as a lack of 
clarity and communication on DSO interpretations of technical and financial data (Austria, 
Bulgaria,  Cyprus,  Czechia,  Estonia,  and  Hungary).  Interviewees  levelled  more  severe 
criticism  towards  DSOs  in  Spain,  where  the  allocation  of  grid  connection  points  was 
administered  by  private  single  point  partners.  These  were  occasionally  also  renewable 
energy generators and thus possible competitors. Stakeholders in Hungary criticised that 
many  DSO  experts  still  lack  the  understanding  or  the  willingness  to  deal  with  the  “new” 
reality of decentralised energy generation and are organised in bureaucratic structures that 
further slow processes.  

As with wind, the main grid issue related to the cost of grid connection and expansion. 
This was reported in eleven Member States (Austria, Bulgaria, Denmark, Estonia, France, 
Germany, Hungary, Ireland, Malta, and Romania). In Austria, Malta and Romania, project 
developers already voiced the concern that many PV projects were not viable anymore due 
to high costs. In Austria, the grid related costs accounted for more than 20% of the total 
investment  costs  of  ground-mounted  PV  projects.  The  frequent  need  for  additional  grid 
extensions  made  many  projects  economically  unviable.  In  Bulgaria,  the  legal  framework 
was more favourable toward plant operators, because the DSO had to cover the costs of 
the grid expansion in principle. However, in practice, this did not always happen.  

In Denmark and France, concerns regarded future development. In Denmark, the reform of 
the  cost  allocation  for  grid  connections  worried  PV  project  developers,  as  it  might  have 
rendered existing business models economically unattractive. In France, stakeholders were 
concerned with the trend of increasing connection costs. The fact that the grid connection 
and expansion must be borne by project developers were also a key barrier in Estonia and 
Hungary. In the latter case, the problem was aggravated by the huge variance between the 
costs for substations between DSOs. There was also no system in place to distribute the 
costs between different projects, when more than one connected to the grid – essentially, 
the first in need of the connection bore the costs. 

The underlying problem of cost issues was often due to grid limitations. Those were either 
the consequence of a lacking grid infrastructure (Bulgaria, Cyprus, Estonia, Germany, 
Greece,  Hungary,  and  Italy).  In  some  Member  States,  however,  this  problem  was 
aggravated  by  developers  reserving  grid  capacities  and  not  using  them  (as  in  Austria, 
Estonia  or  Hungary).  This  was  also  linked  to  alleged  speculation  (Spain),  as  discussed 
above for onshore wind. Another acute problem worsening over time was the ageing of the 
grid, reported as an issue in Bulgaria and France. Ultimately, this could impede developers’ 
ability  to  realise  some  projects  or,  as  a  worst-case  scenario,  DSOs  could  impose  a 
moratorium, as was the case in Slovakia. 

2.3.4. Rooftop PV 

2.3.4.1. Introduction 

Rooftop  PV  installations  were  the  most  common  renewable  energy  installations  across 
almost all EU Member States – the Nordic countries were the only notable exceptions. In 
Finland and Sweden, the issue was, however, not only the lack of solar radiation, but also 
the support schemes in place since they did not prioritise small, decentralised renewable 

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Simplification of permission and administrative procedures for RES installations 

energy installations. At the same time, their power prices were too low to allow the diffusion 
of rooftop solar. Consequently, they play a minor role in this part of the analysis.  

2.3.4.2. Overview of the key process steps 

The  traffic  light  assessment  of  key  process  steps  provides  an  overview  of  23  Member 
States. On a positive note, the overall process for rooftop solar was simpler than onshore 
wind  or  ground-mounted  PV  projects.  This  was  not  surprising,  considering  site  selection 
and  most  of  the  time  administrative  processes  were  less  of  an  issue.  The  simplicity  of 
procedures was also linked to their relatively small size and since they were completed by 
residents  who  generally  lacked  the  ability  to  deal  with  a  larger  administrative  burden. 
Nonetheless, there were a number of moderate barriers in Denmark, as was the case in a 
few other countries. 

AT BE1BE2 BG CY CZ DE DK EE ES FR HR HU IT LT LU LV MT NL PL PT RO SI SK

Site selection

Electricity production 
licence
Application 
preparation process
Administrative 
authorization

Grid connection permit

Corporate legal-fiscal

Other

1

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1  Flanders

No barriers identified

Severe barriers identified

2  Wallonia

Minor barriers identified

Process step not relevant

Moderate barriers identified

No projects implemented

Figure 2-19: Traffic light assessment of project implementation process steps for rooftop PV (Source: RES 
Simplify) 

2.3.4.3. Key barriers  

Most of the barriers that hampered the deployment of rooftop systems were similar to those 
that  hindered  ground-mounted  PV  installations.  Although,  there  were  rooftop-specific 
barriers as well. This section assesses these according to the barrier classification system 
applied for other technologies as well (process-related, conflicting public goods, third-party 
issues, and grid issues). 

2.3.4.3.1. 

Process related issues 

Barriers related to bureaucracy are cases where the administrative effort or the waiting time 
is  not  in  proportion  to  the  size  of  the  project.  This  was  criticised  in  Denmark,  where  the 
application process for a 200 kW installation could take six to eight months at the time of 
the  mapping.  This  was  aggravated  in  the  case  of  mid-size  projects  for  which  some 
municipalities asked for a complex procedure (Denmark, Latvia), while other municipalities 
did not require permits at all. Such incoherent rules and long waiting times made planning 
quite difficult. Another impediment was that residential rooftop solar plant users needed to 
meet certain tax and commerce obligations. These were not a problem for larger projects 
but seem out of proportion in case of small systems, as was the case in Germany.  

69 

 
 
 
Simplification of permission and administrative procedures for RES installations 

2.3.4.3.2. 

Conflicting public goods 

Conflicting public goods were less common for rooftop systems, but some were reported in 
Malta.  There,  the  redevelopment  of  two-  or  three-storey  buildings  into  multi-storey 
apartment  blocks  increased  how  lower  rooftops  were  overshadowed.  This  could  render 
existing  rooftop  PV  plants  useless.  Careful  zoning  and  early  communication  within  local 
communities might help address this issue.  

2.3.4.3.3. 

Grid issues 

Grid  issues  are  linked  to  the  inability  of  DSOs  to  assesses  the  impact  of  decentralised 
rooftop  systems  on  the  stability  of  the  grid.  In  Poland,  the  number  of  PV  prosumers 
increased from 4,050 in 2015 to 457,443 in 2020. Some grid operators were growing worried 
about this fast growth and claimed that they should have the right to disconnect installations 
if  output  is  too  high.  This  demand,  however,  might  undermine  the  business  case  of 
prosumers and could lead to additional procedural disadvantages. In Germany, most grid 
operators have set up simplified connection procedures for rooftop PV installations (usually 
below  30  kWp)  but  some  grid  operators  required  those  that  install  any  rooftop  solar  PV 
installation  to  go  through  the  regular  grid  connection  process,  which  overly  burdened 
developers of small capacities.  

2.3.5. Hydropower  

2.3.5.1. Introduction  

Hydropower is an important factor in the success of the EU’s energy transition due to its 
low  CO2  emissions  intensity  and  its  ability  to  balance  variable  wind  and  solar  power 
production. Hydropower has a long history in Europe and much of its available potential has 
already been tapped (Kelly-Richards et al., 2017; Venus et al., 2020). Nearly 650 TWh are 
generated  in  an  average  hydrological  year  within  Europe  (including  Turkey),  which 
feasible  hydropower  potential 
corresponds 
(Hydropower-Europe, 2021; see Figure 2-20).  

to  around  65%  of 

the  economically 

Figure 2-20: Evolution of yearly production and installed capacity of hydropower in Europe since 2005 
(Source: Hydropower-Europe, 2021; Hydropower & Dams World Atlas, 2020) 

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Simplification of permission and administrative procedures for RES installations 

Figure  2-21  demonstrates  the  untapped  potential  of  hydropower  in  different  European 
countries. In many of these countries there was still a considerable potential for expanding 
hydropower.  Some  target  countries  –  Bulgaria,  Greece,  Slovakia,  Poland,  Czechia, 
Hungary, Cyprus, and Iceland – have tapped into less than 50% of their economical feasible 
potential so far (Hydropower-Europe, 2021). 

Figure 2-21: Generation and extension potential of hydropower in the European countries (Source: 
Hydropower-Europe, 2021; Hydropower & Dams World Atlas, 2020) 

Nevertheless, not many Member States saw a significant role for hydropower in their energy 
mix as can be seen from the NECPs (see Figure 2-22).  

This  was  partly  because  despite  the  large  potential  of  hydropower,  most  sites  for  large 
hydropower plants in the European countries were already used. As a result, around 75% 
of future hydropower projects will have to be small or medium-sized (Kelly-Richards et al., 
2017).  Consequently,  this  report  focuses  more  on  small-scale  hydropower,  but  also 
repowering, which is relevant for large hydropower plants (see e.g. section 2.3.5.3.4). 

71 

 
 
 
 
Simplification of permission and administrative procedures for RES installations 

HR
RO
PT
SK
FI
GR
AT
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PL
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LT
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16%
15%

11%
11%
7%
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6%

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1%

18%

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Hydro

Solar PV Wind

Solar CSP

Biomass

Geothermal

Other

Figure 2-22: National targets for hydropower development (Source: NECPs) 

2.3.5.2. Overview of the key process steps  

This section provides an overview over the key process steps for the implementation of a 
small  hydropower  project  in  ten  EU  Member  States:  Austria,  Germany,  Estonia,  France, 
Greece, Italy, Lithuania, Latvia, Sweden, and Slovenia 17.  

Figure 2-23 shows that the assessment of the process steps for small hydropower projects 
were  more  negative  than  the  assessment  for  wind  and  solar  PV.  The  most  problematic 
process step in all ten countries was administrative authorisation. It encompassed severe 
barriers  in  Germany,  France,  Sweden,  Estonia,  Latvia,  and  Lithuania,  meaning  that 
deployment  of  hydropower  was  almost  impossible  because  of  these  barriers.  In  the 
remaining  four  countries  –  Austria,  Greece,  Italy,  and  Slovenia  –  administrative 
authorisation was impaired by moderate barriers. Two key obstacles made this stage of the 
project implementation extremely difficult: firstly, issues related to concessions, which fell 
under administrative authorisation procedure, and secondly, the deterioration ban stipulated 
in art. 4 (1) of the Water Framework Directive 18 (Directive 2000/60/EC - WFD; see section 
2.3.5.3.1).  

17 Since based on the NECPs, hydropower will not play a key role in achieving national renewable energy targets for 2030 in 
the  great  majority  of  the  EU  Member  States  (see  Figure  2-22),  data  for  the  traffic  light  assessment  was  collected  in  an 
interactive workshop with the small hydropower representatives from the ten Member States represented in Figure 2-23.   

18 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32000L0060 

72 

 
 
 
 
 
Simplification of permission and administrative procedures for RES installations 

Figure 2-23: Traffic light assessment of project implementation process steps for small hydropower (Source: 
RES Simplify) 

In the three Baltic States, namely, Estonia, Lithuania, and Latvia, developers undertaking 
site selection faced severe obstacles. This was mainly because no sites were available for 
hydropower projects due to environmental constraints. In Lithuania, for example, the Law 
on Water (art. 3) prohibited building dams on ecologically and culturally valuable rivers. In 
2004, the government approved the list of such rivers and, as a result, dams were banned 
from being built for any purpose on 169 rivers (Jatautas and Kasiulis, 2016).  

In Italy, developers of small hydropower projects faced moderate barriers in the application 
preparation process. This was mainly due to an increasing opposition from environmental 
non-governmental organisations (NGOs) and fisheries.   

As  can  be  seen  on  Figure  2-23,  obtaining  an  electricity  production  license  and  grid 
connection appeared to be the least problematic process steps in the vast majority of the 
ten European countries examined with regard to small hydropower. In Greece, however, 
connection to the grid was one of the fundamental barriers to the approval of all renewable 
energy technologies, including hydropower. The reason was that the Independent Power 
Transmission  Operator  (IPTO)  as  well  as  the  Hellenic  Distribution  Network  Operator 
(HEDNO)  were  overburdened  with  the  provision  of  connection  offers  as  well  as  with  the 
review of the grid connection offers for re-designed ones, i.e. those that have amended the 
characteristics of their projects (e.g. capacity, etc.).  

In France and Italy, corporate legal-fiscal processes faced moderate obstacles. In France, 
this affected projects that had to be authorised before tendering procedure. However, the 
permitting process for hydropower was expensive, especially due to complex environmental 
impact assessments. This could lead to high losses for a small operator, if the tender fails.  
Larger operators were in a better position to take on these risks by spreading the costs over 
many projects.      

2.3.5.3. Key barriers  

This section provides an overview of the most important barriers to small hydropower in the 
permitting procedures across target countries at the time of the mapping. The most severe 
barriers  that  the  developers  of  small  hydropower  projects  faced  were  related  to  the 
concession as well as the deterioration ban stipulated in the Water Framework Directive. In 
addition, national stakeholders reported that the approval procedure for small hydropower 
projects were time consuming and complex. The reasons for this included the involvement 
of a large number of authorities, and, in some cases, the lack of coordination between those 
involved.  Moreover,  national  stakeholders  communicated  numerous  requests  from 
competent  authorities  for  additional  documents  and  a  low  level  of  digitalisation  in  the 

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Simplification of permission and administrative procedures for RES installations 

permitting processes as further obstacles adversely affecting project implementation. These 
and other barriers for small hydropower projects are discussed in more detail below.    

2.3.5.3.1. 

Concession related issues  

One  of  the  key  obstacles  for  hydropower  were  different  legal  frameworks  for  the  use  of 
water  resources  across  the  EU.  In  some  of  the  EU  Member  States,  the  use  of  water 
resources  fell  under  authorisation  regime  (e.g.  Belgium),  while  in  others  (e.g.  Sweden, 
Greece, Spain), a concession needed to be obtained for the use of water by the developers 
of hydropower projects. In France, for example, a mix of both regimes was in-place: small 
hydropower  installations  (under  4.5  MW)  fell  under  an  authorisation  regime,  while  larger 
ones needed to bargain for a concession (Weisrock, 2021; Morgan, 2021). In the case of 
authorisations, the competent authority stipulated the prerequisites for the activity and the 
authorisation was usually granted at the request of the applicant. In addition, the holder of 
an  authorisation  was  free  to  withdraw  from  the  authorised  activity.  In  contrast  to 
authorisations, concession agreements contained obligations that were legally binding for 
both sides. The execution of activity was subject to specific requirements that were defined 
by the contracting public authority (EC, 2019). 

In addition, the length of the concession and the definitions of concessions for small and 
large hydropower differed from Member State to Member State (Weisrock, 2021; Morgan, 
2021).  More  country-specific  information  on  the  concession  can  be  found  in  Table  2-3, 
below.    

Table 2-3: Concessions for hydropower in European countries (Source: Morgan, 2021) 

Country 
Belgium 

Austria  

Portugal 

Greece 

Spain 

France 

Italy 

Some aspects of concessions  
Permits are issued for 20 years for both small and large hydropower installations. There is 
no competitive procedure. 

Permits  are  issued  for  up  to  90  years.  Power  plants  up  to  10  MW  fall  under  small 
concessions  and  larger  ones  under  large  concessions.  Permits  are  issued  by  the 
competent authorities at district, federal and provincial levels. 

Permits are usually issued for 35 years. The maximum duration is 70 years. As in Austria, 
power  plants  up  to  10  MW  fall  under  the  definition  of  small  concessions  and  those 
exceeding 10 MW under the definition of large concessions. In theory, the renewal of the 
permit is a competitive process. Nevertheless, the incumbent has the advantage. 

The duration of concessions is 10 years. All current concessions will expire in 2022, when 
all River Basin District Management Plans must be put in place. Large concessions are for 
hydropower plants larger than 15 MW. 

The  duration  of  concessions  is  75  years.  The  dividing  line  between  small  and  large 
concessions is 10 MW.  

The  duration  of  large  concessions  is  30–40  years.  They  are  issued  by  the  Ministry  of 
Energy. Small concessions are issued at regional level for 30 years. Large concessions 
are for hydropower plants larger than 10 MW.  

From  2024,  competitive  tenders  will  be  in  place  for  large  concessions.  The  Antitrust 
Authority wants to have competitive tenders for all concessions according to the Service 
Directive19 (Directive 2006/123/EC). The duration of concessions differs per region. The 
dividing line between small and large concessions is 3 MW. 

Germany  

In  some  cases,  there  the  concessions  have  unlimited  duration  (Altrechte).  In  general, 
however, the concession is issued for 30–60 years. There is no competitive tendering in 
place. There are regional differences. 

Thus, clarity and harmonisation were needed to create a level playing field for small-scale 
hydropower. According to the industry representatives, there was a need to harmonise the 

19 https://eur-lex.europa.eu/legal-content/de/TXT/?uri=CELEX:32006L0123. 

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length of concessions and the definition of large and small hydropower to create certainty 
and allow for calculable investment decisions. 

Another legal issue related to concession – raising concerns within the small hydropower 
industry  –  was  whether  concession  should  fall  under  the  Service  Directive  (Directive 
2006/123/EC, also called Bolkestein Directive). While authorisations fell under the Services 
Directive  (Directive  2006/123/EC),  concessions  were  covered  by  public  procurement 
regulations  (Directive  2014/23/EU,  also  called  Procurement  Directive).  According  to  the 
European  Commission,  the  Services  Directive  in  particular  covered  situations  where  the 
number of authorisations for an activity was limited due to the scarcity of natural resources 
or technical capacities (e.g. scarcity of water resources). In these cases, transparent and 
impartial selection procedure for authorisations was crucial (EC, 2019).  

Concession  agreements  must  comply  with  EU  regulations  on  public  procurement  and 
concessions. Compliance with these rules has to ensure that concession agreements are 
awarded  through  competitive,  open,  transparent  and  well-regulated  tender  procedures 
(ibid.). As of March 2019, seven infringement procedures were initiated by the European 
Commission  regarding  concessions  on  the  grounds  of  insufficient  transparency  and 
impartial selection procedures (Morgan, 2021).  

The  concession  procedure  for  large  hydropower  plants  was  a  very  lengthy  and  costly 
process,  according  to  the  hydropower  industry.  For  small  hydropower  plants,  the 
concession process was less complicated, but there were still many small administrative 
problems. 

2.3.5.3.2. 

Deterioration  ban  of  the  Water  Framework  Directive 

(WFD)  

Society’s perception of hydropower is ambiguous. On the one hand, it is a renewable source 
of electricity that provides an answer to climate change and energy security concerns and, 
on the other hand, a local environmental challenge given the impact on river ecosystems 
and local biodiversity, especially if the installation of the hydropower plant entails substantial 
interference with the environment of the water source (Abazaj et al., 2016). 

The Water Framework Directive, adopted in 2000, created a common legal framework for 
the  integrated  management  of  water  resources  in  EU  Member  States  (Starke  and  Van 
Rijswick, 2021). The main aim of the Directive was to ensure the good status of all European 
water bodies, i.e. to achieve high water quality and good living conditions for aquatic flora 
and fauna. For this reason, this directive prioritised ecological considerations, such as the 
protection and enhancement of biodiversity (UBA, 2015).  

In order to at least keep the current state of quality of water bodies, art. 4 WFD introduced 
a deterioration ban (Starke and Van Rijswick, 2021; art. 4 WFD). However, a hydropower 
project could be approved by the competent authority if it falls under the exemption from the 
deterioration ban in accordance with art. 4 (7) of the Directive (EREF, 2021). Art. 4 (7) WFD 
stated  that  Member  States  do  not  breach  the  Directive  if  new  sustainable  development 
activities  lead  to  a  body  of  surface  water  to  deteriorate  from  high  to  good  status.  More 
specifically, the following conditions need to be met by the project for the exemption from 
the deterioration ban to be applied (art. 4 (7) par. a-d WFD):  

•  All practicable mitigation measures are taken to mitigate the adverse impact on the 

status of the water body, 

•  The reasons for those modifications or alterations are of overriding public interest 
and/or the benefits to the environment and to society are outweighed by the benefits 
of  the  new  modifications  or  alterations  to  human  health,  to  the  maintenance  of 
human safety or to sustainable development, 

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Simplification of permission and administrative procedures for RES installations 

•  The beneficial objectives served by those modifications or alterations of the water 
body cannot for reasons of technical feasibility or disproportionate cost be achieved 
by other means, which are a significantly better environmental option and 

•  The  project  and  the  reasons  for  it  are  set  out  and  explained  in  the  River  Basin 

Management Plans (art. 13 WFD). 

Thus, a hydropower project can only be authorised if the competent authority considers the 
project to be a project of overriding public interest. 

As highlighted by representatives of the small hydropower industry, the vague definition of 
overriding  public  interest  leaves  room  for  different  interpretations  by  authorities.  Despite 
Schwarze Sulm decision of the European Court of Justice (ECJ) (decision C-346/14 of 4 
May  2016) 20,  where  the  Court  admitted  that  the  energy  transition  is  an  overriding  public 
interest  and  therefore  may  fall  under  the  exemption  to  the  ban  on  deterioration,  the 
deterioration ban and, specifically, the interpretation of this clause by the national authorities 
constituted one of the biggest obstacles to the small hydropower sector.  

Industry  representatives  complained  that  the  Water  Framework  Directive  was  almost 
always the only benchmark for the competent authorities when deciding on the approval of 
a  hydropower  project.  The  advantages  of  hydropower,  such  as  the  reduction  of  CO2 
emissions  and  thus  contribution  to  climate  protection,  water  retention,  groundwater 
stabilisation, flood protection or social aspects were not taken into account in the decision-
making process (BDW, 2021). Hence, there should be a better alignment of the renewable 
energy  and  environmental  goals  in  the  RED  II  and  the  WFD  to  allow  for  the  further 
deployment  of  small-scale  hydropower  to  meet  the  goals  of  the  EU  Green  Deal. 
Furthermore, the harmonisation of the WFD implementation should be ensured by national, 
regional  or  local  authorities,  given  that  the  implementation  of  the  WFD  falls  within  their 
competence.  They  also  have  a  large  margin  of  discretion  in  the  implementation  of  the 
Directive (as described above) and so the decisions of the responsible authorities in the 
various  countries,  regions  or  municipalities  could  significantly  differ  under  the  same 
conditions.    

2.3.5.3.3. 

Time-consuming and complex approval procedures 

One of the obstacles faced by the small-scale hydropower developers across the EU were 
time-consuming  approval  procedures.  There  were  several  factors  that  caused  lengthy 
administrative procedures. First, the stakeholders interviewed for this report highlighted that 
the approval process was often prolonged by requests from competent authorities for 
additional documents to supplement applications for approvals, for example further expert 
opinions.  Stakeholders  admitted  that  procedural  delays  are  possible  due  to  insufficient 
documentation by the applicant. However, this was sometimes alleged by the authorities to 
justify the excessive length of the procedure. Documents were then frequently returned to 
the  applicant  due  to  minor  problems.  However,  each  such  rejection  of  the  documents 
delayed the process by 2-4 weeks. The reasons for the back and forth were often linked to 
experts or authorities seeking to establish legal protection, e.g. out of fear of a claim for 
damages.  To  address  this  issue,  therefore,  the  legal  deadlines  and  the  limitation  on  the 
number of such requests are of crucial importance. 

Another factor that was responsible for the lengthy administrative procedures was the large 
number  of  authorities  involved  in  the  approval  process.  In  Greece,  the  “water  use 
authorisation” was one of the most bureaucratic processes for realising a small hydropower 
project.  Seven  to  eight  agencies  were  involved  in  the  issue  of  this  licence  alone  (forest 
agency,  archaeological  agency,  Natura  2000  site  administrator,  etc.)  at  the  time  of  the 

20 https://eur-lex.europa.eu/legal-content/DE/TXT/?uri=CELEX:62014CJ0346. 

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mapping. Involvement of different authorities in the approval process, could lead to non-
coordinated procedures. In Austria, for example, the topic of water ecology was dealt with 
individually  during  the  procedure  stipulated  by  both  the  water  law  and  the  nature 
conservation law. In the case of double examination, it might happen that the requirements 
of the two did not correspond. 

In addition, the industry emphasised the lack of digitalisation in the permitting processes. 
Applications  for  approvals  required  a  lot  of  paperwork  in  the  great  majority  of  European 
countries.  In  Austria,  all  applications,  even  those  for  very  small  installations,  must  have 
submitted  several  hard  copies.  In  the  case  of  small  changes,  which  are  common  in  the 
projects,  all  applications  to  all  authorities  must  be  reprinted.  This  lengthened  and 
complicated the process. The demand for simplification includes the possibility of submitting 
project  documents  digitally.  In  Germany,  most  authorities  required  applications  in  both 
paper and digital form. According to the stakeholders, a single signed digital version of the 
application  sent  over  by  mail  should  be  sufficient.  In  addition,  the  number  of  documents 
such as descriptions, grid sheets, expert surveys only for building a very small fish ladder 
on  an  existing  barrier  used  by  hydropower  could  easily  reach  20  documents  and  30-50 
pages for each survey at the time of the mapping. 

2.3.5.3.4. 

Repowering 

Since  a  large  part  of  the  available  hydropower  potential  has  already  been  tapped,  the 
hydropower industry will partially focus on repowering and refurbishing existing plants.  

The difference between the repowering and refurbishment lies in the installed capacity. In 
the case of repowering, the replacement of machinery or its main components as well as 
automation parts or hydraulic systems (in whole or in part) leads to an increase in installed 
capacity and energy production of the plant. In the event of refurbishment, however, the 
replacement of components does not change the installed capacity (Enel, 2021). 

The data collected for this report showed that repowering projects were generally subject 
to the same approval procedures as new hydropower projects in the European countries. 
In  France,  for  example,  the  approval  procedure  for  repowering  and  refurbishing  a 
hydropower plant was the same as for a new installation. In Austria, there was no separate 
procedure  for  the  modernisation  of  hydropower  plants,  which  permits  were  required 
depends  on  the  scope  of  the  project  and  was  decided  individually.  The  procedure  was 
determined by the Water Rights Act: If the project remains within the scope of the previous 
water law permit, there was usually no need to seek a new procedure, only a notification. 
However, a separate procedure was required for major changes and, according to experts, 
a new procedure was necessary for most revitalisation. In Norway, a  repowering project 
required a new approval procedure, unless it only had regional implications; in which case, 
a hearing with the municipality was sufficient.  

In this context, the industry called for a simplified procedure for repowering projects covering 
both  permitting  and  grid  connection  procedure.  One  suggestion  was  that  repowering 
projects were subject to an EIA screening procedure rather than full EIA process. Another 
option seen as viable by the industry was to introduce a certain threshold. For example, a 
full EIA process would only be applicable if repowering increased the installed capacity of 
a power plant by more than 20%. This could be tied to developers having to avoid significant 
negative effects on the aquatic flora and fauna.   

The simplification of repowering procedures is already included in art. 16 RED II. Art. 16 (6) 
RED II states:  

“Member  States  shall  facilitate  the  repowering  of  existing  renewable  energy  plants  by 
ensuring a simplified and swift permit-granting process. The length of that process shall not 
exceed one year.”  

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“Where duly justified on the grounds of extraordinary circumstances, such as on grounds of 
overriding safety reasons where the repowering project impacts substantially on the grid or 
the original capacity, size or performance of the installation, that one-year period may be 
extended by up to one year.” 

In  addition,  Art.  17  (8)  RED  II  foresees  that  Member  States  may  introduce  a  simple 
notification  procedure  for  repowering  projects  in  the  grid  connection  process.  If  this  is 
applied  by  the  Member  State,  repowering  shall  be  permitted  following  notification  to  the 
competent  authority.  However,  only  so,  if  no significant negative  environmental  or  social 
impact can be expected from the implementation of the respective project. The competent 
authority should then have a period of six months after receipt of a notification to decide 
whether this is sufficient.21 

2.3.5.3.5. 

Public opposition and resulting complaint procedures  

The  long  approval  process  was  often  extended  even  further  by  legal  action  initiated  by 
environmental organisations (based on the protection of rivers and biodiversity), but also 
competing users of water bodies, e.g. anglers. In Germany, due to litigation procedures a 
normal reactivation of a former hydropower location on an existing dam could easily take 
five to eight years or even longer at the time of the mapping.  

The  situation  for  small  hydropower  projects  could  get  worse  in  the  future,  as  in  October 
2020, 150 NGOs published a joint manifesto calling on the EU institutions to stop financing 
new  hydropower  projects  in  Europe.  The  NGOs  claimed  that  building  more  hydropower 
contradicts the biodiversity goals of the European Green Deal and that the EU can achieve 
climate neutrality by 2040 without new hydropower plants (EEB, 2020). 

2.3.6. Geothermal 

2.3.6.1. Introduction 

Geothermal  is  a  versatile  energy  source  that  can  be  harnessed  for  both  electricity  and 
heating production. From a regulatory perspective, geothermal technologies are divided into 
two categories: shallow and deep. The terms refer to the depth of the boreholes used to 
access the resource, and there is no universally applicable dividing line between the two. 
According  to  the  European  Geothermal  Energy  Council  (EGEC),  shallow  geothermal 
installations – either ground source heat pumps or underground thermal energy storages – 
do  not  usually  reach  depths  of  more  than  500  metres  underground.  Drillings  extending 
deeper than that are considered as deep geothermal (EGEC, 2021a). The temperature of 
the geothermal resource also depends on the depth of the drilling: shallow geothermal tends 
to reach temperatures ranging until 30°C whereas deep geothermal resources can reach 
up to 200°C (Goetzl, 2020). While shallow geothermal can be used for small- and medium-
scale heat production, deep geothermal resources can produce both heat and electricity, 
either separately or together (combined heat and power - CHP). 

So far, Europe has only harnessed a fragment of its geothermal potential. In 2020, by far 
the  largest  installed  geothermal  capacity  for  electricity  in  the  EU  was  in  Italy  (916  MW) 
followed  by  Germany  (41  MW)  and  Portugal  (33  MW).  The  largest  geothermal  district 
heating producers in 2020 were France (657 MW), Germany (344 MW) and the Netherlands 
(298 MW). In 2020, over 100,000 small shallow geothermal units were purchased, a half of 
which  in  three  EU  Member  States:  Germany,  Sweden  and  the  Netherlands.  The  largest 

21 Although the deadline for the transposition of the RED II into national legal frameworks in EU Member States was set for 
30 June 2021, its implementation is still ongoing in some EU Member States as of early 2023, according to the findings of the 
RES Simplify project. 

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share  of  households  with  a  geothermal  heat  pump  installed  is  in  Sweden  and  Finland.  
(EGEC, 2021b)  

According  to  a  geothermal  expansion  model  developed  by  Della  Longa  et  al.  (2020),  it 
would  be  possible  to  reach  geothermal  electricity  production  level  of  100–210  TWh/year 
and  heating  production  of  880–1050  TWh/year  by  2050.  This  trajectory  implies  that 
geothermal  could  contribute  up  to  7%  of  European  electricity  production  by  2050  (ibid.). 
With the current pace of geothermal expansion, such figures seem unlikely to be achieved: 
numerous administrative, financial and other barriers stand in the way. Section 2.3.6.3. will 
shed light to some of the identified barriers to permitting geothermal installations across EU 
Member States. 

2.3.6.2. Overview of the key process steps 

Despite the notable differences of shallow and deep geothermal, only some EU Member 
States made this differentiation in their legal framework regulating geothermal energy. For 
example,  Austria,  Slovenia  and  Germany  have  set  out  maximum  limits  for  the  depth  of 
shallow geothermal wells, varying from 300 to 400 metres (GeoPLASMA-CE, 2017). 

For  shallow  geothermal  installations  in  the  EU  Member  States,  the  permitting  procedure 
was less complex than for deep geothermal installations. The length of the process also 
depended on the impact the shallow geothermal installation had on the local water system: 
open loop systems tended to have more complicated permitting processes than closed loop 
systems.  The  permitting  framework  was  the  most  straight-forward  in  Nordic  and  Alpine 
countries, such as Austria, Finland and Sweden, where a notification or an action permit (a 
simplified version of a construction permit in Finland) might be sufficient for a small shallow 
geothermal installation. 

Deep geothermal installations were likely to have to undergo a more complicated and time-
consuming  permitting  process.  However,  there  are  also  Member  States  where  deep 
geothermal permitting was rather straight-forward: in Finland, for example, the first deep 
geothermal  project  commissioned  in  2021  only  had  to  acquire  an  action  permit  and  go 
through a relatively light environmental screening process. The same Finnish pilot project 
also benefited from the clear interpretation of who owns the geothermal resource: it belongs 
to the legal entity in possession of the property on the ground-level, regardless of the depth 
of the borehole.  

In  general,  deep  geothermal  licensing  can  be  divided  into  two  main  types  of  licenses: 
exploration and exploitation. Exploration licenses are acquired to map out the geothermal 
resource at hand and they are usually limited in duration, varying from between three to 
seven  years.  Exploitation  licenses  grant  the  actor  the  right  to  harvest  the  geothermal 
resource. In addition, other licenses are also required for deep geothermal installations. For 
example, in Hungary, a successful deep geothermal installation had to receive the following 
licenses  or  approvals  at  the  time  of  the  mapping:  water  license  (if  the  boreholes  do  not 
exceed 2500 m), concession (for boreholes going deeper than 2500 m), heat plant license, 
and an environmental permit. In Belgium, permits were required for exploration, production 
and environmental matters in Flanders, or a unique permit in Wallonia (Geoenvi, 2019). 

2.3.6.3. Key barriers 

The most severe barriers geothermal energy projects encountered were connected to the 
site selection and administrative authorisation process steps. As a rather novel technology, 
licensing  (in  particular)  deep  geothermal  installation  was  hindered  by  a  lack  of  suitable 
guidelines, land use planning, competent authority expertise, and precedence. 

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2.3.6.3.1. 

Lack of access to information 

At the time of the mapping, access to many forms of information relevant for geothermal 
energy projects was difficult and non-transparent in some EU Member States. The lack of 
transparency could occur on different occasions and affect different stakeholders ranging 
from  project  developers  to  public  authorities  and  the  civil  society.  For  example,  in  the 
Netherlands,  all  subsurface  data  had  to  be  made  public  after  five  years  after  the  results 
were available, whereas in some other countries, private companies did not have to share 
data  they  gathered  while  conducting  geological  surveys  geothermal  resource  (EGEC, 
2021a). As this data is often at least partially funded by the public sector, it would be for the 
benefit of the public and geothermal technology to share information more openly. 

The GEOENVI report also raises the issue of insufficient geothermal statistics. As a nascent 
energy source, authorities do not collect data from geothermal installations. Therefore, the 
geothermal  industry  cannot  present  reliable  information  and  statistics  to  concerned 
stakeholders,  such  as  landowners  or  the  general  public,  when  initiating  new  geothermal 
projects (Geoenvi, 2019).   

2.3.6.3.2. 

Incoherent  legislation  as  legal  basis  to  use  the 

geothermal resource 

In the EU, geothermal projects were regulated by a variety of different legal instruments. 
Shallow  geothermal  could  fall  under  water  legislation  (Austria,  Czechia,  Germany,  and 
Slovenia),  mining  legislation  (Poland  and  Slovenia),  land  use  and  building  legislation 
(Finland and Czechia), or a mix of two or more of the aforementioned. Deep geothermal 
tended to be regulated by mining laws, as well as other relevant environmental legislation 
(EGEC, 2021a).  

The heterogenous legislation regulating geothermal installations has, in part, led to variation 
between EU Member States on who has the right to use the geothermal resource. In some 
Member States, the right was clearly defined in legislation; albeit, different legal documents 
were  used  as  the  basis  for  this  right:  in  Germany,  for  example,  the  right  was  codified  in 
mining legislation, whereas in Finland, the right was connected to the Land Use and Building 
Act.  In  other  Member  States,  there  was  a  lack  of  clarity  regarding  the  right  to  use  a 
geothermal  resource,  as  there  may  not  be  precedence  on  such  deep,  underground 
operations  and  how  to  grant  them  administrative  authorisation  (GeoPLASMA-CE,  2017; 
EGEC, 2021a).  

2.3.6.3.3. 

Lack of appropriate land use planning 

In many EU Member States, geothermal technologies have not been deployed on a large 
scale. Partly due to this novelty factor, they have not yet become a part of land use planning. 
Geothermal  installations  still  require  careful  planning,  as  they  could  potentially  impact 
surrounding infrastructure or the underground ecosystem by, for example, interfering with 
groundwater reservoirs. It is highly important to only construct geothermal installations on 
sites that are geologically and hydrologically suitable and safe as there are environmental 
and health risks connected to ill-functioning installations (Geoenvi, 2019; EGEC, 2021c). 

2.3.6.3.4. 

Need for simple permitting for shallow geothermal 

Shallow geothermal installations were often small (geothermal heat pumps) and installed 
by  private  individuals  or  companies  on  their  property  to  generate  heat  for  the  own  use. 
Shallow geothermal thus competed with other forms of heating systems, such as district 
heating, or a gas- or oil-operated boiler on the property. Customers tended to opt for the 
most affordable and easy-to-use heating systems; therefore, if the permitting procedure for 

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a geothermal heat pump was time-consuming and complicated, the customer was likely to 
choose  a  different  technology.  The  permitting  for  small-scale  shallow  geothermal 
installations should be straight-forward, quick and affordable (Sanner, 2021). In Sweden, 
for example, the licensing procedure for a small geothermal heat pump was determined by 
the  local  municipality.  In  some  municipalities,  no  permit  was  necessary  and  a  simple 
notification  to  the  Geological  Survey  of  Sweden  sufficed.  In  the  most  densely  populated 
areas,  such  as  Stockholm,  a  permit  was  needed,  and  processing  the  application  took  a 
couple of months at the time of the mapping. According to EGEC, the permitting process 
duration for shallow geothermal should not exceed two months (EGEC, 2021). 

2.3.6.3.5. 

Complicated  and  lengthy  licensing  procedures  for 

deep geothermal 

Permitting  deep  geothermal  installations  required  numerous  permits,  which  were 
administered by different authorities. In many EU Member States, commissioning a large-
scale  geothermal,  especially  deep  geothermal,  installation  required  applying  for  several 
different  types  of  permits,  such  as  exploration,  exploitation,  water  and  environmental 
permits from numerous authorities. These tended to not cooperate with one-another, a key 
reason for the lengthy permitting processes (Geoenvi, 2021). EGEC called for a one–year 
limit to the duration of the permitting process, which should include the evaluation of the 
application materials and granting the permits (EGEC, 2021a). In order to reach the goal, 
the  whole  permitting  framework  constituting  of  multiple  permits  from  different  authorities 
should  be  replaced  with  a  One  Stop  Shop,  which  would  eradicate  crucial  barriers  to 
smoother and quicker permitting (EGEC, 2021a; Batini, 2021). 

As  a  One  Stop  Shop,  the  national  or  regional  geothermal  authority  would  cut  permitting 
times significantly. The geothermal permit would replace all the permits necessary in the 
current  framework,  including  those  pertaining  to  exploration  and  exploitation,  all 
environmental  impact  assessments,  as  well  as  drilling  and  construction  (EGEC,  2021a; 
EGEC, 2021c). 

At  the  time  of  the  mapping,  permitting  authorities  lacked  necessary  competence  and 
experience for permitting geothermal technologies. This has been reported by geothermal 
experts  by  Italian  and  French  participants  of  the  GEOENVI  projects  (Geoenvi,  2019). 
Having a competent authority focusing solely on geothermal planning and permitting would 
ensure  the  professionalism  and  experience  needed  for  evaluating  potential  geothermal 
projects. 

Bringing geothermal permitting under one license in a single competent authority would also 
solve two existing issues: grid availability and conflicting permit decisions. As it stands, it 
was possible in some EU Member States, such as Italy, for a deep geothermal installation 
to receive an exploration permit, but subsequently receive a negative concession decision 
(Geoenvi, 2019). In a similar manner, the One Stop Shop for geothermal should also be in 
charge  of  guaranteeing  grid  connection  for  geothermal  projects,  but  could  also  become 
involved  in  assessing  the  project’s  technical  and  financial  details  (EGEC,  2021a).  A 
geothermal  authority  could  also  assess  application  materials  in  a  holistic  manner,  which 
would eliminate the possibility of discontinuing an ongoing project. It should be a local or 
regional  level  One  Stop  Shop;  although,  it  could  have  national  offices  to  evaluate  large 
projects. 

Even the existing One Stop Shops did not function as smoothly as they should: in Hungary, 
for  instance,  the  competent  authority  for  the  concession  for  geothermal  is  the  Mining 
Authority, but consultations from the Directorate for Disaster Management (water authority) 
is necessary. As these two institutions are under the auspices of different ministries, there 
were delays in their communication (Geoenvi, 2019). 

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2.3.6.3.6. 

Harmonised guidance needed for permitting and EIA 

procedures 

As  mentioned  in  the  previous  barriers,  the  permits  necessary  for  a  deep  geothermal 
installation varied by Member State. Also, the documentation needed for applying for them 
differed from one country to another, making it challenging for geothermal developers to 
operate across borders. The terminology used for geothermal also varied from country to 
country,  and  both  the  state  authorities  licensing  geothermal  installations  and  project 
developers  operating  on  several  markets  would  benefit  from  an  established  geothermal 
terminology used across all EU Member States. At the time of the mapping, there was no 
standardised  list  of  documents  that  geothermal  installations  needed  when  applying  for 
certain permits (EGEC, 2021a). Having such a list would improve the quality of applications 
and accelerate the work of permitting authorities. 

EIA  processes  of  all  EU  Member  States  are  guided  by  a  common  legal  source,  the  EIA 
Directive 22  (Directive  2011/92/EU).  Member  States,  however,  carried  out  EIAs  slightly 
differently, leading to different EIA guidelines and necessary documentation for screenings. 
The  EIA  procedures  and  guidelines  in  most  EU  Member  States  did  not  take  deep 
geothermal projects into account. Only Italy had a dedicated guideline for deep geothermal 
for the region of Tuscany (Geoenvi, 2019) of the GEOENVI project target countries (EU: 
France, Germany, Italy, Hungary, and Belgium; non-EU: Switzerland, Iceland and Turkey).  

To ensure the safety of the deep geothermal installation planned and to avoid unnecessary 
assessments, EIA guidelines for deep geothermal should be developed. Furthermore, these 
national guidelines should be harmonised at the EU level, setting similar standards, required 
documentation and terminology (Geoenvi, 2019; EGEC, 2021a). Harmonisation should also 
be  paired  with  differentiation,  as  each  region  has  its  own  geological  and  hydrological 
characteristics, which frameworks should reflect.    

2.3.7. Solar thermal  

2.3.7.1. Introduction 

According to the EurObserv’ER Solar thermal concentrated solar power barometer 2020 
(EurObserv’ER,  2020),  the  solar  thermal  market  of  the  EU-28  saw  a  clear  expansion  of 
installed  capacities  in  2018  after  almost  ten  years  of  decline.  A  slight  increase  was  also 
observed in 2019 (+1.5% compared to 2018) when 2.28 million m² of new solar collector 
surface area was installed in Member States. This corresponds to a thermal capacity of just 
under 1.6 GW. The thermal output of the EU-28 thus reached 37.8 GW at the end of 2019. 

Apart from the expansionary trajectory, the market circumstances in EU countries differed 
considerably. The share of installed solar thermal capacity by EU country is demonstrated 
in Figure 2-24. 

22 https://eur-lex.europa.eu/legal-content/de/ALL/?uri=CELEX%3A32011L0092 

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Figure  2-24:  Shares  of 
Solarthermalworld.org, 2020) 

the  European  solar 

thermal  market  (newly 

installed  capacity)  (Source: 

Although Germany was still at the top of the list in 2019 (followed by Greece, Poland, Spain, 
and Denmark), its market continued a decade-long decline (-11% compared to 2018), due 
to opposing national trends (BMWi, 2020a). Installations in Austria and Italy also declined. 
In Denmark, on the other hand, installed capacity increased by 174%, which was a result 
of new solar district heating systems (EurObserv’ER, 2020; Solarthermalworld.org, 2020).  

Looking at the total area of the installed collectors at the end of 2019, by far the largest 
collector area was installed in Germany, which led the EU by a large margin (19.3 Mio m²), 
followed by Austria (5.0 Mio m²), Greece (4.9 Mio m²), Spain (4.4 Mio m²), and Italy (4.3 Mio 
m²) (BMWi, 2020b). 

Solar thermal heat supply technologies cover small-sized systems for single-family houses, 
medium-sized  installations  for  multi-family  houses,  smaller  heating  networks,  process 
heating  systems  and  large  solar  thermal  plants.  In  many  European  countries,  the  total 
potential of solar thermal energy was estimated at 3–12% of the overall heat production 
(Tschopp et al., 2020). 

2.3.7.2. Key barriers  

This  section  provides  an  overview  of  the  most  significant  obstacles  when  applying  for 
permits and connection to the district heating network for a solar thermal system at the time 
of  the  mapping.  These  obstacles  contributed  to  the  slumping  installation  trends  which 
among  other  things  contributed  to  the  above  given  downward  trends  in  some  of  the  EU 
Member States.  

The research for this report found that solar thermal energy is mostly impeded by barriers 
such as political, operational or business model-related obstacles as opposed to procedural 
issues.  One  of  the  political  barriers  was  the  lack  of  binding  EU  and  national  renewable 
heating targets as was the case with renewable energy overall. There should be strategic 
energy planning for the next 20-30 years with sectoral and technology-specific objectives 
and targets in the electricity, heating and cooling and the transport sectors. One of the most 
significant barriers related to business models, according to the industry, was the lack of 
long-term  power  purchase  agreements  (PPAs)  for  solar  thermal  projects  –  the  report 

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discusses this below, given its critical role. In terms of administrative barriers, the results of 
the mapping task have shown that access to land was becoming increasingly problematic 
for the developers of solar thermal projects, partly due to the lack of designated zones for 
projects  in  spatial  plans  and  opposition  of  local  environmental  NGOs  on  environmental 
grounds. Implementation of solar thermal projects was aggravated by unclear regulations 
on district heating network connections, which provides network operators discretion over 
decisions and leads to time-consuming connection procedures. Moreover, seasonal solar 
thermal  storage  (SSTES)  was  not  regulated  and  thus  not  included  in  the  existing 
administrative  procedures  of  the  EU  Member  States.  These  and  other  barriers  for  solar 
thermal energy are discussed in more detail below.    

2.3.7.2.1. 

Land use related issues  

According  to  the  solar  thermal  industry,  access  to  land  for  larger  ground-mounted  solar 
thermal systems (e.g. large-scale solar thermal heating systems connected to local district 
heating systems (DHS) or larger solar thermal systems for industrial processes (SHIP)) was 
increasingly  problematic  in  EU  Member  States.  This  is  related  to  the  lack  of  designated 
zones for energy projects – including solar thermal - in spatial plans, resulting in land use 
conflicts and time-consuming land use change procedures.   

As the construction of solar district heating (SDH) plants usually requires large areas, there 
were often conflicts with competing land uses, such as agriculture or nature conservation. 
Their potential negative impact on the environment and biodiversity or visual impact on the 
surroundings  was  a  common  reason  for  local  resistance,  especially  from  environmental 
NGOs (SDH, 2017). 

A solution used in some European countries is the so called dual-use of infrastructure. This 
entails that land is used for both solar thermal projects and other objectives, such as nature 
conservation – examples of this approach include the use of closed landfill sites, agricultural 
areas, areas near highways (SDH, 2017). As landfill sites are brownfields, using them for 
solar energy projects (PV and solar heat) helps avoid adversely impacting negative impacts 
on sensitive ecosystems (Jäger-Waldau, 2020). In Malta, for example, quarries (currently 
operating, inactive or closed) are allowed to be used for the development of solar energy.  

To solve the land use conflicts, the industry also called for the designation of priority areas 
for  solar  thermal  projects  in  spatial plans, since  heat  cannot  be  transported  as  easily  as 
electricity and therefore solar thermal systems need to be installed near the district heating 
network, meaning close to the residential areas (i.e. cities, villages).   

2.3.7.2.2. 

Connection to district heating networks  

The solar thermal industry was also confronted with obstacles when connecting to district 
heating  networks,  which  were  primarily  due  to  unclear  regulations  for  connection. 
Definitions in regulations were rather vague and could be interpreted differently by various 
parties. When deciding whether to connect a system to the heating network, criteria such 
as “competitiveness”, “economic feasibility” or “efficiency” were often used, which were not 
clearly defined in regulations and thus gave network operators a great deal of discretion. 
As a result, the network operator could say that connecting the solar thermal installation 
was economically not feasible and refuse the connection. There was often no clear legal 
justification for such decision, making a clear framework at national level essential.  

According to the industry, guidelines at EU level might offer a solution. However, they should 
be drafted together with all relevant stakeholders and be based on national consultations. 

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2.3.7.2.3. 

Seasonality issues 

One of the key obstacles to the greater deployment of solar thermal technology in the EU 
Member  States  was  the  lack  of  regulation  and  administrative  procedures  for  the  use  of 
seasonal  solar  thermal  storage  (SSTES).  This  led  to  individual  and  time-consuming 
negotiations  with  the  stakeholders  in  each  case.  SSTES  is  one  of  the  solutions  that 
representatives of the solar thermal industry saw in addressing the seasonal nature of this 
technology.  There  is  a  mismatch  between  solar  thermal  energy  production  during  the 
summer and high demand in winter. In addition, demand for heat differs depending on the 
region: this tends to be higher in northern Europe and lower as one travels south.  

Policy-makers did not take seasonality into account in most national legal frameworks and 
have not developed the foundations for storing energy in such a manner. This impacts the 
technology adversely, since using solar thermal energy only in the heating season is not 
economically viable. A non-discriminatory regulatory framework for flexibility and balancing 
solutions is one of the key factors for a level playing field for solar thermal energy storage. 
It  means  that  non-discriminatory  access  to  heating  networks  needs  to  be  ensured  by 
operators  and,  in  particular,  access  to  district  heating  systems  for  heat  needs  to  be 
encouraged (EASE, 2017). 

2.3.7.2.4. 

Lack of long-term PPAs 

Representatives of the solar thermal industry reported that the absence of long-term PPAs 
in the heating sector is problematic – which was also an issue in the electricity sector of 
some EU countries. Although this was not an administrative barrier, it significantly impeded 
the further growth of the sector. In general, many operators of district heating system (DHS) 
produce the heat themselves but can also take on heat from other producers. In Lithuania, 
for example, competition among heat producers is organised on the basis of monthly heat 
sale  auctions.  There  is  a  national  fuel  and  energy  exchange  –  BALTPOOL  and  all  heat 
producers are obliged to buy fuel and sell heat on this exchange (RES Legal Europe, 2018; 
Euroheat  &  Power,  2019).  This  monthly  auction  is  mainly  used  for  biomass.  However, 
according  to  the  solar  thermal  industry,  monthly  heat  auctions  mean  higher  investment 
costs. Monthly auctions benefit natural gas, but not solar thermal since for cost reasons the 
latter simply cannot compete with the former under current market conditions. Solar is much 
more competitive vis-a-vis natural gas in countries with a high carbon tax. Otherwise, the 
competitiveness of solar can be underpinned by long-term – 10–15 year – PPAs. 

2.3.8. Specific features aimed to ease administrative procedures  

As  part  of  the  mapping  task,  the  Consortium  also  examined  whether  there  are  specific 
features  in  the  27  EU  Member  States  that  facilitate  renewable  energy  installations’ 
administrative  procedures.  These  were  examined  without  regard  to  technology  and 
included:  

“Two plus one” and/ or “one plus one” year rules, 

•  Simultaneous procedures, 
•  One Stop Shop or a single contact point for renewable energy projects, 
• 
•  Simple notification procedure, 
•  Pre-planning procedure, 
•  Pre-application consultations, 
•  Project acceptance measures, 
•  Measures to streamline litigation by third parties.  

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Some of the features – single contact point, a simple notification procedure for small-scale 
installations and repowering projects, the “two plus one” and the “one plus one” rules – were 
integrated into RED II and thus Member States were obliged to introduce them by 30 June 
2021. Figure 2-25 demonstrates which of the examined simplification features researchers 
identified at the time of the mapping. Results are discussed in more detail below.  

Figure 2-25: Specific features to ease administrative procedures in the 27 EU Member States 

2.3.8.1. Simultaneous procedures  

Some approval processes for renewable energy projects can run simultaneously in many 
EU Member States. The aim of simultaneous procedures is to streamline the approval of 
the renewable energy projects. As can be seen on Figure 2-25, almost half of the Member 
States have introduced this at the time of the mapping.  

In Austria, for example, developers could apply for multiple permits (electricity production 
license,  approval  under  the  nature  conservation  law  procedure,  aviation  law  procedure, 
forestry law permit, water law permit, occupational health and safety law permit, building 
permit) in parallel. Site selection and the grid connection application could also be done in 
parallel. In Portugal, obtaining an electricity production license and connecting the power 
plant  to  the  grid  may  be  carried  out  simultaneously,  once  the  applicant  has  successfully 
obtained a grid capacity reserve title. In Finland, it was possible to combine construction 
permit and different environmental permit processes (joint procedure). As a part of the joint 
procedure,  all  applications  were  possible  to  be  submitted  electronically  to  competent 
authorities simultaneously. Moreover, the applicant could provide supplements for different 
applications at once, public hearings for all the processes were organised simultaneously, 
and decisions were published together.  

Simultaneous  procedures  are  intended  to  make  the  approval  process  more  efficient,  but 
this was not always the case in practice. Interviewees in Austria, for example, reported that 
during the substantive law procedure – when the impacts on public goods are examined 
individually  by  different  authorities  –  it  can  happen  that  authority  requirements  are 
contradictory. In order to ensure that the simultaneous procedures are executed smoothly 
and  efficiently,  clear  regulations  as  well  as  the  distribution  of  responsibilities  and  good 
coordination between the authorities involved are essential.  

2.3.8.2. One Stop Shop or a single contact point   

Establishing a One Stop Shop or a single contact point is another feature that can simplify 
and accelerate permitting procedures for renewable energy projects.  

A One Stop Shop in public administration refers to the ability to carry out all the necessary 
bureaucratic  steps  in  one  place.  Similarly,  according  to  RED  II,  the  single  contact  point 
should guide the applicant through the entire administrative process so that the applicant is 
not  obliged  to  contact  other  administrative  authorities  to  obtain  the  approval,  unless  the 
applicant prefers to. As a result, art. 16 RED II requires the Member States to set up or 
designate one or more contact points for renewable energy projects. The approval process 

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should cover all relevant permits to build, repower and operate renewable energy plants 
and assets necessary for their connection to the grid. In addition, RED II requires that the 
contact points make available a manual covering the procedures for developers. Thus, the 
aim of a One Stop Shop or a single contact point is to reduce the complexity of permitting 
for project developers and increase their efficiency and transparency (art. 16 RED II).  

Figure 2-25 demonstrates that several Member States have introduced a One Stop Shop 
or a single contact point at the time of the mapping. For instance, France has introduced a 
One Stop Shop for wind energy projects. Here, the “environmental authorisation” procedure 
applies to onshore wind projects that fall under environmental protection (ICPE) as of 2017 
or offshore wind projects that fall under the Water Act (Schmid and FEE, 2020). This aims 
to combine all the environmental approvals which are necessary for the project in one single 
permit and alleviates the developer to have to apply for a building permit. In Germany, One 
Stop  Shops  for  administrative  authorisation  covered  building  and  environmental  permits, 
but  did  not  include  grid  connection.  Belgium  (Wallonia  and  Flanders)  have  merged  the 
urban  and  environmental  permits  into  a  single  one.  There  was  a  One  Stop  Shop  –  the 
environmental  desk  –  in  Flanders  to  obtain  an  integrated  environmental  permit  for  the 
construction, repowering and operation of the plant, i.e. the environmental desk. Although, 
this  did  not  cover  the  electricity  production  license  (if  required)  and  the  grid  connection 
permit (if required). In Denmark, the Danish Energy Agency served as a One Stop Shop for 
offshore wind procedures. Here, too, it did not cover the grid connection at the time of the 
mapping.  

National experts emphasised during the stakeholder workshops that a One Stop Shop or a 
single contact point can also introduce risks and jeopardise project implementation. This 
can occur if there are staff related issues at the single competent authority, such as being 
understaffed or a lack of expertise. These can lead to serious bottlenecks in the permitting 
procedures.  For this reason, some stakeholders prefered to have the One Stop Shop or 
single  contact  point  introduced  only  as  an  optional  alternative  to  the  current  splintered 
permitting  procedure,  as  is  the  case  under  RED  II.  They  sought  the  flexibility  to  choose 
between the two options to deal with administrative issues.  

2.3.8.3. Application of “two plus one” and/ or “one plus one” rules 

According  to  art.  16  RED  II,  the  permit-granting  process  shall  not  exceed  two  years  for 
power  plants,  including  all  relevant  procedures  of  competent  authorities.  This  two-year 
period  may  be  extended  by  up  to  one  year  (“two  plus  one”  rule)  due  to  extraordinary 
circumstances.  In  addition,  the  permit-granting  process  shall  not  exceed  one  year  for 
installations with an electrical capacity of less than 150 kW. This one-year period may be 
extended by up to an additional year due to extraordinary circumstances (“one plus one” 
rule).  The  “one  plus  one”  rule  applies  also  to  permit-granting  process  for  repowering. 
Extraordinary circumstances during repowering include safety considerations, if the project 
significantly impacts the network or the original capacity, size or performance of the system 
(art. 16 (4-6) RED II). 

According to RED II, the deadlines of “two plus one” and “one plus one” rules do not cover 
the legal complaint procedures and the time required to conduct EIAs and other appropriate 
assessments (art. 16 (7) RED II). These two aspects caused some of the longest delays for 
wind and PV projects in most countries, which substantially weakens the impact of art. 16 
RED II. In its proposal to revise the RED II of May 2022, the Commission set new deadlines 
for  the  permit-granting  procedures  that  include  the  time  required  for  environmental 
assessments, where applicable.  

The results of the mapping task showed that the deadlines for renewable energy projects 
in  almost  all  EU  Member  States  were  not  yet  compatible  with  art.  16  RED  II,  except  in 
Germany and Lithuania (see Figure 2-25). Although the EU Member States had established 
procedural  deadlines  for  the  approval  of  renewable  energy  projects,  in  all  EU  Member 

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States there was no general deadline for the entire duration of the permit-granting process 
as stipulated in art. 16 RED II (note that the mapping task was completed earlier than the 
deadline for the RED II implementation). Moreover, there was no monitoring of the length 
of permitting procedures for renewable energy projects in the EU Member States.    

In Lithuania, the procedures for installations larger than 30 kW were compliant with the “two 
plus one” rule, while installations with an installed capacity of less than 30 kW complied with 
the “one plus one” rule. In Germany, after the confirmed completion of submitting required 
documents for an onshore wind project, authorities needed to approve the application within 
three months in the case of a simplified procedure and within seven months in the case of 
a formal procedure, if third parties do not cause delays. The reasons for delays needed to 
be explained by the authority and allow for a prolongation of three months (BImSchV, 2020; 
BImSchG, 2020), which is in line with RED II. However, at the time of the mapping, there 
was no explicit deadline for the total duration of the approval process for renewable energy 
projects in these two countries either.  

2.3.8.4. Simple notification procedure  

According  to  art.  17  (1)  RED  II,  Member  States  shall  establish  a  simple-notification 
procedure  for  the  grid  connections  of  renewable  energy  systems  developed  for  self-
consumption and demonstration projects with an electrical output of 10.8 kW or less. The 
DSO can either approve or reject the requested grid connection or suggest an alternative 
which it has to justify (e.g. safety reasons or technical incompatibility with the system). If the 
grid connection application is approved by the DSO or if there is no decision by the DSO 
within a period of one month after receipt of the notification (silent approval), the renewable 
energy systems can be connected.  

In addition, Member States are allowed to establish a simple notification procedure for the 
grid connection of renewable energy systems with an installed capacity of more than 10.8 
kW but not exceeding 50 kW. However, this can only be upheld if the stability, reliability and 
safety of the grid is ensured (art. 17 (2) RED II). 

According  to  RED  II,  Member  States  are  also  allowed  to  introduce  simple  notification 
procedures for the grid connection of projects that are repowered. An important prerequisite, 
however, is that the project is not expected to carry any significant negative environmental 
or social impact. The competent authority shall decide whether the notification is sufficient 
within  six  months.  If  the  decision  is  positive,  the  competent  authority  grants  a  permit. 
Otherwise, the developer must apply for a new permit (art. 16 (8) RED II).  

It  should  be  noted  that  the  focus  of  the  mapping  of  administrative  and  grid  connection 
procedures was not only on the simple notification procedures discussed in the RED II. The 
scope  of  the  research  in  terms  of  simple  notification  procedures  was  much  broader  and 
include all simple notification procedures in renewable energy project approval processes.  

As  can  be  seen  on  Figure  2-25,  simple  notification  procedures  for  renewable  energy 
projects were common in nearly half of the EU Member States. Some countries applied a 
simple notification procedure for the grid connection of small-scale projects (e.g. Ireland, 
Denmark, Lithuania, Malta). In Ireland, for example, there was a straight-forward, simple 
notification procedure for grid connection process under the micro-generation scheme for 
rooftop PV and onshore wind. This applied to installations with an installed capacity of less 
than 11 kW. In January 2021, the Department of Communications, Climate Action and the 
Environment  launched  a  public  consultation  on  a  new  micro-generation  scheme  for 
residential users. Based on this, experts expect that the capacity limit will be increased from 
11 kW to 50 kW. In Lithuania, simple notification procedure applied for the grid connection 
of  prosumers’  installations  with  an  installed  capacity  of  less  than  30  kW.  In  Denmark,  a 
simple-notification procedure for grid connection to repower projects was already in line with 
art. 16 (8) RED II.  

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In  other  EU  countries,  the  simple  notification  procedure  was  applied  during  the  building 
permitting (e.g. Croatia, Spain). In Croatia, simple structures, including rooftop PV systems, 
did  not  require  a  building  permit,  if  they  are  constructed  on  an  already  existing  building 
irrespective of that being able to transit energy to the network. The 2017 Simple Buildings 
Regulation, however, suggests that the developer will be obliged to notify the competent 
building authority when they launch construction. In Spain, there was no simple notification 
procedure on a national level at the time of the mapping. However, units with a capacity of 
10 kW or less in Andalucía were only subject to a responsible declaration or prior notification 
on  the  construction  instead  of  a  full  building  permit.  In  Poland,  a  simple  notification  was 
used for micro-installations (up to 50 kW) in both the building permitting and grid connection, 
if connected to the distribution grid.  

Some  EU  Member  States  went  even  further  and  did  not  even  require  installing  a  power 
plant to notify the authorities if the projects do not exceed a certain capacity. For example, 
the Building Act in Czechia required neither a building permit nor a building notification for 
electricity producing installations with a total capacity of up to and including 20 kW at the 
time  of  the  mapping.  In  Portugal,  self-consumption  units  (Unidades  de  Produção  para 
Autoconsumo  -  UPAC)  with  an  installed  capacity  below  350  W  were  not  subject  to  prior 
notification nor control – producers might simply buy the equipment and install it.  

In  conclusion,  the  simple  notification  procedure  was  already  fairly  widespread  in  the  EU 
countries. Nevertheless, there was still room for improvement in a large number of Member 
States. With regard to repowering in particular, simple notification procedures was detected 
only in Denmark.   

2.3.8.5. Pre-planning procedure 

This  research  project  focused  on  the  use  of  pre-planning  tools  in  EU  countries.  Results 
demonstrate  that  the  pre-planning  measures  were  not  particularly  widespread  in  target 
countries at the time of the mapping. They were identified in only nine Member States (see 
Figure 2-25). The pre-planning instrument most frequently identified is the designation of 
areas for renewable energy projects, mainly wind power, but, in some countries, also for 
ground-mounted  PV.  In  these  areas  the  permitting  requirements  were  reduced  and 
therefore the projects could be implemented in an easier and faster manner.  

In the case of offshore wind, the specified areas are usually legally binding for the competent 
authorities and project developers. For example, in Denmark, area screenings of Danish 
waters for offshore wind turbines are done by or on behalf of Danish Energy Agency and 
they provide the basis for the political decision on where to locate national tenders. In the 
case of onshore wind turbines and ground-mounted PV systems, the designated areas are 
usually not mandatory. The aim of the planning instruments that specify geographic areas 
for  these  two  technologies  is  to  inform  the  project  developers  about  the  most  suitable 
locations for their projects.  

There  were  different  kinds  of  instruments  used  in  the  EU  Member  States  to  assist 
developers  in  choosing  suitable  locations  for  their  power  plants.  In  Belgium,  the  best 
locations for renewable energy projects were shown via a national grid capacity map. This 
was not binding and did not influence whether a project was permitted. In Spain, there were 
two maps published by the national government for wind and solar power at the time of the 
mapping.  These  classify  the  country’s  territory  into  five  environmental  sensitivity  classes 
(maximum, very high, high, moderate and low) based on the type of project. These tools 
are only indicative and do not replace the necessary administrative steps, such as the EIA. 
In  Czechia,  areas  in  which  the  construction  of  wind  power  and  solar  PV  plants  is 
“unsuitable”, “rather unsuitable” and “generally suitable” are defined in the Methodological 
Instructions issued by the Ministry of Environment. Nevertheless, the areas’ differentiation 
only gives a broad overview on the expected complexity of follow-up processes, and is also 
not legally binding for state authorities. 

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Although most of the pre-planning tools identified were non-obligatory and only provided 
information, they tended to save project developers time, allowing them from the outset to 
focus on the areas with the greatest potential for approval. 

2.3.8.6. Pre-application consultations 

In  a  pre-application  consultation,  a  developer  consults  with  the  community  on  a  major 
development before applying for planning permission. The aim of the process is to improve 
the planning system by strengthening community participation at an early stage and better 
responding to local views on the proposed developments. Research results show that pre-
application consultations were applied in twelve Member States, including Austria, Cyprus, 
Czechia, Spain, Finland, Ireland, Lithuania, Latvia, Portugal, Romania, and Slovakia.  

In Ireland, for example, it was recommended that at least one pre-application meeting is 
held with the local authority to discuss the scope of the application and seek their views as 
to what should be included in the application or in the accompanying Environmental Report 
or  Environmental  Impact  Statement  (EIS).  Pre-planning  community  engagement  is  not  a 
mandatory requirement, but is strongly recommended. Local engagement can begin in early 
project development stages (e.g. for the wind monitoring mast) and/or during the EIA prior 
to  submitting  a  planning  application.  Examples  of  public  engagement  activities  included 
visits, information packs, meetings and public exhibitions (IWEA, 2012). 

Preplanning community engagement mainly took place prior or as a part of EIA procedures 
in EU countries. In Latvia, however, pre-consultations with the transmission or distribution 
system operators were also strongly recommended before submitting an application for grid 
connection.  Accordingly,  developers  usually  undertook  pre-consultations,  especially  for 
larger renewable energy projects.  

Pre-planning consultations were perceived as a useful tool to improve the administrative 
procedure as they provide a platform for project developers and all local actors involved to 
discuss the project and project implementation conditions in advance. This gives the local 
community the opportunity to express their fears and concerns at an early stage and the 
project developer to address them with the help of open and well-founded discussions. If all 
concerns  of  the  local  community  are  adequately  (and  to  the  extent  possible)  taken  into 
account, this usually helps to avoid time-consuming appeal procedures thereafter.     

2.3.8.7. Project acceptance measures 

Project acceptance measures are measures that aim to enhance the local acceptance of 
renewable  energy  projects.  The  main  reasons  for  the  resistance  from  local  communities 
(including NIMBY) are varying impacts, including visual and aesthetic, land-use and nature, 
environmental, health, and property-related.  

Acceptance  measures  to  reduce  or  avoid  local  opposition  can  be  of  a  financial  or  non-
financial nature.  

Some non-financial measures were identified in Ireland. They are foreseen in the draft Wind 
Energy Development Guidelines and include (1) the obligation for public communication, 
where  project  developers  are  obliged  to  engage  in  consultations  with  the  local 
community,  before  applying  for  a  planning  permission,  and  the  (2)  preparation  of  a 
community report. The community report should set out how the project development will 
affect the local community and how local community participation will be assured throughout 
the project’s lifetime.  

Most measures to increase project acceptance were, however, of a financial nature. Taxes 
are very often levied on onshore wind projects by local governments in the Member States. 
This was the case, for example, in Spain, Cyprus, Germany, and Lithuania. In this context, 
it was decisive, which municipality benefits from the local taxes: the municipality where the 

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project is sited or where the headquarters of the project owning company is registered. In 
Germany, for example, the tax code had to be adapted to ensure the municipality where 
the plant is installed, can benefit, too. Similarly, at the time of the mapping, a “green fund 
scheme” in Denmark obligated the developer to pay EUR 11,811 (DKK 88,000) per MW of 
onshore wind capacity to the relevant municipality, which could use the funds to support for 
local initiatives, such as local green projects.   

The use of various ownership models was another common practice applied in the EU 
countries  to  enhance  project  acceptance.  In  Germany,  for  example,  the  majority  of 
operating wind farms are community owned. A number of ownership models have emerged, 
including  limited  partnerships,  cooperatives,  voluntary  associations,  community  trusts, 
informal  community  groups,  and  social  enterprises.  These  can  be  combined  with  further 
measures aimed to support localities. For instance, the state of Brandenburg passed a law 
that  forces  operators  to  pay  an  annual  lump  sum  of  EUR  10,000  per  wind  turbine  to 
neighbouring  municipalities  (Schmid  and  Business  Intelligence,  2019).  Similarly  in 
Denmark, “RE-bonus scheme” obligates the developer to pay neighbours an annual bonus 
corresponding to a specified part of the capacity of the plant. In France, renewable projects 
can receive a local participation bonus if they have 40% of equity capital owned by at least 
20 local persons or regional authorities (investissement participatif) or at least 20 natural 
persons  contributing  to  10%  of  overall  project  finance  (financement  participatif)  (Schmid 
and FEE, 2020). 

At the time of the mapping, Ireland planned to establish a “Community Benefit Fund”, 
which  would  be  funded  from  renewable  electricity  produced  by  installations  under  the 
Renewable  Electricity  Support  Scheme  (RESS  -  auctions)  (EUR  2/MWh).  Finally,  there 
were  two  schemes  in  Denmark  that  addressed  opposition  caused  by  local  community 
concerns on how renewable energy projects impact on the value of their property. The “loss 
of value scheme” required the developer to compensate any loss of value to residential 
property  equal  to  or  higher  than  1%  of  the  property  value.  While  the  “option-to-sell 
scheme”  allowed  some  neighbours  within  a  distance  of  six  times  the  height  of  a  wind 
turbine or 200 m from a ground-mounted solar PV plant to sell their property to the project 
developer. 

As mentioned above, less than half of the EU Member States had introduced or plan to take 
project  acceptance  measures  at  the  time  of  the  mapping.  Especially  those  without  such 
measures and with major local opposition problems should strongly consider learning from 
others that have already taken action that has proven to be effective. 

2.3.8.8. Measures to streamline litigation by third parties 

According to RED II (art. 16 (7)), judicial appeals, remedies and other proceedings before 
a  court  or  tribunal,  and  alternative  dispute  resolution  mechanisms,  including  complaint 
procedures, non-judicial appeals and remedies shall be unaffected from the Directive. The 
deadlines  relating  to  “two  plus  one”  and  “one  plus  one”  rules  can  be  extended  for  the 
duration of these proceedings. As a result, the lead times of renewable energy projects are 
often much longer. Problems may also arise, when a third party (e.g. neighbour, a NGO or 
a completely unrelated person in a Member States with very liberal rights to make a claim) 
does not play fair and uses the right of complaint to simply delay project implementation for 
ideological  or  commercial  reasons.  To  prevent  this,  some  countries  have  safeguards  in 
place. Nevertheless, measures to streamline litigation by third parties were identified in only 
four target countries (see Figure 2-25 above). 

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In  Germany,  for  example,  as  a  part  of  the  Renewable  Energy  Sources  Act  (EEG),  the 
Federal Ministry for Environment established a clearing authority 23 in 2007 for the resolution 
of conflicts concerning the deployment of renewable energy sources.  

Another measure to streamline the judicial process research found in Member States by 
third parties is to limit the right of appeal to those parties who are (potentially) affected by 
the decision or act of the competent authority (significant individual interest). This was the 
case in Lithuania and Denmark. In contrast, all municipality residents in Finland have the 
right to lodge a complaint about spatial planning decisions – not only those who are directly 
(potentially)  affected  by  the  change  in  the  spatial  plan.  No  specific  reason  for  filing  a 
complaint  is  required.  This  is  perceived  as  one  of  the  significant  barriers  to  the 
implementation of renewable energy projects in Finland. Also in Ireland, nearly everyone 
could appeal a planning permission at the time of the mapping. Having acknowledged that 
this was an obstacle to further and faster deployment of renewable energy projects, An Bord 
Pleanála (Ireland's national independent planning body) was discussing how to reform the 
appeal process, to rationalise third parties’ ability to file appeals. 

In Denmark, the right to appeal in the case of decisions under the Planning Act (with the 
exception  of  rural  zone  permits)  was  limited  to  questions  concerning  the  legality  of  the 
decision. The same was the case for EIA screening decisions. This meant, that the board 
(the Planning Board of Appeals for planning decisions and the Environment and Food Board 
of  Appeals  in  case  of  EIA  screening  decisions)  could  only  try  whether  the  decision  was 
made in accordance with all applicable rules, but could not reopen the examination of the 
subject matter. This hindered the re-evaluation of renewable energy projects that may be 
viable. 

2.3.8.9. Summary 

In summary, the results of the mapping of administrative permitting procedures showed that 
in  EU  Member  States  the  most  frequently  used  features  to  simplify  administrative 
procedures for renewable energy projects were (1) simultaneous procedures, (2) the use of 
simple notification procedures for small-scale renewable energy projects and (to a lesser 
extent)  for  repowering  projects,  (3)  the  use  of  pre-application  consultations,  and  (4)  the 
adoption  of  certain  financial  and/  or  non-financial  project  acceptance  measures.  On  the 
other  hand,  application  of  the  “two  plus  one”  and  “one  plus  one”  rules  and  measures  to 
streamline  the  litigation  by  third  parties  were  not  yet  widely  implemented,  leaving  much 
room for improvement in the majority of countries.  

23 www.clearingstelle-eeg-kwkg.de 

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3. Monitoring  of  the  Member  States  based  on  the 

performance indicators 

The  goal  of  the  underlying  work  of  this  chapter  is  to  grasp  the  performance  of  EU-27, 
Iceland,  Norway,  and  the  UK  when  it  comes  to  permitting  procedures  of  renewables 
projects.  Initially  this  was  thought  to  be  the  basis  for  the  analysis  of  best  practice  in 
permitting. However, this approach was adapted as is described in the following chapters. 

3.1. Methodology  

The  performance  indicators  that  were  developed  initially  were  the  starting  point  for  the 
analysis of good RES-E and RES-H permitting practice in Europe. To fill these indicators 
with  life,  we  conducted an  online  survey  and  evaluated  the  data in  the  National  Reports 
prepared  by  the  Consortium.  The  project  partners  WindEurope  and  SolarPower  Europe 
distributed  the  survey  among  their  members.  Also,  members  of  the  associations  EREF 
Europe  (small  hydropower),  EGEC  (geothermal  energy)  and  Solar  Heat  Europe  were 
involved. The goal was to gather technology and process step specific information on the 
performance  of  permission  procedures  in  individual  countries.  This  approach  aimed  at 
identifying especially well functioning processes and steps so that these could be analysed 
further. 

Figure 3-1 shows the headline of the survey and an exemplary question. For eight different 
topics participants could answer questions. Questions were either multiple choice questions 
or open questions. This way participants could choose a given answer and provide free text. 
The survey was open for two months and we received 39 responses. 

Source: RES Simplify 

Figure 3-1: Headline of the RES Simplify survey and exemplary question 

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In addition to the survey responses, we also reviewed the National Reports elaborated in 
Task 1, as described in section 2.2. Data that provided information on the performance of 
procedures was added to the research. However, data was only available for 14 out of 27 
Member  States.  Therefore,  a  complete  picture  of  the  European  situation  could  not  be 
painted. 

Additionally,  the  data  was  not  statistically  robust  and  therefore  it  was  unclear  how 
representative the obtained information is. For seven Member States with the data, only 
one data point was available. The other Member States showed between three and eight 
replies,  which  can  also  not  be  considered  representative  from  a  statistical  point  of  view. 
Therefore, we decided to deviate from the initial approach. Originally, the indicators were 
the  basis  for  the  research  of  best  practice,  which  had  aimed  at  focusing  on  obviously 
successful permission procedures in “high performance” Member States. However, with the 
data  available  it  was  not  possible  to  clearly  identify  which  Member  States  show  good 
permitting procedures. 

Although  the  data  is  not  representative  it  can  show  trends  and  can  give  an  idea  on  the 
situation in the respective Member States. Therefore, we used our evaluation as a starting 
point for discussion with stakeholders. For the depiction of the data, we formed average 
values for the individual Member States. Afterwards the data was shown in Europe maps. 
These maps were the input for two stakeholder workshops for wind and solar power. 

The participants of the workshops were members of RES associations from their respective 
Member States. The goal of the workshops was to consolidate the data which had been 
gathered so far. Also, we planned to retrieve new information. During the workshops the 
findings  on  the  performance  indicators  was  presented.  These  consolidation  workshops 
revealed that there are different perceptions on national situation amongst stakeholders and 
national  experts.  This  underlined  the  dependencies  from  the  individual  subjective 
assessment, and the need for a broader data basis in order to clearly identify best practice 
countries.  

Irrespective of that, section 3.2 presents the main findings on performance indicators. For 
further  research,  and  as  a  contribution  for  monitoring  and  further  improving  permission 
procedures in Europe, it is recommended to introduce an obligation for Member States to 
regularly report on the performance of the RES permission activities (see section 6.3.3). 

3.2. Key findings on performance indicators 

In  this  chapter  the  data  from  the  survey  and  the  National  Reports  is  depicted  in  Europe 
maps.  This  way  they  give  an  overview  of  the  European  situation  and  possible  regional 
trends. The maps either depict a single indicator or a combination of two indicators. This 
way possible connections or suspected effects of indicators become visible. 

Disclaimer: The maps depicted in this chapter only have an indicative character as the 
data basis is not representative. 

As the following Table 3-1 for overall efficiency shows, only limited data exists based on the 
conducted online survey. The sample size for all Member States for PV-related responses 
is 24 and for wind onshore 23. For most Member States only between one and three data 
points are available, with France and Poland being the exception with eight and five data 
points respectively. For other indicators the data basis has a similar shape. 

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Table 3-1: Overview over responses received on the performance indicator “overall efficiency of permission 
process” (selection list for optional answers: “High efficiency (less time than the RED II limits)”; “Satisfactory 
efficiency (within the time of the RED II limits)”; “Moderate efficiency (more time than the RED II limits)”; “Poor 
efficiency (considerably more time than the RED II limits)”; “No answer”) 

Country

PV

Austria
Croatia
Denmark
France
France
France
France
France
France
France
France
Germany
Germany
Germany
Italy
Italy
Italy
Latvia
Netherlands
Poland
Poland
Poland
Poland
Poland
Portugal
Portugal
Portugal
Romania
Slovakia
Slovakia
Slovakia
Spain
Spain
Spain
United Kingdom

Poor
Satisfactory

Moderate
Moderate
Poor
Poor
Moderate

Poor
Satisfactory
Poor
Moderate
Poor

Moderate

Poor
Poor

Poor
Satisfactory
Moderate
Poor
Poor

Poor
Satisfactory
Poor
Poor

Source: RES Simplify 

Wind 
onshore
Poor
Poor

Poor

Moderate
Poor
Moderate

Poor

Poor
Poor
Moderate

Poor
Poor
Poor
Poor
Poor
Poor
Satisfactory
Moderate
Poor

Satisfactory
Poor
Poor
Moderate

For the depiction in Europe maps average values for the Member States were used. This 
is  critical  for  Member  States  with  only  one  data  point.  In  this  case  the  reply  of  a  single 
stakeholder is depicted as representing the overall situation in a Member State. Although 
stakeholders  were  asked  to  reply  not  for  individual  projects  but  the  whole  industry  this 
cannot necessarily be interpreted as the actual situation in the Member State. Therefore, 
the following maps rather show an indication and can serve as the basis for a discussion 
about the actual situation. Besides this, it should be pointed out that the focus on average 
values does neglect the range of provided answers. 

3.2.1. PV 

Figure  3-2  below  depicts  the  overall  perceived  efficiency  of  PV  permitting  processes  in 
European  Member  States.  Efficiency  of  permitting  describes  the  necessary  time  from 
handing  in  the  application  by  project  developers  to  handing  out  of  permissions  by 
authorities. 

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Source: RES Simplify 

Figure 3-2: Indicative results of overall perceived efficiency of PV permitting processes (n = 24) in European 
Member States 

In most Member States stakeholders assessed the overall perceived efficiency as rather 
low. Denmark showed the highest score with a satisfactory efficiency. The efficiency of other 
Member  States  ranged  from  moderate  to  poor.  Eastern  and  Southern  Member  States 
showed a lower efficiency than Western and Northern Member States. For a lot of Member 
States no information was available. 

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Source: RES Simplify 

Figure 3-3: Indicative results of overall perceived efficiency of PV permitting processes (n = 24) and 
possibilities for stakeholder participation (n = 22) in European Member States 

In  the  online  survey  the  respondents  were  asked  for  the  possibilities  of  stakeholder 
participation in permitting procedures. The results reflect the subjective assessment of the 
situation by the respective respondents, but they do not technically reflect clearly defined 
measures for stakeholder participation. These measures can range from a situation where 
stakeholders  are  simply  asked  for  their  opinion  to  an  in-depth  participation  in  e.g.  site 
selection.  The  concrete  definition  of  participation  was  left  open  for  the  interpretation  of 
stakeholders, which has to be considered when interpreting the results. 

As stakeholders can influence RES-E projects, their opposition may lead to litigation and 
slow down their realisation. Participation therefore is important as it can prevent litigation 
and  corresponding  timely  procedures.  This  way  the  realisation  of  projects  is  sped  up. 
Therefore, an early stakeholder engagement plays a key role. 

As depicted in Figure 3-3 above possibilities for participation range in Member States from 
“Possible  without  barriers”  to  “Possible  only  with  large  restrictions”.  For  the  majority  of 
Member States for which data was available participation of stakeholders is possible to a 
large  extent.  Spain,  Slovakia,  and  Romania  show  participation  for  stakeholders  without 
barriers. Only Croatia demonstrates higher barriers for participation. For the interpretation 
of this overview, it should be pointed out that most respondents where representatives of 
the RES industry, whose assessments might differ from those of other stakeholders (e.g. 
environmental NGOs or authorities). 

Combining the overall efficiency with the possibilities for participation did not show a clear 
trend.  The  assumption  that  in  countries  with  well-functioning  stakeholder  participation 
project  realisation  is  faster  could  not  be  confirmed:  in  “moderate”  and  “poor”  efficiency 

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countries both good and bad possibilities for participations can be observed. Disclaimers 
apply for this depiction. 

Source: RES Simplify 

Figure 3-4: Indicative results of overall perceived efficiency of PV permitting processes (n = 24) and average 
process duration (n = 39) in European Member States 

Figure 3-4 above depicts the overall permitting process duration and the overall perceived 
efficiency.  PV  data  refers  to  rooftop  systems,  ground-mounted  PV  systems,  and  non-
specified PV systems. If stakeholders gave information on PV without specifying the kind of 
technology, this data was interpreted as non-specified. 

In  the  survey,  the  overall  duration  of  permitting  procedures  comprises  the  time  until  all 
necessary  permits  are  obtained.  This  also  includes  the  time  to  clear  legal  challenges. 
Participants  were  asked  to  evaluate  the  situation  in  their Member  States.  Art.  16 RED  II 
currently aims for a total process duration of two years on average. Under extraordinary 
circumstances this can be extended by one year. The duration defined by the RED II does 
not include legal challenges nor time spent on environmental assessments, in contrast to 
the survey. However, from a project developer’s point of view, the relevant parameter is the 
total  length  of  the  process  up  to  the  commissioning  of  a  plant,  including  expected  legal 
cases.  The  survey  also  asked  for  a  differentiated  indication  of  the  length  of  individual 
process steps. Thus, it was intended that also the process duration excluding the time for 
litigation could be evaluated. However, received data did not allow for such an assessment.  

The  overall  process  duration  that  was  stated  by  stakeholders  showed  a  large  variation 
between Member States. For rooftop PV systems the process duration varied between 0.1 
years  in  Malta  and  0.8  years  in  Bulgaria.  For  ground-mounted  PV  systems  the  reported 
duration varies between one year in Bulgaria and 4.5 years in Greece. Not specified PV 
installations show comparably high durations that range from one to 4.6 years. As expected, 
the  permitting  duration  experienced  for  rooftop  installations  is  shorter  than  for  ground-

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mounted systems. The duration of non-specified PV installations suggests that these power 
plants may be ground-mounted PV systems as well. 

For rooftop PV systems the two-year limit defined by art. 16 RED II is met all over Europe. 
For ground-mounted systems durations potentially including legal challenges and EIA did 
not exceed two years in four out of seven Member States. Greece, Ireland, and Spain are 
exceptions as processes last for more than three or even four years here. Most processes 
for unspecified PV installations often do not exceed the duration of three years. Exceptions 
are France, Poland, and Portugal. 

As a second major indicator the overall perceived effectiveness of processes was queried 
from stakeholders. Effectiveness was defined in the scope of the survey as the ability of 
processes  to  hand  out  permissions.  Ineffective  processes  grant  fewer  permissions  as  a 
share of total applications. 

Source: RES Simplify 

Figure 3-5: Overall perceived effectiveness of PV permitting procedures (n = 26) in European Member States 

The  map  above  (Figure  3-5)  depicts  the  overall  perceived  effectiveness  in  European 
Member States. In contrast to the overall efficiency of PV permitting procedures, there are 
no countries with a poor rating. Out of twelve Member States for which survey results were 
available, seven showed a satisfactory effectiveness and only five a moderate one. 

This shows, with the disclaimers in mind, that although processes are not the most efficient 
ones, permits are granted to project developers at least with a moderate effectiveness. 

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Source: RES Simplify 

Figure 3-6: Overall perceived effectiveness of PV permitting procedures (n = 26) and project approval rate (n 
= 44) in European Member States 

Figure 3-6 above shows the overall perceived effectiveness and the approval rate of PV 
project  applications  in  European  Member  States  and  the  UK  as  assessed  in  the  RES 
Simplify  survey.  The  approval  rate  defines  what  share  of  applications  are  handed  out  a 
permission. It thereby acts as a second indicator for the overall effectiveness of permitting 
procedures. 

If no permission is handed out, authorities reject a planned project. Also, it may be the case 
that authorities cannot deal with a project in time or delay it by questioning assessments or 
documents.  The  reasons  for  this  can  be  manyfold,  e.g.  the  lack  of  a  suitable  basis  for 
decision-making or the large number of applications. 

The approval rate which has been derived based on the RES Simplify survey varies widely. 24 
Approval rate ranges from 10% in Portugal to 98% in Croatia. However, Portugal seems to 
be an outlier with complicated procedures as for other Member States the approval rate is 
at least 48% and goes up to 98%. 

As the survey responses are based on subjective experiences of the stakeholders, we also 
analysed the RES expansion of the EU Member States to complement this information.  

24 Disclaimers apply here.  

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Source:  RES  Simplify  based  on  the  EurObserv'ER  online  database  (https://www.eurobserv-er.org/online-database/  |  Last 
access: 12 July 2021) and Integrated National Energy and Climate Plans of the Member States of the European Union. 

Figure 3-7: Deployment of PV in 2017, 2018 and 2019 in relation to linear target-compliant trajectory to reach 
the 2030 PV capacity goals defined in the Integrated National Energy and Climate Plans (NECPs) 

Figure 3-7 above shows the yearly deployment of PV in relation to the yearly necessary 
deployment to reach the 2030 PV capacity goals defined in the NECPs. 100% depicts the 
yearly  deployment  to  reach  these  goals  in  a  linear  manner.  For  each  Member  State  the 
deployment in 2017, 2018 and 2019 was extracted from the EurObserv’ER database, which 
is  based  on  the  data  from  Eurostat.  This  was  put  in  relation  to  the  necessary  yearly  PV 
deployment, which was derived from the technology specific targets defined in the NECPs. 
A deployment over 100% shows that necessary deployment was exceeded and vice versa. 
Not all states provided information in their NECPs that was usable for this figure. In this 
case “n/a” is shown for the country. 

As the figure shows, only four states exceed their yearly necessary deployment (based on 
the  assumption  of  a  linear  increase)  in  2019:  Estonia,  Spain,  Hungary,  and  Malta.  Only 
Malta was able to surpass their goal in three consecutive years. Apart from the yearly target-
compliant deployment, also the development in between years can be interpreted. Almost 
all states showed an improvement, most notably Germany and Hungary. The reason for 
this can be a change to more attractive support policies. Interestingly, Estonia and Spain 
had almost no expansion of PV in 2017 and 2018.  

Countries with high deployment rates suggest that not only the support scheme is attractive 
but also permitting processes function well. Therefore, the information from the Figure 3-7 
above can indicate best practice for permitting PV installations in Estonia, Spain, Hungary, 
and Malta. 

3.2.2. Onshore wind 

Figure  3-8  below  depicts  the  overall  perceived  efficiency  of  onshore  wind  permitting 
processes in the EU Member States. Efficiency of permitting describes the necessary time 

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from  handing  in  of  documents  by  project  developers  to  handing  out  of  permissions  by 
authorities. 

Source: RES Simplify 

Figure 3-8: Indicative results of overall perceived efficiency of onshore wind permitting processes (n = 23) in 
European Member States and the UK 

In most Member States, stakeholders assessed the overall perceived efficiency of onshore 
wind  permitting  rather  low.  Most  states  show  a  poor  efficiency.  Exceptions  are  France, 
Latvia, Portugal, Spain, and the UK. Therefore, a distinction can be made between Western 
European countries on the one hand and Central and Eastern European countries on the 
other hand.  

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Source: RES Simplify 

Figure 3-9: Indicative results of overall perceived efficiency of onshore wind permitting processes (n = 23) and 
possibilities for stakeholder participation (n = 21) in European Member States and the UK 

As was mentioned in the previous chapter, no clear definition of participation was given in 
the  survey.  Therefore,  respondents  might  have  different  understandings  of  this  concept. 
This must be considered when interpreting these results. 

As is depicted in the figure above, the possibilities for participation between the Member 
States  vary.  For  countries  for  which  data  was  available,  almost  all  make  participation  of 
stakeholders possible to a large extent. Austria, France, Romania, Spain, and the UK show 
participation for stakeholders without barriers. Also in Germany, Italy, Latvia, and Poland 
stakeholders may participate to a large extent without barriers. Only Croatia shows large 
restrictions for participation. 

Combining  the  overall  perceived  efficiency  with  the  possibilities  for  participation  did  not 
show  a  clear  trend.  The  assumption  that  in  countries  with  well-functioning  stakeholder 
participation  project  realisation  is  faster  could  not  be  confirmed:  In  moderate  and  poor 
efficiency countries good and bad participatory possibilities can be observed. 

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Source: RES Simplify 

Figure 3-10: Indicative results of overall perceived efficiency of onshore wind permitting processes (n = 23) 
and average process duration (n = 39) in European Member States; Remarks: Belgium: Average duration is 
shown for Flanders and Wallonia combined. Italy: Only comprises time for the preparation of EIA and 
individual permit. Latvia: Since 2012 no new projects have been developed.  

Figure 3-10 above depicts the overall permitting process duration and the overall perceived 
efficiency  for  onshore  wind  projects.  The  overall  duration  of  permitting  procedures 
comprises the time until all necessary permits are obtained, possible legal challenges are 
cleared and the EIA is obtained. Art. 16 RED II currently aims for a total process duration 
of  two  years  on  average,  which  can  be  extended  by  one  year  under  extraordinary 
circumstances. The duration defined by the RED II does not include legal challenges nor 
time spent on environmental assessments, contrary to the survey.  

The provided information on overall process duration for onshore wind permitting showed 
a large variation between countries. For most countries, the duration of procedures varies 
around 6 years. The shortest durations can be found in Latvia with 2.8 years, the UK as well 
as Finland with 3 years. The longest durations with 8 and 9 years were reported in Greece 
and Ireland. 

Almost no country manages to realise permitting in two (respectively three) years as stated 
in the RED II. It must be emphasised that the durations in the figure contain the time to clear 
legal  challenges  and  realise  the  EIA.  Therefore,  long  processes  are  not  only  caused  by 
inefficient  and  slow  processes.  The  figure  shows  that  countries  with  a  higher  efficiency 
rating tend to show shorter permitting durations. This is a contrast to Figure 3-4 which shows 
the corresponding data for PV. There no trend between the perceived level of efficiency and 
the process duration could be found.  

During the RES Simplify survey also the overall perceived effectiveness of processes was 
queried  from  stakeholders.  Effectiveness  was  defined  in  the  scope  of  the  survey  as  the 
ability of processes to hand out permissions. Ineffective processes grant fewer permissions 
per applications or no permits at all. 

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Source: RES Simplify 

Figure 3-11: Overall perceived effectiveness of onshore wind permitting procedures (n = 23) in European 
Member States and the UK 

The map above depicts the overall effectiveness in European Member States and the UK. 
In  contrast  to  the  overall  perceived  efficiency  of  onshore  wind  procedures,  there  are  no 
countries with a poor rating. Out of the ten countries for which data was available six showed 
a moderate effectiveness and four a satisfactory one. 

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Source: RES Simplify 

Figure 3-12: Overall perceived effectiveness of onshore wind permitting procedures (n = 23) and project 
approval rate (n = 28) in European Member States and the UK 

The approval rate defines what share of applications are handed out a permission. If no 
permission is handed out, authorities reject a planned project. The approval rate therefore 
evaluates the effectiveness of permitting procedures and complements the information on 
the overall perceived effectiveness of processes. 

The  approval  rate  varies  widely. 25  The  approval  rate  varies  between  5%  and  goes  up  to 
95%. Greece shows the lowest approval rate. The low rate of 5% here is connected to the 
project  developers’  approach  in  this  country,  as  has  been  clarified  in  the  consolidation 
workshops: usually a large variety of projects is planned of which only a small number is 
completed. Low rates are also present in Denmark, Italy, and Sweden. The highest approval 
rates can be found in Austria, Croatia, and Portugal. 

The overall perceived effectiveness is displayed in combination with the project approval 
rate. This confirmed the hypothesis that a good effectiveness potentially appears with higher 
approval rates. An exception is France, which shows a comparably low approval rate with 
a high effectiveness.  

In  order  to  complement  the  picture  which  derives  from  the  subjective  responses  to  the 
survey, we analysed how the annual RES capacity increase in Member States relates to 
the increase which is necessary in order to reach national 2030 RES targets, as indicated 
in the NECPs.  

Figure 3-13 shows the yearly deployment of onshore wind in relation to the yearly necessary 
deployment  to  reach  the  2030  NECP  onshore  wind  goals.  100%  depicts  the  necessary 
deployment  to  reach  these  goals  in  a  linear  manner.  For  each  Member  State  the  yearly 

25 Disclaimers apply here. 

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deployment in 2017, 2018 and 2019 was extracted from the EurObserv’ER database, which 
is based on the data from Eurostat. This was put in relation to the necessary yearly onshore 
wind  deployment  that  was  derived  from  the  technology  specific  targets  defined  in  the 
NECPs.  A  deployment  over  100%  shows  the  necessary  deployment  was  exceeded  and 
vice versa. Not all states provided information in their NECPs that was usable for this figure. 
In this case “n/a” is shown for the country. 

y
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a
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n
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A

160%

140%

120%

100%

80%

60%

40%

20%

0%

2017 - new RES-E capacity installed

2018 - new RES-E capacity installed

2019 - new RES-E capacity installed

Annual capacity  addition required 
for 2030 NECP goal

119%

31%

31%

n/a

n/a

n/a

n/a

n/a

10%

n/a

n/a

n/a

n/a

n/a

n/a

n/a

2%

n/a

n/a

n/a

n/a

n/a

0%

n/a

n/a

0%

n/a

AT BE BG CY CZ DE DK EE ES

FI

FR GR HR HU IE

IT

LT

LU LV MT NL PL PT RO SE

SI

SK UK

14%

Source:  RES  Simplify  based  on  the  EurObserv'ER  online  database  (https://www.eurobserv-er.org/online-database/  |  Last 
access: 12 July 2021) and Integrated National Energy and Climate Plans of the Member States of the European Union. 

Figure 3-13: Deployment of wind onshore in 2017, 2018 and 2019 in relation to linear target-compliant 
trajectory to reach the 2030 wind capacity goals defined in the Integrated National Energy and Climate Plans 
(NECPs) 

Again, this lack of data underlines the need for a common EU requirement that Member 
States should make such data available in their national reporting (see section 6.3.3). 

As Figure 3-13 shows, only Ireland exceeded their yearly necessary deployment (based on 
the assumption of linear increase) in 2019 after a decline in 2018. For Denmark, Germany, 
Italy,  Latvia,  Portugal,  Romania,  and  Slovakia  the  installation  of  capacity  in  2019  is  the 
lowest  in  all  three  years.  The  development  of  the  yearly  deployment  indicates  that  the 
permitting situation in none of the countries was improving. For Germany, Denmark, and 
Italy it seems that the situation was even worsening. However, in 2021 the German situation 
is improving (FA Wind 2021). Latvia, Portugal, Romania, and Slovakia will need to increase 
their deployment conditions significantly as wind expansion is progressing with a very low 
rate or not at all.  

Ireland exceeded its goals in 2019 and improved in comparison to 2018. From this follows 
that the assessment of available data only suggests Ireland as a candidate for permitting 
best practice. 

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4. Dissemination and promotion of best practice 

4.1. Objective 

The objective of this task was to carry out a number of dissemination activities by drawing 
on the engagement plan developed for this purpose. The task also aimed to further promote  
good  and  best  practices  collected  by  the  RES  Simplify  project  across  the  EU-27.  The 
Consortium used the window of opportunity during which the RED II was being implemented 
by Member States, given the relevance of proposed practices. Dissemination and promotion 
became  the  cornerstone  of  the  project  as  it  connected  all  the  tasks  and  enhanced  their 
efficacy. 

In the light of above, Task 3 included the following project activities: 

•  engagement  of  public  policy  makers  and  regulators  as  well  as  private  industry 

stakeholders and civil society groups, 

•  validation of the preliminary results and dissemination of good and best practices, 
• 

identification of newly emerged good and best practices in EU Member States during 
dissemination activities, 

•  sharing optimised processes identified in Task 4, 
• 

the collection of ideas and suggestions to develop new policy initiatives to optimise 
the permitting process at the EU level in Task 5. 

4.2. Methodology 

The  Stakeholder  Engagement  Plan  (SEP)  developed  for  the  RES  Simplify  project  and 
agreed  upon  by  the  European  Commission  highlighted  the  key  steps  to  engage  with 
stakeholders  in  the  course  of  the  project  implementation.  It  provided  a  blueprint  for 
engagement,  especially  the  representatives  of  the  renewable  energy  and  other  relevant 
industries, representatives of European organisations and initiatives that connect national 
and  municipal  public  target  groups,  European  and  national  regulators  as  well  as  groups 
advocating  for  environmental  issues  and  civil  society  groups.  Stakeholder  engagement 
provided valuable input and confirmation with respect to a number of project deliverables. 
Stakeholder engagement  enabled interaction between  key stakeholder groups. It offered 
them an opportunity to raise their concerns and opinions on permitting and grid connection 
related  specific  topics  via  conferences,  webinars,  in-person  meetings,  and  interviews.  In 
addition, stakeholder engagement ensured that these concerns and views were taken into 
consideration.  

In order to develop an effective SEP, it was necessary to determine who the stakeholders 
are and to understand their engagement-related needs and expectations, as well as their 
priorities and objectives in relation to the RES Simplify study. The Consortium involved key 
interest  groups,  namely  public  stakeholders,  and  private  industry  and  civil  society 
stakeholders to include and possibly align different and potentially conflicting perspectives. 
Public bodies in charge of administrative procedures at national, and – where relevant – 
regional level were of particular importance. In addition, grid operators, but also renewable 
energy  and  other  industry  associations,  developers  of  renewable  energy  projects  and 
operators of renewable energy installations, environmental NGOs, aviation organisations, 
and other relevant stakeholders participated in the dissemination activities of the project. 

Public stakeholders were the first target group as they are responsible for the regulation 
and  implementation  of  administrative  and  grid  connection  measures.  They  became  the 

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initial point of contact with regard to the planned amendments to the administrative and grid 
connection procedures in EU Member States, especially in the implementation of RED II 
and  the  dissemination  of  best  practices.  The  following  public  stakeholders  have  been 
approached: 

•  ministries 

responsible 

for 

renewable  energy,  building  and 

infrastructure, 

environment protection, aviation, defense, 

•  administrative  bodies  (national,  regional,  local)  responsible  for  the  submission  of 

(building and environmental) permits, 

•  any authorities that exist to reduce bureaucracy in the respective country or at the 

EU level. 

The  Consortium  contacted  private  industry  stakeholders  directly  affected  by  the  current 
administrative regime and the legislative changes related to the implementation of RED II. 
These  included  representatives  from  renewable  energy  and  other  industry  associations, 
developers of renewable energy projects and operators of renewable energy plants, and 
investors  in  renewable  energy  projects.  Closely  linked  to  this  group  were  electricity 
distribution system operators (DSOs) and transmission system operators (TSOs) both of 
which were involved. Stakeholders from the private sector more broadly and civil society 
were of utmost importance since they can have a significant impact on the development 
and  implementation  of  renewable  energy  projects  due  to  conflicting  interests.  They  also 
represented  the  main  target  group  which  could  help  identify  inefficiencies  in  current 
administrative  and  grid  connection  procedures  (i.e.  barriers)  as  well  as  good  and  best 
practices that other Member States could potentially adopt. These stakeholders include:  

•  environmental organisations and groups, 
•  water associations, 
•  civil and military aviation agencies and associations, 
•  other groups active at the local and regional level.  

There are a variety of engagement  techniques that were used to build relationships and 
trust  with  stakeholders,  gather  information,  as  well  as  consult  and  disseminate  project 
findings  to  stakeholders.  To  involve  both  private  and  public  stakeholder  groups,  the 
Consortium implemented a two-way approach that addressed stakeholders in both a top-
down manner from the European level, as well as bottom up from the national and regional 
level. The former by drawing on EU networks, while the latter involved directly contacting 
national private and public stakeholders and target groups. 

4.3. Stakeholder engagement activities 

We  designed  the  RES  Simplify  project  to  include  a  number  of  stakeholder  engagement 
activities,  which  collected  and  discussed  feedback  on  initial  project  results  as  well  as 
disseminated and promoted good or best practices on administrative and grid connection 
procedures for renewable energy plants. Planned activities targeted representatives of the 
renewable energy industry, policy makers and regulators both at the EU and Member State 
level,  and  other  public  and  private  stakeholders  across  the  EU.  The  formats  of  the  (co-) 
organised activities were workshops (primarily online/virtual webinars due to the COVID-19 
restrictions  in  force  at  that  time),  sectoral  surveys,  bilateral  meetings  (held  in-person  or 
online) as well as discussions and presentations at public EU-wide and national events.  

The project consortium typically presented the following project results:   

•  short introduction of the RES Simplify project, 
•  qualitative assessment of administrative and grid connection procedures in EU-27, 

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•  overview over the key administrative and grid connection barriers in EU-27, 
• 

recommendations and best practice examples for RES permission procedures. 

An  exhaustive  list  of  the  52  dissemination  activities  throughout  the  duration  of  the  RES 
Simplify project is provided in Table 4-1 below. 

Table 4-1: Implemented stakeholder engagement activities under the RES Simplify project 

Planned 
activity  
Initial sectoral 
meetings 

Implemented 
No. 
2 

Sectoral 
surveys  

2 

Final  sectoral 
workshops  

6 

Intersectoral-
engagement 
activities 

5 

Short description of activity and date 

•  WindEurope online workshop on 20.10.2020. 
•  SolarPower Europe online workshop on 18.11.2020. 
•  Online survey for solar power was launched in mid-December 2020 (was 
online  until  end  of  January  2021)  to  collect  input  on  good  practice  in 
permitting and grid connection procedure for solar power installations. 
•  Online survey for wind power industry was launched in mid-December 
2020  (was  online  until  end  of  January  2021)  to  collect  input  on  good 
practice  in  permitting  and  grid  connection  procedure  for  wind  power 
installations. 

•  WindEurope  online  feedback  and  validation  workshop  on  22.03.2021. 

Additional session on 16.06.2021. 

•  SolarPower  Europe  online  feedback  and  validation  workshop  on 

20.04.2021. 

•  SolarPower Europe online workshop on 26.05.2021; additional feedback 

and validation session on 07.06.2021. 

•  SolarPower Europe online webinar on solar potential in Europe on the 
ground on 09.02.2022 (to present and discuss good practice examples 
identified  and  collect  further  good  practice  in  permitting  and  grid 
connection procedure for PV). 

•  WindEurope sectoral online webinar on 02.03.2023. Final workshop to 
the 
disseminate  collect  good  practice  examples  and  discuss 
implementation  of  the  Renewable  Energy  Directive  &  EU  Emergency 
Measures on a national level. 

•  SolarPower Europe sectoral online webinar on solar on 22.03.2023 (to 
present  and  discuss  good  practice  examples  identified  and  collect 
further  good  practice  in  permitting  and  grid  connection  procedure  for 
PV). 

•  EU  NGO  online  workshop  on  10.12.2020.  Presentation  to  Agora, 
Beyond Coal, CAN, CEPS, ClientEarth, Greenpeace to present, discuss 
and validate preliminary research results on barriers and good practice. 
feedback  and  validation  workshop  with  national 

•  WWF  online 

representatives on 08.04.2021. 

•  EREF online workshop on 18.05.2021; additional session on 28.05.2021 
(feedback  and  validation  of  desktop  research  results  on  barriers  and 
good practice). 

•  EGEC  online  workshop  on  20.05.2021  (feedback  and  validation  of 

desktop research results on barriers and good practice). 

•  Solar  Heat  Europe  online  workshop  on  26.05.2021  (feedback  and 
validation of desktop research results on barriers and good practice). 

Engagement activities with policy-makers and regulators 
Virtual 
workshops 

RES Simplify project. 

6 

•  Presentation at the CA-RES group on 27.10.2020: Introduction into the 

•  Presentation at the CA-RES group on 17.11.2021: Overview of the key 
administrative and grid connection barriers to wind power projects in EU 
Member States.  

•  Presentation at the technical meeting of BEMIP offshore wind group on 
08.03.2022:  Overview  over  key  administrative  and  grid  connection 
barriers to offshore wind installations and best practices. 

•  Presentation at the CA-RES group on 19.05.2022: Presentation of good 
practice and recommendations for permission procedures for renewable 
energy installations. 

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National 
events 

11 

Bilateral 
meetings 

17 

•  DG GROW MS dialogue (as part of the Single Market Enforcement Task 
Force)  on  25.10.2022:  Presentation  of  good  practice  and 
recommendations for permission procedures for RES installations. 
•  Presentation  at  the  WEF  Working  Group  on  27.10.2022:  Accelerating 
permitting  for  renewables  scale-up  –  identifying  challenges  and  best 
practices in the permitting process for clean power projects in Europe. 
•  eclareon and the Slovak Association of Photovoltaic Industry and RES 
(SAPI) national online webinar in Slovakia on 28.03.2022: Presentation 
of  key  barriers  in  permitting  renewable  energy  installations  in  EU 
Member  States  and  good  practice  examples  in  simplifying  and 
accelerating permitting procedures across EU. 

•  WindEurope  national  annual  wind  energy  conference  –  WindEurope 
Ireland  on  13.04.2022  (session  on  permitting):  Presentation  of  key 
barriers  in  permitting  wind  power  projects  in  EU  Member  States  and 
good  practice  examples  in  simplifying  and  accelerating  permitting 
procedures for renewable installations across EU. 

•  Annual  Days  of  Good  Wind  organised  by  the  Croatian  Wind  Energy 
Association (OIE) on 02.-04.06.2022 in Dubrovnik, Croatia: Presentation 
of key barriers in permitting solar power projects in EU Member States 
and  good  practice  examples  in  simplifying  and  accelerating  permitting 
procedures for renewable installations across EU. 

•  SolarPower  Europe  national  online  webinar  in  Italy  on  27.06.2022: 
Presentation of key barriers in permitting renewable energy installations 
in  EU  Member  States  and  good  practice  examples  in  simplifying  and 
accelerating permitting procedures across EU. 

•  SolarPower Europe national online webinar in Sweden on 19.09.2022: 
Presentation of key barriers in permitting renewable energy installations 
in  EU  Member  States  and  good  practice  examples  in  simplifying  and 
accelerating permitting procedures across EU. 

•  eclareon  National  online  workshop  in  Hungary  on  27.10.2022:  RES 
Simplify  -  Reaching  carbon  neutrality  in  the  EU:  Sectoral  policies  and 
overcoming green energy barriers. 

•  SolarPower Europe and WindEurope national workshop in Romania in 
Bucharest  on  23.11.2022:  RES  Simplify  –  Simplification  of  permission 
and administrative procedures for RES installations. 

•  SolarPower  Europe  national  online  webinar  in  Spain  on  29.11.2022: 
RES Simplify - Administrative process as one of the main challenges for 
the rapid use of renewables. 

•  SolarPower  Europe  multinational  online  workshop  for  Belgium  and 
Netherlands on 15.01.2023: RES Simplify – Simplification of permitting 
procedures for RES. 

•  eclareon national online webinar: RES Simplify on 08.02.2023 - Good 
practice  and  recommendations  for  permission  procedures  for  RES 
installations  Webinar:  Permitting  of  RES  projects  in  the  Baltics”  (for 
Latvia, Lithuania and Estonia). 

•  SolarPower  Europe  national  online  webinar:  RES  Simplify  on 
01.03.2023  -  Simplify  Permitting  to  Accelerate  Renewables  (PV)  in 
Slovenia. 

•  Policy officer from Federal Ministry for Economic Affairs and Energy who 
is  working  on  steps  to  align  the  protection  of  environment  with  the 
development of RES deployment on legal conflicts due to environmental 
conflicts and their consequences for application processes. 

•  Finnish wind power developer on experiences with neighbour conflicts 
during  wind  power  projects  (motivations,  type  of  conflicts,  legal 
loopholes used by neighbours).  

•  Two  representatives  of  wind  power  turbine  manufacturers  on  existing 

legal and administrative issues.  

•  Officer  from  the  Ministry  of  Agriculture,  Rural  Development  and 
Environment/  Ministry  of  Interior  of  Cyprus  to  discuss  and  validate 
preliminary research results for Cyprus. 

•  Renewable energy advisor/project manager at the Ministry of Economic 
Affairs Energy Department of Estonia to discuss and validate preliminary 
research results for Estonia. 

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•  Regional planner at the regional council of Lapland, Finland to discuss 

and validate preliminary research results for Finland. 

•  Head  of  Department  at  Ministry  of  Innovation  and  Technology  of 
Hungary  to  discuss  and  validate  preliminary  research  results  for 
Hungary. 

•  Head of Department at Hungarian Energy & Utilities Regulatory Agency 

to discuss and validate preliminary research results for Hungary. 

•  Eirgrid  officials,  Ireland  to  discuss  and  validate  preliminary  research 

results for Ireland. 

•  Director of the Renewable Energy Promotion Department at the Energy 
Regulatory  Office  of  Czechia  to  discuss  and  validate  preliminary 
research results for Czechia. 

•  State  Secretary  responsible  for  the  Energy  Sector  at  the  Ministry  of 
Economy  of  the  Slovak  Republic  to  discuss  and  validate  preliminary 
research results for Slovakia. 

•  RES  policy  analyst  at  the  Swedish  Energy  Agency  to  discuss  and 

validate preliminary research results for Sweden. 

•  Representative of a German association that supports the expansion of 
wind energy on possible policies that speed up wind energy expansion, 
among others a clear legal basis for nature conversation, facilitation of 
regional planning or financial participation of neighbours. 

•  Experienced German wind energy project planner on existing legal and 
administrative  barriers,  among  others  missing  political  support, 
insufficient qualification of administration and missing strict deadlines. 
•  German  energy  supplier  and  wind  energy  project  planner  on  existing 
legal  and  administrative  barriers,  among  others  a  missing  clear  legal 
basis, missing local support for wind projects, missing area targets for 
wind projects.    

•  Bilateral online exchange between Oeko-Institut e.V. and eclareon and 

Iberdrola (ES). 

•  Bilateral online exchange between eclareon and WEF. 

3 

Presentation of results at public events and workshops 
Presentations 
public 
in 
events 
for 
public 
stakeholders 

•  WindEurope  Electric  City  2021,  Copenhagen  on  25.11.2021: 
Presentation of key barriers in permitting wind projects in EU Member 
States  and  good  practice  examples  in  simplifying  and  accelerating 
permitting procedures across EU. 

•  SolarPower Summit 2022, Brussels on 31.03.2022: Presentation of key 
barriers  in  permitting  solar  power  projects  in  EU  Member  States  and 
good  practice  examples  in  simplifying  and  accelerating  permitting 
procedures across EU – Facilitating project permitting, from promises to 
reality thanks to best practices. 

•  WindEurope annual event in Bilbao (side event – permitting workshop) 
on 06.04.2022: Presentation of key barriers in permitting wind projects 
in  EU  Member  States  and  good  practice  examples  in  simplifying  and 
accelerating permitting procedures across EU. 

4.4. Key findings of dissemination activities 

4.4.1. Brief summary 

The  consortium  (co-)organised  52  stakeholder  engagement  activities  in  total  between 
October 2020 and March 2023. Apart from the bilateral meetings with policy-makers and 
regulators, the vast majority of these activities took place after the completion of the RES 
Simplify  interim  report  in  July  2021.  The  objective  of  stakeholder  dissemination  was  to 
further promote and discuss examples of good practices linked to the permitting and grid 
connection  of  renewable  energy  technologies.  Another  goal  was  to  disseminate  findings 
and inform several (target) stakeholder groups responsible for designing approval and grid 
connection  procedures.  Presentations  of  our  results  were  followed  by  participants’ 

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Simplification of permission and administrative procedures for RES installations 

exchanges  predominantly  on  persisting  barriers  alongside  good  and  best  practices 
identified by the Consortium. 

During  the  dissemination  stage  of  project  results,  the  Consortium  reached  out  to  a wide 
variety of stakeholder groups. A vast network of national renewable energy associations 
turned out to be "gatekeepers" of utmoust importance in the sense that they could provide 
both  insights  and  reach  key  stakeholders.  In  view  of  this,  members  of  the  Consortium 
organised national events in cooperation with renewable energy associations in EU Member 
States.  A mix  of  national  decision-makers  (mainly  representatives  of  ministries,  energy 
regulators, and energy agencies), industry players (project developers), national TSOs and 
DSOs, as well as environmental NGOs, and consultants participated in these events. 

The  discussions  of  the  dissemination  events  at  the  national  or  the  multinational  level 
focused on current barriers and obstacles in the way of renewable energy deployment in 
respective  Member  States.  Among  these  obstacles  were  predominantly  unnecessarily 
complex and lengthy permitting procedures, a lack of knowledge and/ or understanding of 
RES  by  involved  public  stakeholders,  as  well  as  the  lack  of  investments  or  sufficient 
attention  to  the  sector.  Good  and  best  practices  either  identified  through  research 
conducted during the RES Simplify project or in the interim were also discussed. Ultimately, 
these events tended to focus on progress made and necessary further steps. 

legal 

frameworks  on  permitting  were  changing  rapidly  during 

The  national 
the  
dissemination of the project.  Member States were implementing the revised Renewable 
Energy  Directive  (RED  II)26,  but  a  number  of  contextual  factors  were  also  shaping  the 
attention the project received at the national and EU level. Its findings were instrumental in 
guiding how Member States approached their plans to draw on the Recovery and Resilience 
Fund, as the COVID-19 pandemic highlighted a number of vulnerabilities and shortcomings 
that  governments  needed  to  address.  The  subsequently  unfolding  energy  crisis  in  2021 
became a key point of departure that boosted renewable energy deployment to offset the 
price  spikes  consumers  experienced.  Renewables  became  essential  to  ensure  supply 
security and their competitiveness also increased as energy prices soared. 

The project’s outreach and thereby impact has been much broader than anticipated, since 
it became a starting point in the push for accelerating renewable deployment in light of an 
energy crisis that was worsened by Russia’s war on Ukraine. The sudden change in the 
geopolitical situation due to the outbreak of the war further highlighted the importance of 
renewable energy diffusion, as EU Member States sought to increase their energy supply 
security.  Following  the  invasion,  the  EU  adopted  the  REPowerEU  Plan  and  most 
governments  took  quick  action  to  drastically  reduce  imports  of  Russian  fossil  fuels, 
amplifying the importance of accelerating renewable deployment. RES Simplify offered solid 
research  and  recommendations  in  this  regard  and  formed  a  major  input  for  the 
Commission’s Recommendation on speeding up permit-granting procedures for renewable 
energy projects 27 and the accompanying guidance28, as well as the Commission’s proposal 

26 Although the deadline for the transposition of the RED II into national legal frameworks in EU Member States was set for 
30 June 2021, its implementation is still ongoing in some EU Member States as of early 2023, according to the findings of the 
RES Simplify project. 

27 Commission Recommendation (EU) 2022/822 of 18 May 2022 on speeding up permit-granting procedures for renewable 
energy projects and facilitating Power Purchase Agreements. Available at: http://data.europa.eu/eli/reco/2022/822/oj. 

28 COMMISSION STAFF WORKING DOCUMENT Guidance to Member States on good practices to speed up permit-granting 
procedures  for  renewable  energy  projects  and  on  facilitating  Power  Purchase  Agreements  Accompanying  the  document 
Commission  Recommendation  on  speeding  up  permit-granting  procedures  for  renewable  energy  projects  and  facilitating 
Power 
https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52022SC0149.  

SWD/2022/0149 

Agreements 

Purchase 

Available 

final. 

at: 

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Simplification of permission and administrative procedures for RES installations 

to revise the RED II 29. The project also offered help and guidance to Member States and 
allowed  them  to  respond  in  a  swift  manner  to  these  unexpected  challenges.  It  equipped 
them with the tools necessary to fight major bottlenecks and obstacles linked to permitting 
and grid connection procedures by drawing on examples from other EU countries. 

In  light  of  these  developments  and  thanks  to  the  series  of  dissemination  activities,  the 
project has also streamlined RED II-related policy-making by providing tangible examples 
of  measures  taken  by  a  number  of  Member  States.  With  this,  it  contributed  to  the 
simplification of permitting throughout EU Member States. 

4.4.2. Takeaways 

In this subsection, we provide key takeaways from the dissemination activities carried out 
as  a  part  of  the  RES  Simplify  project.  In  particular,  it  briefly  summarises  stakeholders’ 
insights  on  already  implemented  good  practices  in  permitting  and  grid  connection 
procedures introduced by EU Member States as well as their ideas for further improvements 
in national permit-granting procedures.  

Online tools and digitalisation 

The  introduction  of  new  online  tools  and  digitalision  of  processes  has  gathered  pace  as 
well.  For  example,  in  the  Netherlands,  a  digital  One  Stop  Shop  for  accelerating  the 
permitting procedures for renewable energy projects was created and should be launched 
in  2024.  In  Italy,  two  specific  digital  platforms  were  under  construction  in  October  2022. 
One is a single digital platform for the submission of project applications. The other aims to 
support  regions  of  Italy  to  identify  areas  suitable  to  host  renewable  energy  plants.  In 
Portugal, the RAU (Reporte Ambiental Único) is envisaged as a single repository for the 
monitoring and follow up of all procedures relevant for the development of renewable energy 
projects in the country in line with the new SIMPLEX framework that is in force as of 1 March 
2023.  Finally,  Spain  has  created  a  fully  digital  permitting  process  at  all  levels  of  the 
administration  for  all  renewable  energy  technologies30,  which  significantly  streamlined 
administrative processes throughout the country. 

Environmental impact assessment (EIA) 

A  few  Member  States  have  also  begun  to  introduce  measures  which  accelerate 
environmental impact assessment (EIA) related processes. For example, there is no need 
to conduct a new EIA in Italy, if the hydropower plant concession contracts’ criteria are not 
changed. At the EREF workshop on the small hydropower sector held in February 2022, it 
was suggested that for repowering of hydropower plants included in the EIA Law projects 
only need to be screened, instead of the full EIA procedures being undertaken. Italy has 
also  used  funds  from  the  Recovery  and  Resilience  Plan  (RRP)  to  create  a  Special 
Committee to perform EIAs of renewable energy and other projects funded under the RRP. 
In Lithuania, solar PV plants are not required to undergo an EIA process anymore, unless 
they are located in Natura 2000 areas. In France, if the repowering of hydropower plants is 
of  up  to  20%  capacity  only  and  it  is  considered  without  any  substantial  effects  on  the 
environment, no permission is needed. This up to 20% increase without permission can be 
used once in a project’s lifetime. Also, no EIA is needed if capacity does not change as a 
result of refurbishment. However, there should be no “heavy environmental impact” and the 

29  Proposal  for  a  DIRECTIVE  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL  amending  Directive  (EU) 
2018/2001 on the promotion of the use of energy from renewable sources, Directive 2010/31/EU on the energy performance 
of buildings and Directive 2012/27/EU on energy efficiency COM/2022/222 final. Available at: https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX:52022PC0222.  

30  National  level  (all  administrations):  https://rec.redsara.es/registro/action/are/acceso.do.  Example  of  a  local  level: 
https://geria.sedelectronica.es/info.0. 
project: 
https://sede.miteco.gob.es/portal/site/seMITECO/navServicioContenido.  

Possibility 

permitting 

consult 

status 

the 

to 

of 

a 

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Simplification of permission and administrative procedures for RES installations 

definition of “heavy” is based on the judgement of local authorities. Portugal also removed 
an  obligation  to  present  an  EIA  in  certain  cases;  for  example,  for  the  change  of  main 
equipment in wind energy projects and also for solar parks that occupy territory of less than 
100 hectars. 

Simple notification for small-scale PV  

Czechia and Bulgaria began to apply simplified notification procedures for small-scale PV 
installations quite recently. In Czechia, the threshholds for power generation licenses and 
also for building permits for small-scale solar PV installations were increased from 10 and 
20 kW of installed capacity respectively to 50 kW in January 2023. Similarly, in Bulgaria, 
self-consumption of renewable energy sources without export to the grid of up to 20 kW 
located in urban areas (rooftop, building-integrated photovoltaics, or on plots adjacent to 
existing buildings) enjoy a simplified notification procedure as of early 2023. Owners have 
the  obligation  to  notify  the  grid  operator  and  local  municipality  about  the  installation’s 
technical specifications, but are not required to obtain a building permit anymore. 

Overriding public interest principle 

It is worthwhile to highlight the work of a few Member States in their recent implementation 
of  the  overriding  public  interest  principle  for  renewable  energy  projects.  Germany  is  of 
particular  relevance,  as it  was  the  first  EU  Member  State  which  adopted  the  principle  of 
overriding public interested via its Renewable Energy Sources Act (Erneuerbare-Energie-
Gesetz  -  EEG)  in  July  2022.  The  principle  has  already  been  used  in  court  cases.  Most 
importantly  it  informed  a  recent  ruling  in  a  case  brought  to  court  in  Mecklenburg 
Vorpommern. 31  Furthermore,  Czechia  introduced  the  principle  of  assessing  renewable 
energy  projects  exceeding  1  MW  as  a  matter  of  public  interest  in  early  2023,  thereby 
equating  them  with  other  objects  of  public  interest  (i.e.  which  typically  do  not  require  a 
change in zoning plans). This is deemed to significantly accelerate the implementation of 
large-scale ground-mounted solar PV and wind power projects in the country. The principle 
is  also  mentioned  in  new  legislation  in  France  where  the  so-called  imperative  reason  of 
major  public  interest  was  introduced  for  certain  renewable  energy  projects 32  to  limit  the 
number of appeals one can launch against projects.  

Land use and acceleration areas 

A number of Member States adopted measures which may be considered examples of good 
practices  for  land  use.  Firstly,  Lithuania  introduced  its  energy  legislation  recently  and  a 
breakthrough package came into force in July 2022. It includes, among others, that solar 
PV, wind, and biogas installations producing electricity can be built on land outside cities 
without a change in land use plans. Secondly, positive developments in the simplified land 
use for renewable energy projects were recorded in the Balkans. Namely, Bulgaria adopted 
several  changes  simplifying  permit-granting  procedures  as  of  early  2023.  Renewable 
energy  projects  with  an  installed  capacity  up  to  1  MW  located  in  urban  areas  (rooftop, 
building-integrated photovoltaics, or on plots adjacent to existing buildings) are not required 
to prepare a detailed spatial plan and are subject to simplified procedures when obtaining 
a  building  permit.  Furthermore,  storage  projects  are  defined  as  movable  objects  and  as 
such enjoy a simplified building permit procedure, too.  

In  Romania,  renewable  energy  projects  can  now  be  developed  directly  on  extra-muros 
lands with fertility class III., IV. and V., which is considered a major and important legislative 
change. Additionally, Portugal has done a preparation work in order to identify the future 
renewables acceleration areas, which should cover around 12% of the country’s territory, 

31 https://www.energate-messenger.com/news/230514/overriding-public-interest-scores-first-time-in-court 

32 In order to benefit from the concept, projects are required to fulfil criteria given by the type of renewable energy source, the 
forecasted power of the planned installation, and the overall contribution expected from installations of similar power to the 
achievement of certain objectives set by the France’s energy strategy. 

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as foreseen by the revised RED. The screening included not only nature and biodiversity 
concerns but also potential for synergy, grid congestion, archeology and other aspects. The 
areas  have  not  been  fully  implemented  yet.  Spain  made  big  advances  by  creating 
acceleration areas for onshore wind and solar PV projects. The Spanish Government began 
this  by  undertaking  environmental  sensibility  mapping  for  both  technologies  in  2022, 
providing developers with a publicly available, digital tool to map nationwide areas suitable 
for renewable energy development. Developers have been using the map since February 
2022  to  accelerate  the  expansion  of  renewables.  For  “no-go  areas”,  Spain  established 
‘’exclusion indicators’’ as well as ‘’weighting indicators’’ for many types of areas. The more 
sensitive the areas (such as Urban areas, water bodies and flood zones, certain regions for 
species conservation, Natura 2000, etc.), the more difficult it is to obtain a permit. 

Positive silence for renewable energy projects 

The  principle  of  positive  administrative  silence  for  renewable  energy  projects  has  been 
introduced  in  some  Member  States.  Most  recently,  the  so-called  rule  of  administrative 
positive  silence  was  implemented  in  Portugal  under  its  aforesaid  SIMPLEX  framework, 
which has been in force since 1 March 2023. Spain also applies a 15-day deadline for some 
parts of the permitting procedure. Positive administrative silence applies and possibility of 
a favorable report without detailed analysis if the promoting company has already received 
another favorable report for the same technology (also in a different location) in the period 
of last two years. 

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5. Monitoring  the  implementation  of  permit  granting 

procedures following the transposition of RED II 

This section outlines monitoring results on how EU Member States amended their permit-
granting procedures for renewable energy sources – especially solar and wind energy, as 
these are the two technologies common to the decarbonisation pathway of Member States 
– to comply with the obligation of transposing arts. 15,16, and 17 of the RED II into national 
legislation (Task 5). The section begins by presenting the methodology employed to monitor 
these  national  development  across  the  27  EU  Member  States.  It  proceeds  with  a 
comparative  analysis  of  various  policy  implementation  pathways  towards  RED  II 
implementation  and  provides  also  additional  best  practices  going  beyond  its  current 
requirements, both reflecting the distinct political and economic contexts across the EU. 

5.1. Methodology 

This section provides a comprehensive overview of the methodology that was implemented 
to identify and summarise the evolution of permit granting procedures across EU Member 
States  between  April  2022  and  December  2022,  with  a  specific  emphasis  on  the 
transposition of arts. 15, 16, and 17 of RED II. In line with recent policy developments, the 
Consortium  identified  additional  good  practices  going  beyond  the  current  RED  II 
requirements, which are summarised in a separate section. 

Data gathering began with the establishment of a regular monitoring facility. This aimed to 
collect data on permit granting procedures’ legal amendments in EU Member States on the 
implementation of RED II arts. 15, 16 and 17. The facility involved monthly in-depth reviews 
of  the  national  legislative  process  across  27  EU  Member  States,  conducted  by  country 
researchers with an extensive knowledge of national legal and political frameworks. The 
country researchers utilised a variety of primary and secondary sources, including relevant 
websites of the national ministries, parliaments, and governments, as well as other reliable 
domestic sources of information. In addition, information on the implementation of RED II 
arts.  15,  16  and  17  was  gathered  through  European  renewable  energy  associations  – 
WindEurope and SolarPower Europe – and their networks. 

Country researchers conducted additional semi-structured interviews with representatives 
of the relevant ministries, parliaments, or with experts from the energy sector of that Member 
State, if the legal language used in a particular national development was unclear or where 
the implications of a certain modification were difficult to assess. This allowed the country 
researchers to clarify any ambiguities and ensure the accuracy of reporting. 

Although the monitoring process focused on a country-level approach, it was designed to 
leverage synergies at the transnational level. In the event of any regional developments, 
the  country  researchers  established  structures  of  cross-communication  to  ensure  the 
homogenisation of the information generated from the transnational monitoring process. 

Upon finalising the collection of the Member State monitoring results, the second step of 
our methodology involved a comparative assessment of the transposition of arts. 15, 16, 
and  17  of  RED  II  across  the  EU  Member  States.  The  aim  of  this  step  was  to  clarify  the 
points  of  convergence  and  divergence  between  different  approaches  towards  domestic 
transposition. By integrating this comparative analysis of legislative developments with our 
examination  of  barriers  and  good  practices,  we  aimed  to  reveal  the  key  determinants  of 
successful permit granting process reforms in the EU, in line with arts. 15, 16, and 17 of 
RED II. 

Overall,  our  methodology  was  designed  to  provide  a  comprehensive  and  systematic 
approach  to  monitoring  the  evolution  of  permit  granting  procedures  across  EU  Member 

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States. The use of a standardised framework and a rigorous review process ensured the 
accuracy and consistency of our data, while our comparative analysis allowed us to identify 
areas for improvement and share best practices across countries. 

5.2. Findings of Member State monitoring 

This  section  offers  a  comparative  analysis  of  the  permitting  process  reforms  across  EU 
Member States, in accordance with the transposition of arts. 15, 16, and 17 of the RED II. 
The objective is to gain insights from national experiences to comprehend broader policy 
trends  in  the  EU,  emphasising  innovative  policy  options  and  instruments  that  streamline 
and promote RES deployment. 

Transposing RED II entails intricate multi-level governance challenges, which directly and 
indirectly influence the policy choices made by Member States concerning permit granting. 
We concentrated on a select group of centrally relevant items, monitoring legislative activity 
in these specific areas. Generally, the items of interest pertain to developments that impact 
multiple  renewable  energy  technologies,  mainly  solar  PV  and  wind  power.  If  provisions 
strictly  apply  to  a  single  technology,  we  explicitly  present  the  rationale  behind  these 
decisions. For example, simple notification procedures were primarily developed for small-
scale rooftop PV projects.  

The main items of interest, which informed the assessment of the Member State monitoring 
results were the following: 

•  Do renewable energy project developers enjoy streamlined permit-granting through 

one-stop shops and digitalised procedures? 

•  Are renewable energy projects subject to a 2-year deadline for permit granting and 

a 1-year deadline for other requirements?  

•  Are  there  unique  regulations  for  repowering  projects  in  terms  of  permit-granting 

(shorter deadlines, impact assessment exemptions, etc.)?  

•  Do  any  special  rules  apply  to  permit-granting  for  projects  on  artificial  structures 
(shorter  deadlines,  impact  assessment  exemptions,  etc.)?  If  so,  are  there  any 
definitions or limited lists of such structures?  

• 

Is  there  a  straightforward  notification  process  for  grid  connections  of  small-scale 
projects?  

5.2.1. One Stop Shop and digitalisation 

The  single  contact  point  or  One  Stop  Shop  is  a  crucial  aspect  of  promoting  RES 
development  in  EU  Member  States  from  the  developers'  perspective,  as  it  significantly 
reduces administrative costs, ensuring they only need to contact one institution in order to 
obtain all the necessary permits and approvals for a project. This approach aims to simplify 
and  streamline  administrative  procedures  by  centralising  all  permit  and  authorisation 
requirements on a single platform, reducing bureaucratic hurdles and shortening the time 
required to obtain necessary permits for renewable energy projects. RED II also requires 
Member  States  to  allow  digital  submission  of  documents  by  the  applicant.  However, 
implementation of the single contact point and digitalisation levels vary among EU countries. 
Nevertheless,  the  design  and  implementation  of  digital  solutions  for  permit-granting 
procedures and the  One Stop Shop  concept  could display a high degree of universality, 
being easily implementable in some form across all Member States.  

In  Germany,  various  local  authorities  have  introduced  a  One  Stop  Shop  approach  for 
permitting procedures, substantially simplifying the process for renewable energy projects. 
Where  implemented,  these  procedures  are  supported  by  robust  digitalisation.  However, 

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there is currently no federal requirement to standardise the permit-granting process, which 
could pose potential obstacles for developers operating in different regions of Germany, as 
revealed by our Member State monitoring conducted between April and December 2022. 
The sole exception is represented by offshore wind projects, which benefit from a national 
One Stop Shop, developed as part of the Wind Energy at Sea Act adopted in July 2022. 

In the Netherlands, the Environment and Spatial Planning Act, which will enter into force 
on 1 January 2024 and replace a bundle of current legislative pieces, established a single 
permit  for  various  activities,  including  renewable  energy  projects.  However,  the  level  of 
digitalisation in the permit application process is still limited, with expectations that some of 
the  issues  will  be  addressed  in  2023.  Currently,  the  permit  granting  application  process 
varies across regional jurisdictions in the Netherlands, and is conditional on the size of the 
project.  There  is  an  expectation  that  the  new  Act,  coupled  with  other  legislative 
developments, will consolidate a solid national framework that embeds a One Stop Shop 
and incorporates digital tools to streamline application processes.  

In  contrast,  other  countries  have  yet  to  fully  embrace  a  One  Stop  Shop  approach  and 
digitalisation. In Slovakia, the regional grid operators have only recently started to digitalise 
grid connection procedures, while environmental and building permitting processes remain 
largely  paper-based.  In  Romania,  the  issue  is  more  complex.  Governmental  ordinance 
GEO 140/2022 for the single industrial license – a recent legislative development adopted 
in October 2022 – enables, under Section 2, renewable energy project developers to apply 
for  a  single  license  for  all  activities,  namely  generation,  transmission,  distribution,  and 
trading. A complete digital One Stop Shop has not been considered, one reason being that 
it would require a strong central administration ready to cooperate with developers across 
different regions, which is not the case for the moment. Similar issues have appeared in 
countries such as Hungary or Poland; in the case of the latter, this has materialised in the 
draft  version  of  its  ‘Energy  Policy  for  Poland  until  2040’  (PEP2040),  which  will  move  the 
procedure closer to a One Stop Shop approach.   

In France, the level of digitalisation of permit applications is still limited. Similarly, Italy's 
regulatory framework, while recognising the importance of renewable energy development 
under  the  Legislative  Decree  199/2021,  suffers  from  a  complex  regulatory  framework, 
overlapping  responsibilities,  and  a  lack  of  a  unified  digital  platform.  A  similar  issue  of 
fragmentation appears in Ireland, where at least for rooftop PV and small-scale wind power 
projects, there has been no attempt at digitalising the permit granting application. The most 
recent piece of legislation transposing the RED II Directive, the draft of the Planning and 
Development Bill of 2022, does not appear to resolve this issue.  

Spain has recently developed online platforms for permitting. Thus, fully digital permitting 
process at all levels of the administration are now available. Portugal has also announced 
a new digital platform, which will include an automatic electronic certification system and 
apply the rule of positive silence. Greece has also digitalised much of the process, with the 
target of shortening the entire permitting process from 5 years to 14 months. 

In summary, the comparative assessment of Member State monitoring results from April 
2022 to December 2022 indicates that digitalisation has emerged as a top priority for all 
Member  States,  primarily  due  to  its  potential  to  alleviate  administrative  bottlenecks 
throughout the permit-granting process. The comprehensive implementation of the single 
contact point required under RED II art. 16 is limited to a few Member States, with numerous 
others planning to introduce it throughout 2023. 

5.2.2. Deadlines for permit granting 

Introducing  explicit  deadlines  for  the  permit-granting  process  could  streamline  the 
deployment of renewable energy projects, as it ensures a timely and efficient authorisation 
process, with a timeline that can be clearly anticipated by projects developers. A significant 
number of Member States do not have specific deadlines for permit granting, partly because 

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of their decentralised political system, but also because there was no impetus to create new 
legislation in the past years. For example, Hungary, Slovenia, Slovakia and Sweden do 
not  have  any  specified  deadlines  for  the  permit-granting  processes,  which  may  result  in 
delays and uncertainty for renewable energy project developers. Spain, despite suffering 
from administrative bottlenecks and delays, has introduced provisions to reduce deadlines 
for  projects  with  a  favourable  environmental  impact  determination  report  under  art.  7  of 
Royal Decree —Law 6/2022 of 29 March 2022. 

Even  in case  where  an explicit  deadline  appears  in  the  legislation,  in  practice  such  self-
imposed  deadlines  are  not  always  respected  by  decision-makers.  This  is  the  case  in 
Member States such as Greece, Poland, or Romania. In the case of Romania, while the 
GEO  163/2022  transposed  most  of  the  RED  II  into  domestic  legislation,  there  is  no 
secondary  law  that  entails  specific  provisions  which  should  be  implemented  by  local 
authorities. On  the  other  side  of  the  spectrum,  Austria  and  Spain  have  both  introduced 
mandatory  deadlines,  through  the  Renewable  Energy  Expansion  Act  and  Law  6/2022 
respectively, with authorities attempting to enforce them. Currently, based on national-level 
reports  from  Spain,  such  deadlines  improve  the  swiftness  of  the  entire  permit  granting 
process, in line with the aims of the RED II, but for ensuring complete acquiescene with the 
RED II, deadlines should be further cut in half. Some of the longest durations of the permit 
granting process are observed in Italy, where certain projects had to wait around 7–9 years 
before being either approved or rejected, including the environmental assessment and court 
proceedings, as resulting from the data collected by SolarPower Europe and WindEurope. 

Although well-defined deadlines are essential for renewable energy project developers, our 
monitoring indicates that the demand for legislation in this area has not been met with a 
similarly  ambitious  supply  of  new  policies  from  national  governments.  While  the 
effectiveness  of  policies  that  explicitly  set  deadlines  for  the  permit-granting  process  in 
domestic legislation is undeniable, these approaches seem to face considerable political 
feasibility challenges. 

5.2.3. Repowering renewable energy installations 

Repowering  can  help  increase  the  capacity  and  efficiency  of  renewable  energy  projects 
without requiring additional land or extensive resources. It refers to the process of replacing 
or upgrading existing renewable energy installations, such as wind turbines or solar panels, 
with newer and more efficient technologies that have become available since the original 
project was commissioned.  

In Germany, repowering is actively encouraged, particularly for wind energy projects. As 
part  of  the  Renewable  Energy  Act,  repowering  measures  are  prioritised  over  new 
installations  in  the  same  area.  This  policy  approach  helps  to  maximise  the  potential  of 
existing  sites  and  supports  the  transition  to  more  efficient  technologies.  For  solar  PV 
projects,  developers  who  attempt  repowering  can  choose  to  receive  the  same  market 
premium as for the previous installation, up to the previously installed capacity. A similar 
approach,  where  priority  is  given  to  repowering,  directly  resulting  in  a  faster  permitting 
process,  can  be  found  in  Greece  under  art.  42  of  Law  4951/2022,  which  is  the  main 
instrument  for  the  RED  II  transposition.  The  simplification  of  the  authorisation  process 
complements initial developments that were adopted through Law 4685/2020. 

In contrast, France legislation supports repowering as long as installed capacity expansion 
remains  below  20%,  which  benefit  from  simplified  procedures.  The  general  framework 
supports  the  replacement  of  outdated  installations  with  more  efficient  technologies, 
especially  if  the  repowering  process  does  not  require  significant  changes  to  the  existing 
infrastructure or additional permits. The concept of repowering also depends on the specific 
modifications made to the originally-approved renewable energy installation. For example, 
in  Slovakia,  if  the  only  reason  for  repowering  is  technological  improvement  and  not  the 

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building part of the installation, no new permit is required per the most recent version of the 
Energy Act. 

Our  monitoring  of  the  RED  II  transposition  in  the  EU  Member  States  revealed  that 
repowering  is  much  more  of  a concern  for  countries  with  mature  RES  markets.  In these 
countries, the objective is no longer just to install new capacities. Instead, their focus tends 
to be on efficiently distributing land and other resources in order to maximise production 
and ensure low grid investment costs. That is the reason why in the majority of Member 
States there is no explicit mention of repowering in new domestic law that transposes RED 
II. As this means some of the provisions of RED II are not yet transposed, further legislative 
activity is expected throughout 2023.  

5.2.4. Renewable energy installations on artificial structures 

Artificial structures, such as rooftops, facades, and other built infrastructure, can be used to 
support renewable energy installations, particularly solar panels. Utilising artificial structures 
can help to maximise the available space for renewable energy production while minimising 
the  need  for  additional  land  resources.  EU  Member  States  have  designed  different 
approaches for how artificial structures should be used in pursuit of national and European 
climate objectives. 

The main takeaway is that for small-scale projects, especially rooftop solar PV, there is a 
simplified procedure that requires no additional permits in a significant number of Member 
States. For example, in Czechia, as provided in the previous section, no building permit is 
needed for rooftops up to 50 kW since January 2023, under the latest amendments to the 
State Energy Policy, initially adopted in 2015. This is a significant increase from the previous 
limit  of  20  kW.  Similar  developments  were  observed  in  2022  in  Ireland  and  Greece,  as 
revealed  by  the  Draft  Planning  and  Development  Bill  of  2022  and  Law  4951/2022, 
respectively. These legal updates  thoroughly simplified procedures in place for small PV 
projects on artificial structures, mostly for residential buildings. 

Explicit simplified procedures can be effective in solving certain administrative barriers, but 
many  Member  States  have  not  considered  them  because  they  attempted  to  design  a 
comprehensive  simplified  permit-granting  procedure  that  improves  the  process  for  all 
developers. This is particularly true for mature RES markets. For example, Germany has 
made significant progress in shortening the duration and bureaucratic complexity of permit-
granting  for  renewable  energy  projects  in  recent  years,  without  implementing  special 
provisions for small-scale installations. Therefore, the transposition of arts. 15, 16, and 17 
of RED II has not directly led to a rapid expansion of exemptions for small projects placed 
on artificial structures.  

5.2.5. Simple notification for small-scale PV  

Small-scale photovoltaic installations – typically referring to rooftop solar panels and other 
decentralised solar energy systems in the domestic legislation of EU Member States – play 
a crucial role in promoting the adoption of renewable energy and serve important market 
functions in both developing and mature RES markets. The permitting process for small-
scale  PV  projects  varies  across  EU  Member  States,  with  some  countries  implementing 
more streamlined processes and incentives to encourage small-scale solar adoption. Our 
monitoring  of  the  permit-granting  process  for  all  Member  States  reveals  that  almost  all 
countries have made significant progress on this issue, which is of direct importance for 
assessing the transposition of art. 17 of the RED II. 

Simplified  or  at  least  less  complicated  notification  procedures  for  obtaining  the  grid 
connection  permit  can  be  found  in  Austria,  Belgium,  Bulgaria,  France,  Germany, 
Greece,  Ireland,  the  Netherlands,  Poland,  Slovakia,  Spain,  and  Sweden.  In  most  of 
these cases, the transposition of art. 17 of the RED II was directly responsible for the new 

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pieces of legislation that addressed administrative bottlenecks for small-scale PV projects. 
More  specifically,  in  Poland,  according  to  the  construction  law,  a  building  permit  is  not 
required  for  the  performance  of  construction  works  consisting  in  the  installation  of  PV 
installations with a capacity of not more than 50 kW. In Sweden, electricity users with a 
subscription for a fuse of less than 63A are not required to pay a fee to connect a unit of 
less than 43.5 kW at an existing grid connection point. Such a connection is not considered 
new,  unless  the  new  addition  requires  the  fuse  to  be  upgraded.  Therefore,  electricity 
network companies are not able to deny such a connection request anymore. 

Currently, Italy is in the process of developing the necessary guidelines for implementing a 
simplified  notification  process  for  small-scale  PV  projects.  Following  Energy  Decree 
17/2022, a simplified model will be used for the connection of PV systems with a maximum 
power  of  200  kW  integrated  on  the  rooftops  of  buildings.  In  Romania,  government 
emergency ordinance GEO 163/2022 stipulates that, after six months following its entry into 
force,  the  Romanian  Energy  Regulatory  Authority  will  establish  a  simple  notification 
procedure  for  grid  connections,  whereby  installations  or  generating  units  of  renewable 
energy prosumers and demonstration projects with an approved electrical output less than 
or  equal  to  10.8  kW  will  be  connected  to  the  grid  following  a  simple  notification.  This 
provision is expected to enter into force in June 2023. 

5.3. Additional measures 

This section provides an overview over additional measures identified in the course of the 
RED II monitoring task. Since the items of interest provided below are not part of the current 
RED II, they are summarised separately. 

The main items of interest were the following: 

•  Do renewable energy projects receive priority due to public interest considerations, 
under the principle of overidding public interest? If so, which regulations are subject 
to this priority, and are there any specific conditions that developers must fulfill?  

•  Have  any  preferred  areas  been  designated  at  the  national  level  for  renewable 
energy deployment? Have any restricted areas been identified at the national level 
where  renewable  energy  deployment  is  prohibited?  Do  specific  rules  (time  limits, 
support schemes, impact assessments, etc.) apply within these preferred/restricted 
areas?  

• 

Is  a  tacit  approval  mechanism  in  place  for  administrative  decisions?  If  so,  under 
what conditions is it applied?  

5.3.1. Overriding public interest principle 

The principle of overriding public interest is an essential factor in the development of RES 
across EU Member  States, particularly in established markets. This concept implies that 
renewable  energy  projects  are  considered  a  priority  and  receive  preferential  treatment 
during  permitting  processes  and  land-use  planning.  However,  the  implementation  of  this 
principle varies significantly across EU, and in multiple Member States’ national laws and 
regulations there is still no mention of it.  

A rebuttable presumption that renewable energy projects and related grid infrastructure are 
in the overriding public interest and serving public health and safety when balancing legal 
interests  in  the  individual  cases  was  also  introduced  in  the  Council  Regulation  on 

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accelerating the deployment of renewable energy adopted on 22 December 2022 33. This 
facilitates that projects comply with one of the conditions to benefit from specific derogations 
foreseen in the relevant articles of the Habitats, Birds and Water Framework directives. 

As mentioned in the previous sections, Germany's Renewable Energy Act (Erneuerbare-
Energien-Gesetz - EEG) that was adopted in July 2022 explicitly recognises the importance 
of renewable energy projects, supporting their development in designated priority areas until 
greenhouse  gas  (GHG)  neutrality  is  achieved.  German  courts  have  already  applied  the 
concept  of  overriding  public  interest  after  the  implementation  of  the  legislation.  This 
prerogative appeared also in the initial version of the EEG, which entered into force in 2017, 
but in 2022 the norms of application became clearer. Similarly, France has classified both 
solar and wind energy projects of public utility under Renewable Energy Acceleration Bill, 
facilitating land expropriation for such projects when necessary. 

In  contrast,  countries  such  as  Romania  and  Slovakia  in  East-Central  Europe  do  not 
support  prioritisation  of  renewables  through  a  notion  of  public  interest  or  national 
significance. Romania, however, is considering a legislative reform on energy infrastructure 
that could introduce this principle by early 2024, according to expert interviews conducted 
with representatives of the Government throughout 2022. 

Sweden  exhibits  a  more  nuanced  scenario.  While  wind  power  is  considered  a  national 
interest  in  certain  areas,  solar  PV  does  not  receive  the  same  recognition.  Nevertheless, 
recent judgments by the Land and Environment Court of Appeal in 2022 indicate a shifting 
attitude  towards  acknowledging  the  importance  of  solar  energy  projects.  In  Italy,  the 
National Energy Strategy recognises the significance of renewable energy development for 
achieving  climate  targets,  through  the  Legislative  Decree  199/2021,  but  a  complex 
regulatory  framework  and  overlapping  responsibilities  impede  the  implementation  of  this 
principle. 

As  an  example  of  ambitious  measures,  Austria  offers  a  comprehensive  approach,  with 
renewable  energy  projects  prioritised  in  national  land-use  planning  under  Title  1  of  the 
current  Renewable  Energy  Expansion  Act  (EAG).  Additionally,  the  Renewable  Energy 
Accelerated Expansion Act (EABG) is set to be drafted in mid-2023, aiming to eliminate any 
remaining administrative barriers and further strengthening the principle of public interest 
for renewable energy projects, including both solar and wind power,  when such projects 
would not require an environmental impact assessment.  

5.3.2. Identification of suitable areas 

The  designation  of  suitable  areas  is  an  essential  aspect  of  promoting  renewable  energy 
projects,  even  if  considerations  should  be  balanced  with  land  use  and  environmental 
concerns.  The  approach  to  establishing  suitable  (and/  or  not  suitable)  areas  varies 
significantly among EU Member States. So-called go-to areas tend to be  more important 
for mature RES markets, while no-go areas are more frequently identified in countries where 
RES penetration is so far lower, especially Central and Eastern Europe.  

The issue of spatial planning is particularly important in federal states across the EU, where 
local authorities are responsible for managing land distribution and ensuring an equitable 
approach  that  balances  environmental,  social,  historical,  and  economic  considerations. 
Austria and Germany provide examples of Member States where variation occurs at the 
sub-national  level.  For  example,  in  Austria,  three  of  the  nine  regional  provinces  have 

33  Council  Regulation  (EU)  2022/2577  of  22  December  2022  laying  down  a  framework  to  accelerate  the  deployment  of 
renewable 
https://eur-lex.europa.eu/legal-
p. 
energy,  OJ 
content/EN/TXT/?uri=CELEX:32022R2577.  

29.12.2022, 

Available 

335, 

36. 

at: 

L 

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updated their legislation to enshrine the conditions for defining a particular area as suitable 
for renewable energy project developments.  

While the explicit definition of “go-to” zones has not been a primary focus in our assessment 
of  the  Member  State  monitoring  results,  several  Member  States  have  made  significant 
progress  in  reducing  the  number  and  size  of  no-go  areas.  For  instance,  Bulgaria  has 
evolved in this sense, particularly with regard to onshore wind projects within the Natura 
2000 Framework. 

France  serves  as  an  example  of  a  Member  State  that  has  developed  a  comprehensive 
strategy  for  defining  so-called  acceleration  zones 34  as  given  by  the  Renewable  Energy 
Acceleration Bill 35, which entered into force in February 2023 and transposes articles from 
RED  II.  Specifically,  the  legislation  stipulates  that  municipalities  identify  areas  based  on 
state-provided data on potential sites and after public consultation. Their proposals are then 
submitted to a “prefectural referent” established by law, which will create a departmental-
level cartography. A regional energy committee must subsequently determine whether the 
identified areas are sufficient to achieve regional renewable energy deployment objectives. 
If  so,  municipalities  may  also  define  exclusion  zones.  Within  the  perimeters  of  protected 
areas  and  major  French  sites,  municipalities  identify  these  acceleration  zones  after 
consulting the site manager. The legislation mandates that these areas must "contribute to 
achieving" the national objectives by December 2027. 

Finally,  Spain  has  also  defined  acceleration  areas  at  national  level  by  performing  an 
enviromental  impact  mapping  both  for  onshore  wind  and  solar,  and  Portugal  has  done 
preparation work in order to identify future acceleration areas as well. In identified areas, 
grid connection processes should be swifter, as developers will not be required to engage 
any preliminary environmental assessments.  

5.3.3. Positive silence for renewable energy projects 

Positive silence is a principle in administrative procedures where the absence of a response 
from  authorities  within  a  specified  time  frame  is  considered  an  approval  of  a  request  or 
application.  This  principle  can  help  expedite  permitting  processes  for  renewable  energy 
projects by reducing bureaucratic delays and providing greater certainty for developers. It 
is recommended by the Commission that Member States should introduce rules such that 
the  lack  of  a  reply  from  the  competent  authority  or  authorities,  within  the  established 
deadlines, results in the acceptance of a given request at the relevant stage of a permit-
granting procedure for renewable projects, unless their reply is required by Union or national 
legislation. 36 For EIAs, for instance, the final assessment has to be explicit. Our monitoring 
process has revealed that positive silence has been an important point of discussion for 
domestic  decision-makers  in  the  EU  Member  States  where  RES  markets  are  not  well-
established and regulated. As a result, there have been significant legislative developments 
between  April  2022  and  the  beginning  of  2023  in  Member  States  in  East  and  Central 
Europe. 

Measures  related  to  the  concept  of  positive  silence  have  been  especially  important  for 
Member States that tend to fall short of meeting EU climate and energy targets, such as 
Bulgaria. In the Bulgarian case, there is a simpler notification regime with local permitting 
authorities for self-consumption projects below 20 kW in installed capacity, per art. 147 of 
the Spatial Development Act. Similar approaches have been identified in Greece, Ireland, 
Poland,  Slovakia,  as  revealed  by  our  Member  State  monitoring  from  April  2022  to 

34 des zones d'accélération pour l'implantation d'installations terrestres de production d'énergies renouvelables 

35  LOI  n°  2023-175  du  10  mars  2023  relative  à  l'accélération  de  la  production  d'énergies  renouvelables.  URL : 
https://www.legifrance.gouv.fr/dossierlegislatif/JORFDOLE000046329719/ 

36 Recommendation C(2022) 3219 final 

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December  2022  and  subsequent  discussions  with  representatives  of  the  national 
governments. Discussions on the topic are currently ongoing in Romania. In each case, a 
set of conditions clearly stipulate which types of projects are covered, as well as which steps 
of the grid connection process are relevant for positive silence considerations. Small-scale 
PV projects are usually included. 

In contrast, the principle of positive silence is not applied in renewable energy permitting 
processes in Germany. Instead, renewable energy projects must obtain explicit approval 
from  relevant  authorities  before  proceeding.  This  is  similar  in  other  Western  European 
countries, including Italy, Spain, the Netherlands, and Portugal, which announced that it 
aims to introduce the positive silence soon. 

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6. Recommendations  and  best  practices  in  permitting 

procedures 

This section presents the best practice recommendations for permitting procedures which 
we have identified and elaborated for this report. We considered the EU 27, Iceland, Norway 
and  the  UK  for  potential  best  practice.  It  also  includes  further  recommendations  on 
improving permitting procedures based on the conducted research. 

6.1. Methodology 

This section describes the methodology that was applied to identify and further develop best 
practice in permitting procedures.  

The initial approach for the identification of good practice can be divided in three steps: 

•  Literature research, 
• 
•  Consolidation. 

Interactive stakeholder workshops, 

In the first step, literature on permitting procedures was evaluated. The goal was to identify 
existing best practice in permitting and new suggestions to speed up procedures. The basis 
for this, on the one hand, were the National Reports that were prepared as described in 
section 3.1. In these reports for each target country, different country-specific process steps 
were  evaluated  considering  barriers  and  best  practice.  Also,  literature  research  on 
suggestions  for  better  procedures  was  conducted.  The  main  source  for  this  was 
international, European, and national grey literature. Among others the following literature 
was reviewed in order to identify and further develop best-practice recommendations: 37 

•  Attendorn  (2020a):  Thorsten  Attendorn:  Klimaschutz  erfolgreich  gestalten  –  was 
und 

können;  Handlungsfelder  Windkraft,  Wasserkraft 

Behörden 
Verkehrswende, 2018. 

tun 

•  Attendorn 

(2020b):  Thorsten  Attendorn:  Aufwertung  der  Wasserkraft  bei 

wasserrechtlichen Abwägungsentscheidungen; in: Wasserwirtschaft 11/2020. 

•  Brancheninitiative  Windindustrie  (2021):  Akuter  Handlungsbedarf  für  Onshore-
Windenergie in Deutschland: „Flächen bereitstellen und Genehmigungshemmnisse 
abbauen“ Impulspapier der Brancheninitiative Windindustrie; March 2021. 

•  BDW (2021): Bundesverband Deutscher Wasserkraftwerke: Administrative Barriers 

to small hydro power development in Germany. 

•  BWE  (2021a):  BWE-Vorschläge  zur  Beschleunigung  und  Erleichterung  des 
Repowering von Windenergieanlagen; Bundesverband WindEnergie, March 2021. 

•  BWE  (2021b):  Dringende  Änderungen  im  Erneuerbare-Energien-Gesetz  2021  – 
„Reparaturgesetz“  des  EEG  2021,  Bundesverband 

Forderungen 
WindEnergie, March 2021. 

für  ein 

37 It should be noted that this list includes not only literature which has been reviewed at the initial literature review, but also 
documents  which  have  been  consulted  at  a  later  stage  with  the  aim  of  identifying  and  elaborating  best  practice 
recommendations.  

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•  BWE (2021c): Genehmigungen für Windenergie ziehen wieder an; Pressemitteilung 

des Bundesverband WindEnergie e.V., April 2021. 

•  DG ENER/Navigant (2020): Technical assistance in realisation of the 5th report on 

progress of renewable energy in the EU (Task 1-2).  

•  Deutsche WindGuard (2019), Vorbereitung und Begleitung bei der Erstellung eines 
Erfahrungsberichts gemäß §97 Erneuerbare-Energien-Gesetz, Bundesministerium 
für Wirtschaft und Energie: Berlin. 

•  FSR (2015): Regimes for granting the right to use hydropower in Europe; Glachant, 
J.-M., Saguan, M., Rious, V., Douguet, S. (Florence School of Regulation), 2015.  

•  Geoenvi  (2019b),  Proposal  For  A  Harmonized  European  Geothermal  Licensing 

Guidelines, Geoenvi: Brussels. 

• 

• 

IEW  (2018):  Freins  et  leviers  au  développement  éolien  en  Wallonie;  Fédération 
Inter-Environnement Wallonie, 2018. 

Interreg  Europe 
(2021),  Advancing  Public  Participation  and  stakeholdeR 
engagement fOr the improVement of renewable Energy policies, Interreg Europe: 
Lille. 

•  Kment, M. (2020): Sachdienliche Änderungen des Baugesetzbuchs zur Förderung 
von  Flächenausweisungen  für  Windenergieanlagen;  Rechtswissenschaftliches 
Gutachten im Auftrag der Stiftung Klimaneutralität; Augsburg 2020. 

•  Landkreis Waldshut et al. (2015): Landkreis Waldshut, Landesnaturschutzverband 
Baden-Württemberg 
Wasserkraftwerke, 
Landesfischereiverband Baden e.V.: Ablaufschema: Gestattungsverfahren für eine 
Wasserkraftanlage  –  Hinweise  für  Planer  und  Investoren  im  Landkreis  Waldshut 
(2015). 

Arbeitsgemeinschaft 

e.V., 

•  Öko-Institut et al. (2017): Study on Technical Assistance in Realisation of the 2016 
Report on Renewable Energy, in preparation of the Renewable Energy Package for 
the 
Union. 
in 
2020-2030 
https://ec.europa.eu/energy/sites/ener/files/documents/res-
study_final_report_170227.pdf. 

European 

Period 

the 

•  Regeocities  (2015):  Recommendation  guidelines 

for  a  common  European 

regulatory framework, 2015. 

•  Regeocities 
regulations. 

(2021):  Compilation  of  Recommendations  on  environmental 

•  SKN  &  Agora  (2021):  Stiftung  Klimaneutralität,  Agora  Energiewende,  Agora 
für  ein  klimaneutrales  Deutschland.  50 

Verkehrswende:  Politikinstrumente 
Empfehlungen für die 20. Legislaturperiode. 

•  SKN (2021): Wie kann die Verfügbarkeit von Flächen für die Windenergie an Land 

schnell und rechtssicher erhöht werden?, Stiftung Klimaneutralität: Berlin. 

•  SUER (2020): EE-Ausbau im öffentlichen Interesse und im Dienst der öffentlichen 
Sicherheit (§ 1 Abs. 5 EEG 2021): Rechtliche Auswirkungen; Presentation by Frank 
Sailer (Stiftung Umweltenergierecht) at „Stiftung spezial #EEG2021“, 12. November 
2020. 

•  UBA  et  al.  (2018):  Stephan  Naumann  (Umweltbundesamt),  Stephan  Heimerl 
(Fichtner  Water  &  Transportation  GmbH),  Ulf  Stein 
Institut): 
Empfehlungen  des  Forums  Fischschutz  und  Fischabstieg;  in:  Wasserwirtschaft 
6/2018. 

(Ecologic 

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Simplification of permission and administrative procedures for RES installations 

•  UTAH Energy Hub (2021), Solar Permitting Best Practice, UTAH Energy Hub: Utah. 
In addition to best practice recommendations from the literature, the research team also 
further  elaborated  suggestions  for  best  practices  based  on  stakeholder  interviews  and 
desktop research. The result of this research was a list of 156 best practice suggestions. 
The  options  in  the  list  were  at  different  degrees  fundamental  and  effective.  This  was 
considered  in  the  definition  of  a  best  practice  short  list,  which  formed  the  basis  for  the 
discussion with stakeholders in several technology-specific workshops. This list was further 
discussed  in  the  Consortium  and  options  were  chosen  that  the  team  deemed  especially 
useful to speed up permitting. 

A  first  round  of  workshops  has  resulted  in  only  limited  feedback  on  the  presented 
performance  indicators  and  best  practice  suggestions.  In  order  to  improve  the  level  and 
quality of feedback from stakeholders we opted to adapt the methodology. We redesigned 
our workshops and swapped our more informative approach to an interactive one. The goal 
of  these  new  workshops  was  to  work  jointly  with  stakeholders  on  suggestions  for  better 
permitting and shape out policy recommendations. The workshops were divided into three 
stages: 

•  Presentation of the best practice short list defined by the project team; 
•  Discussion  on  the  best  practice  short  list,  addition  of  new  best  practice  and 

evaluation of best practice suggestions; 

• 

In-depth discussion of the best practice suggestions which have been rated as high-
priority by the participating experts. 

The interactive workshops were realised through the online tool miro. This tool offers the 
possibility  to  jointly  work  on  a  digital  flipchart,  allowing  participants  to  contribute 
simultaneously in parallel to a web conference.  

Source: RES Simplify 

Figure 6-1: Screenshot of an exemplary miro board that was used during the stakeholder workshops 

The  discussions  with  the  stakeholders  covered  different  aspects  of  the  identified  best 
practice  recommendations.  These  included  the  specific  barriers  which  need  to  be 
addressed  by  best  practice  from  the  stakeholders’  point  of  view.  For  the  different 
recommendations, success factors have been discussed. Such success factors can relate 
to  external  aspects  (e.g.  specific  regulatory  or  geographical  framework),  which  are 
necessary to make the best practice recommendations applicable in a given country. This 

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should help to assess to which extent the recommendations are applicable and transferable 
for  different  countries.  Furthermore,  such  success  factors  include  internal  aspects,  i.e. 
details of how the recommended measure has to be implemented so that it can develop its 
full effect. 

In  the  end, a  set  of  best  practice  recommendations  has  been  compiled  which is  broadly 
applicable and suitable for addressing major barriers to an effective and efficient permission 
of RES installations. This set of recommendations also is considered appropriate to give 
major guidance and support for implementing the specific requirements which are stipulated 
by  arts.  15,  16  and  17  RED  II  (see  section  7:  Outline  for  the  optimised  processes  and 
supporting IT infrastructure that are compliant with RED II). 

The recommendations can be grouped in six different categories: 

•  Administrative communication and processes, 
•  Guidance and best practice, 
•  Central provision of information, 
•  Participation and acceptance measures, 
•  Eased procedures, 
•  Clarified priority for RES in administrative processes. 

An overview of the given recommendations is provided in Figure 6-2 and Figure 6-3 on the 
following pages. 

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Figure 6-2: Overview over general best practice recommendations in order to enhance permission procedures 

Figure 6-3: Overview over additional technology-specific best practice recommendations 

These recommendations, as shown in Figure 6-2 and in Figure 6-3, are further described 
in the following sections. 

6.2. Administrative communication and processes 

This section contains best practices on the communication between project developers and 
competent authorities, and general improvement of the administrative processes. 

6.2.1. Use of e-communication, including a mechanism for monitoring 

project progress 

The introduction of e-communication can substitute the use of paper forms and unifies the 
different application processes. For each application a digital version of documents can be 
prepared. Those should contain the necessary information for permitting. After submitting 
their application online, participants can follow their application process. This way applicants 
can understand in which phase of the process they are. Officials also benefit from this: they 

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can easily sort, store, and review applications. Thereby, they can get a better overview of 
all the documents that are present, access them quickly and process them. 

Another  benefit  of  digitalisation  is  the  indication of  possible barriers.  If  a  process  step  is 
slow in comparison to others, this can indicate difficulties in processing. When a barrier is 
found,  it  can  be  analysed  and  measures  can  be  taken  to  support  the  personnel  or  the 
necessary  infrastructure.  Therefore,  digitalisation  does  not  only  help  to  speed  up  the 
processes, but also is the basis for monitoring and improving. 

This  digital  communication  platform  should  also  allow  for  an  easy  application  (from  the 
developers’ point of view) in the context of simplified authorisation procedures and simple 
notification for grid connection. 

For example, in Germany, EIA documents show higher complexity than others. For officials 
it is hard to evaluate, if a species protection report that was handed in is sufficient. As their 
work  focusses  mainly  on  processing  of  documents,  officials  often  lack  the  specialised 
knowledge when it comes to species and nature protection. As this process step takes a lot 
of time this indicates the necessity of support. Possible solutions may be the introduction of 
a nature conservation council that advises officials, if necessary. Also, the legal basis for 
permitting of the EIA could be changed so that officials have a clear idea on when and when 
not to give out a permission. 

Further guidance on the implementation of an electronic platform for communication and 
appropriate IT structures can be found in section 7.4. 

Good practice examples: 

Germany: 38  In  2010,  the  State  of  Lower  Saxony  introduced  an  electronic  authorisation 
application 
(ELektronische 
immissionsschutzrechtliche Antragstellung - ELiA), which today is used by eight German 
federal states and offers an encrypted submission of application documents. 

applications 

immission 

protection 

form 

for 

Portugal:  The  new  RAU  (Reporte  Ambiental  Único)  serves as  a  single repository  for  the 
monitoring and follow up of all procedures relevant for the development of renewable energy 
projects in the country in line with the new SIMPLEX framework that is in force as of 1 March 
2023. It represents a digital One Stop Shop for permitting which even applies the principle 
of positive silence – a mechanism to certify tacit approval of permits if authorities do not 
deliver one by the deadlines set upon them in law. In detail, an applicant may download the 
relevant permit after the period has elapsed. 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (1) par. 2 (a): administrative procedures are streamlined, 
•  Art. 15 (1) par. 2 (b): simplified authorisation procedures ( also to be facilitated 

digitally), 

•  Art. 16 (2): applicants shall be allowed to submit relevant documents also in digital 

form, 

•  Art. 16 (4), 16 (5) and 16 (6): time limits for application process ( can be monitored 

digitally), 

38 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

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•  Art 16 (8), art. 17 (1) and 17 (2): simple notification for grid connection ( also to be 

facilitated digitally). 

6.2.2. One  Stop  Shop  /  consolidation  into  one  single  application 

process 

A One Stop Shop (OSS) is a single national contact point for the permission of renewable 
projects. The main benefit for project developers is that they only need to contact a single 
institution to gather all necessary permits to realise their projects. This saves time as all 
documents  are  sent  to  a  single  contact  point.  This  way  developers  do  not  need  to 
communicate with more than one official. Beneficiaries also can be international developers 
that have little to no local knowledge. 

An OSS can be designed differently. It can support applicants with the permission of their 
projects.  Officials  that  work  at  the  OSS  communicate  with  the  authorities  instead  of 
planners.  This  way  they  gather  the  permissions  of  a  project.  Applicants  do  not  need  to 
engage with more than one official. They concentrate on the preparation of all documents 
that are necessary for grid access, electricity production license or the environmental impact 
assessment. 

Another type of the OSS gives out the permission themselves. It reviews the documents 
that are presented by the project developers. Only if documents are not sufficient, they get 
into contact with other authorities. Designing an OSS this way relieves authorities, but on 
the  other  hand  has  high  demands  to  the  OSS  employees.  As  they  are  the  responsible 
authority  that  permits,  they  must  be  prepared  accordingly.  Otherwise,  this  design  of  the 
OSS could also lead to delays in permitting. 

An option to mitigate this is to create OSS on different levels. They could deal with different 
project types. A local OSS could support households and small businesses. A regional OSS 
could deal with medium sized projects by regional planners. A national OSS could support 
very  large  projects.  This  way,  the  specialisation  of  the  OSS  can  be  divided  among 
institutions. Organising OSS in this subsidiary way could fulfil different needs when it comes 
to project planning, e.g. personal contact between consumers and an authority that knows 
the regional situation. National OSS on the other hand could be highly specialised in one 
project type. 

Different  OSS  could  also  be  implemented  with  technology-specific  responsibilities,  thus 
ensuring high technology-specific competences. 

An  OSS  also  can  be  designed  as  optional.  This  way  project  applicants  can  still  directly 
contact  single  authorities.  This  can  be  important:  If  an  optional  OSS  is  working  slowly, 
applicants  still  can  skip  it.  Permitting  procedures  can  continue.  Also,  planners  still  can 
benefit from their experience and personal contacts. Project developers that work well with 
authorities can continue their style of working. This shows that there is a benefit in having 
different ways to apply for permissions. This approach is also in line with the wording of 
RED II, which stipulates that “Those contact points shall, upon request by the applicant, 
guide  through  and  facilitate  the  entire  administrative  permit  application  and  granting 
process.” 

Another understanding of OSS is that it simply acts as a guide for project developers. This 
kind of OSS simply guides the planners towards responsible authorities and helps gather 
permissions. Planners still would have to apply for permissions themselves. 

According to the requirements of RED II, the OSS should also provide online manuals of 
procedures for RES developers (see recommendations under 6.4).  

Good practice examples: 

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Norway: 39  As  energy  act  license  and  hydropower  license  are  both  often  granted  by  the 
national regulatory authority Norges vassdrags- og energidirektorat NVE (depending on the 
size and potential impacts of the installation), the processes run parallel to each other and 
the  processes  can  be  coordinated  within  the  same  authority.  In  addition,  NVE  and  the 
national grid operator Statnett are engaged in dialogue during the licensing process and the 
assessment of grid capacity for hydropower projects. Collaboration and dialogue ensure the 
potential  situation  of  granting  grid  capacity  or  a  hydropower  license  for  a  project,  and 
denying  it  of  the  other.  The  hydropower  license,  processed  and  granted  by  the  NVE  or 
processed by NVE and granted by a Royal Decree, has a wide variety of built-in features 
that  are  often  granted  as  separate  licenses  in  other  countries:  operation  permit, 
environmental permit, construction permit, and so on. The NVE serves as a national contact 
point and OSS for hydropower licensing, which has multiple benefits from the viewpoint of 
smooth permitting. The applicant can turn to NVE with all permitting-related questions and 
doubts,  and  the  same  rings  true  to  other  stakeholders  taking  interest  in  upcoming 
hydropower projects, such as NGOs willing to have their say about the ongoing processes. 
The  OSS  role  also  has  positive  effect  on  the  NVE’s  internal  functioning  as  it  is  home  to 
(almost) all the hydropower permitting expertise and experience in Norway. The NVE can 
combine  all  possible  aspects  of  permitting  into  the  same  decision-making  “table”,  which 
allows it to acquire a comprehensive picture of the potential hydropower projects, and to 
assess an assembled impact of the project at hand. Considering all possible impacts and 
features at the same time is time-consuming, but according to the interviewed NVE experts, 
it enables the institution to take “balanced and sustainable decisions”. NVE is in charge of 
most hydropower-related permits and procedures, but not all. For example, the authority for 
land  use  lies  within  municipalities.  However,  the  permitting  authorities,  such  as  NVE, 
municipalities and grid operators, are engaged in long-standing cooperation when it comes 
to combining interests and evaluating the effects and plans of potential hydropower projects. 

Germany: 40  Germany’s  current  OSS  design  for  offshore  wind  energy  offers  project 
developers a single authorisation process with the national maritime agency (Bundesamt 
für  Seeschifffahrt  und  Hydrographie  –  BSH)  as  the  competent  authority.  In  addition,  this 
process  is  preceded  by  another  simplified  step  as  site  allocation  and  public  subsidy 
selection  are  combined  into  one  single  process  at  the  national  regulatory  agency 
(Bundesnetzagentur). Comparing the complexity of these two authorisation steps with the 
procedures required for German onshore wind parks, suggests that the authorisation design 
developed for offshore wind energy reflects some measures demanded for a simplification 
of onshore authorisation processes. 

Denmark: 41 The Danish Energy Ageny (DEA) serving as an OSS for offshore procedures is 
very  efficient  according  to  an  interviewed  stakeholder.  All  the  permitting  decisions  are 
coordinated  by  DEA  with  other  authorities,  which  are  responsible  for  different  offshore 
interests. The resulting licenses are thus “comprehensive” in the sense that they are granted 
on  behalf  of  several  authorities  and  include  conditions  stipulated  by  all  these.  The 
mentioned  licences  do  not  completely  preclude  the  need  to  obtain  permits  from  other 
authorities  as  seen  above.  The  system  however  eases  the  process  for  the  developer 
greatly, and also provides more certainty that the project can be established, as all relevant 
authorities have cleared the project on the stated conditions. 

39 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Norway. 

40 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

41 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Denmark. 

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RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art.  15  (1)  par.  2  (a):  Administrative  procedures  are  expedited  at  the  appropriate 
administrative  level:    OSS  involves,  where  appropriate,  other  administrative 
authorities, 

•  Art.  15  (1)  par.  2  (b):  Rules  take  fully  into  account  the  particularities  of  individual 
renewable energy technologies:  OSS could be technology specific, thus ensuring 
high technology-specific competences,  

•  Art. 15 (1) par. 2 (d), arts. 16 (6), 16 (7), 16 (8), 17 (1), 17(2): Simplified procedures 

for specific devices, 

•  Art. 16 (1), 16 (2): Establishment of a One Stop Shop (“contact point”), 
•  Art. 16 (3): OSS shall make available also online manuals of procedures for RES 

developers and address also small-scale and self-consumer projects.  

6.2.3. Clear roles and processes 

Country analysis and stakeholder discussions have revealed that in many Member States 
responsibilities  and  processes  are  not  only  complex,  but  also  non  transparent  both  for 
authorities and for project developers. Therefore, it seems essential to define and to clearly 
describe  the  process  which  must  be  followed  in  an  application  process,  and  the 
responsibilities of the parties involved. The design of the process should take the following 
elements into account: 

•  A clear sequential description of the application process should be provided 
• 

Individual  responsibilities  of  authorities  (and  other  parties)  should  be  clearly 
assigned 

o  The establishment of a central “responsible” authority should be considered, 

or at least implemented in the form of an OSS  

o  The  number  of  involved  parties  should  be  clearly  restricted  in  order  to 

improve efficiency of the process 

•  Transparency on required documentation for each process step should be provided 
o  Repetitive requests for (further) data and documentation should be avoided 

by appropriate rules 

o  Each documentation should only be required once 
•  Clear deadlines for each step of the process should be defined 

o  Rules should be defined with respect to the effect of a deadline not being 
kept (e.g. classification as approval, start of an alternative “bypass” process, 
etc.) 

•  Depending on complexity, size and technology, the process should include a multi-
tier application approach, from initial screening to general eligibility and clarification 
of details 

•  The process should sufficiently take specific differences into account: 

o  Size of project (capacity) 
o  Technology 

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o  Type  of  project  (new  installation,  repowering,  self-consumer  installation, 

etc.). 

•  Concerns from other interests (environmental, archaeological, military or aviation) 
should be formulated at an early stage in order to avoid a late appearance of show-
stoppers 

•  The process design should include a clear framework on complaint procedure and 

deadlines for challenging a permission 

•  An appropriate IT infrastructure should be set up. 

Such a process description can be elaborated on different levels of details from national to 
local level, depending on possible differences of the processes and involved parties. Ideally, 
it should also include cooperation with stakeholder associations which are relevant in the 
given sphere of action in order to increase acceptance and reduce the risk of complaints 
throughout the process. 

Depending on the details of implementation one can expect synergies and interplay with 
the following proposed measures: 

•  Use  of  e-communication,  including  a  mechanism  for  monitoring  project  progress 

(see section 6.2.1), 

•  One  Stop  Shop  /  consolidation  into  one  single  application  process  (see  section 

6.2.2), 

•  Public provision of guidelines and documentation templates on the national level for 

authorities, project developers and stakeholders (see section 6.3.2), 

•  Cooperative monitoring mechanism for the identification and removal of regulatory 

barriers (see section 6.3.3). 

The outline of such a process should take into account the advice taken from other best-
practice recommendations, as is further elaborated in section 7. 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (1) par. 2 (a): administrative procedures are streamlined, expedited at the 

appropriate level and predictable timeframes, 

•  Art.  15  (1)  par  2  (b):  rules  are  objective,  transparent  and  proportionate,  do  not 
discriminate  between  applicants  and  take  fully  into  account  the  particularities  of 
individual renewable energy technologies, 

•  Art. 15 (1) par. 2 (d), arts. 16 (6), 16 (7), 16 (8), 17 (1), 17(2): simplified procedures 

for specific devices are implemented in the process design, 

•  Art. 16 (1), 16 (2), 16 (3): role of OSS  should be reflected by the process design, 
•  Art.  16  (4),  16  (5),  16  (6),  16  (7),  16  (8):  time-limitations  for  overall  processes                             

 should be consistently implemented, 

•  Art. 16 (5): easy access for applicants for dispute resolution, 
•  Arts.  16  (6),  16  (8),  17  (1),  17  (2):  simplified  procedures  for repowering  and  self-

consumers. 

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6.3. Guidance and best practice 

6.3.1. EU  guidance  document  on 

implementation  of  relevant 

regulation provisions in arts. 15, 16 RED and art. 8 IEMD 

This recommendation suggests that the European Commission should provide a guidance 
document for Member States on the implementation of the relevant provisions in arts. 15, 
16 RED  and art. 8 IEMD 42 (Internal Electricity Market Directive (EU) 2019/944). Guidance 
documents fulfil an important function by supporting Member States in reaching their goals. 
They do this by highlighting modes of action that can be followed and shine the spotlight on 
potential pitfalls, all the while equipping actors with useful knowledge to meet requirements. 
A RED guidance document helps Member States reach goals defined in the Directive. It 
gives recommendations linked all the requirements imposed by the Directive and describes 
factors that facilitate  their successful implementation.  

By their nature, however, recommendations are formulated in a generalistic manner to apply 
to  a  broad  number  and  type  of  cases.  European  Member  States  are  a  diverse  group  of 
countries and substantial differences between their permitting procedures and processes 
sustain. Laws and regulations differ, and responsibilities are distributed differently between 
various authorities. A precise definition of a single measure is not advisable as it may not 
be  applicable  for  every  Member  State.  Recommendations  must  therefore  be  general 
enough to be applicable in different Member States, but concrete enough so that it is clear 
how one may approach the implementation of RED  articles.  

An  example  of  a  guidance  document  is  outlined  in  section  7  of  this  report  on  optimised 
processes  and  supporting  IT  infrastructure.  It  summarises  the  findings  of  this  project’s 
research  and  links  results  to  the  relevant  articles  and  their  goals.  The  best  practice 
recommendations  described  in  this  chapter  follow  the  principle  of  being  abstract,  but 
applicable at the same time. The provided best practice examples can help Member States 
learn from cases which they can use as a blueprint for their cases. Furthermore, it should 
“Commission 
be  pointed  out 
Recommendation  on  speeding  up  permit-granting  procedures  for  renewable  energy 
projects  and  facilitating  Power  Purchase  Agreements”  (EC  2022a),  together  with  a 
Commission Staff Working Document on Guidance to Member States on good practices to 
speed  up  permit-granting  procedures  for  renewable  energy  projects  and  on  facilitating 
Power  Purchase  Agreements  (EC  2022b)  in  May  2022.  These  documents  also  address 
major  recommendations  which  are  suggested  by  this  report  with  a  view  to  the 
implementation of the relevant arts. 15, 16 and 17 of RED II.  

the  European  Commission  has  provided  a 

that 

These guidance documents can be used by Member States and further be developed by 
the European Commission, particularly in order to provide specific guidance to the revised 
RED arts. 15 and 16, once it enters into force.  

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  This recommendation refers per definition to all relevant requirements of arts. 15, 

16 and 17 of RED. 

42 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32019L0944 

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Simplification of permission and administrative procedures for RES installations 

6.3.2. Public provision of guidelines and documentation templates on 
the  national  level  for  authorities,  project  developers  and 
stakeholders 

Guidelines for stakeholders act as a helping hand when it comes to realisation of renewable 
projects.  They  inform  on  and  describe  the  process  of  RES-E  and  RES-H  permitting. 
Stakeholders can extract the necessary information and even application documents they 
use  during  project  permitting.  Guidelines  deal  with  the  specific  topic  of  RES-E  project 
permitting. They therefore have to be more specific than guidance documents on the EU 
level  and  should  facilitate  specific  renewable  energy  projects  rather  than  support  the 
establishment  of  an  appropriate  policy  framework.  As  they  focus  on  projects  in  a  single 
Member  State,  they  describe  in  detail  the  process  steps  for  planners  in  the  respective 
country. 

To ensure that a guideline unfolds its complete potential, accessibility of information must 
be  guaranteed.  A  guideline  needs  to  transfer  helpful  information  to  a  target  group. 
Therefore, information must be easily extractable. What does this mean? It is essential that 
texts are not formulated in a too complex manner. Knowledge should be displayed in an 
appealing way. Figures can also help to show information clearly arranged. 

The shape of the information should orient itself by the weakest member of the target group. 
If the document is prepared in a way that this member can access information easily, each 
other member of the group can. If this is not the case, the access to information needs to 
be  simplified.  However,  this  does  not  mean  that  guidelines  always  must  be  formulated 
extremely simple. It rather means that the target group has an impact on the way a guideline 
is  written.  Therefore,  it  can  be  useful  to  integrate  an  actor  from  the  target  group  when 
formulating  guidelines.  They  can  give  feedback  on  formulated  advice  and  on  how 
understandable the guidelines are. 

Provision of guidelines 

The formulation of guidelines is only the first step. The second step is to make the guidelines 
easily accessible. Without an easy access the quality of the guidelines itself does not matter, 
as  nobody  is  able  to  access  and  read  the  advice.  As  described  in  an  earlier  section, 
digitalisation is key when it comes to quick, easy, and transparent access to information. 
This is also true when it comes to guidance and application documents. Therefore, a digital 
central  contact  point  must  be  implemented  to  make  this  access  possible.  With  an  easy 
access to these documents planners and authorities alike can integrate advice into their 
planning and work. 

This  is  true  for  all  documents  that  can  help  to  ease  the  process  for  both  sides.  If 
documentation and application templates can be downloaded quickly via a central platform, 
there  is  no  restriction  of  use.  This  speeds  up  the  process  for  planners.  Authorities  also 
benefit from this. If templates are easily accessible, they face less requests for documents. 
They can ensure that the applications they receive are uniform and easier to process. In 
any case a digital point of contact is of help for both sides. 

See  also  section  6.2.1  (Use  of  e-communication,  including  a  mechanism  for  monitoring 
project progress), section 6.2.2 (One Stop Shop / consolidation into one single application 
process) and section 7.4 (IT infrastructure) on related best practice recommendations. 

Good practice examples: 

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Spain: 43 The Spanish Aviation Safety Ageny (Agencia Estatal de Seguridad Aérea – AESA) 
has  elaborated  guidance  material,  such  as  support  documentation  for  the  processing  of 
applications.  Four  form  templates  are  available  to  assist  users  in  the  processing  of 
authorisation applications, that can be used by wind power developers for instance. 

Some Autonomous Communities, such as Andalucía and Extremadura, published a guiding 
document  explaining  step  by  step  how  to  install  a  renewable  energy  system  for  self-
consumption. 

Italy:44 Stakeholders have described as good practice by the competent authority to provide 
project  developers  with  guidance  on  the  application  process  at  the  beginning  of  the 
authorisation procedures, as for example the ‘MUTA portal’ of the Lombardy region. 

UK: 45  The  Scottish  Government  has  published  “Good  Practice  Principles  for  Community 
Benefits  from  Onshore  Renewable  Energy  Developments”  which  provides  guidance  on 
good practice principles for communities, businesses, local authorities and others (Scottish 
Government 2019). 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (1) par 2. (b): public provision of guidelines, 
•  Art.  16  (1),  16  (2),  16  (3):  Member  States  establish  a  single  contact  point  which 
guides the applicant through the administrative permit application in a transparent 
manner, providing the applicant with all necessary information and making available 
a manual of procedures. 

6.3.3. Cooperative  monitoring  mechanism  for  the  identification  and 

removal of regulatory barriers 

A  monitoring  process  helps  with  identifying  and  removing  barriers.  In  this  approach, 
stakeholders, permitting authorities and potentially even the European Commission work 
together  to  speed  up  processes.  For  this,  authorities  set  up  a  digital  contact  point. 
Stakeholders  can  submit  their  experience  with  procedures  which  then  is  reviewed  by 
authorities.  In  a  second  step,  a  joint  approach  to  solve  these  problems  is  prepared. 
Stakeholders  and  authorities  work  together  in  analysing  problems  and  talking  about 
possible solutions. 

Step 1: Reporting barriers and slow processes 

When planners encounter a problem, they turn towards the monitoring contact point. Via an 
online formular they can submit their case 24 hours a day, 7 days a week. The information 
they submitted and the person that is responsible for their case can always be reviewed 
online. In the online formular information on the barrier they experienced can be stated. This 
can entail different topics, among other: 

•  Type of authority, 
•  Process step, 

43 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Spain. 

44 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Italy. 

45 Description taken from responses to the RES Simplify Survey. 

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•  Type of technology, 
•  Time for completing this process step. 

Step 2: Sorting information and evaluating information 

This information that is submitted by planners is sorted by authorities. This is the basis for 
them to understand if there is a systematic problem or only an irregularity in procedures. 
Not all cases need to be followed through. Otherwise, resources are bound and processes 
are  slowed  down.  But  when  should  a  barrier  be  addressed?  This  needs  to  be  clearly 
defined. For example, a certain number of complaints is reached, or the impact of the barrier 
is very severe, e.g. slows a project down immensely. 

Step 3: Investigating and working on solutions 

If a barrier has been found that needs to be addressed the third process step is initiated. 
Authorities and project developers jointly investigate and analyse the barrier. Cooperation 
can  have  different  forms  in  this  process  step.  Most  optimally  an  open  discussion  on  the 
process  and  influence  factors  is  realised.  This  can  be  a  joint  workshop  and  group 
discussions. The outcome of this should be a clear picture of what causes a barrier. Is it the 
type of information project developers submit or the legal basis that authorities apply when 
permitting? In any case this is the basis for the next process step. 

Step 4: Defining solutions and speeding up the process 

If it is clear what the factors are that cause a slow process, they can be addressed. Project 
developers  and  authorities  alike  jointly  think  about  approaches  that  can  speed  up  the 
process.  Both  perspectives  are  relevant  here.  On  the  one  hand,  state  authorities  define 
what resources are necessary for them to approve an application. This can be of different 
nature, e.g. certain information that needs to be provided, guidelines on a specific topic, or 
an increase in workforce. 

On  the  other  hand,  project  developers  state  which  information  they  can  easily  or  hardly 
provide. They can review the requirements stated by the authorities and provide information 
on these from the planner’s point of view. At this point new barriers in processes can already 
be avoided as all parties are included in this process. Too strong requirements stand out 
quickly and can be redefined and streamlined for the implementation. 

In addition to that, a structured analysis of the performance of permission procedures should 
be  enhanced  by  EU-wide  reporting  obligations  on  the  Member  States  on  efficiency  and 
effectiveness  of  RES  permissions.  For  that  purpose,  e.g.  the  NECP  template  could  be 
extended  by  the  European  Commission  in  order  to  cover,  amongst  others,  the  following 
aspects: 

• 

• 

In order to assess the effectiveness of permitting procedures: 

o  What are the project approval rates? 
o  How high is the % of projects which are legally challenged? 

In order to assess the efficiency of permitting procedures: 

o  Do deadlines exist in the overall process and for individual process steps? 
o  How long does the overall process and individual process steps take? 

Based on such information, Member States and the European Commission can regularly 
assess the performance of RES permission regulation, and consider appropriate measures 
for improvement. 

Good practice examples: 

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Germany: The German Renewable Energy Act requires the federal states to report to the 
federal government on the status of renewables. This particularly includes permitted RES 
installations, the progress of repowering, and the area of land which is available for further 
wind energy deployment according to regional and urban land-use plans. If the available 
area is not sufficient, reasons and proposals for improvement must be provided. Monitoring 
reports are assessed by a cooperation committee of the Federal Ministry of Economy and 
Energy  and  the  federal  states.  Based  on  the  committee’s  assessment,  the  Federal 
Government report on the progress of RES deployment with a view to reaching the RES 
targets  and  provides  recommendations  for  further  measures  (Tagesspiegel  Background 
2021). 

Portugal:46  In  an  attempt  to  help  government  entities  tackle  the  numerous  amount  of 
processes,  and  also  to  assist  its  own  associates  with  their  endeavours,  the  Portuguese 
Renewables  Association  APREN  (Associação  Portuguesa  de  Energias  Renováveis) 
created a task force in 2019, following a request by the State Secretariat of Energy, with 
the aim to identify the main problems in the licensing, environmental and grid connection 
steps. 

Spain: 47  The  interviewed  expert  of  UNEF  shared  the  experience  of  the  so  called  “self-
consumption roundtables” organised by Autonomous Communities, which involve different 
stakeholders such as companies, associations, distributors and the public administrations. 
In those roundtables, stakeholders share doubts and conflicts in the application of regulation 
and try to resolve them and work on initiatives to facilitate the procedures for installing self-
consumption. 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  This recommendation is not aiming at the implementation of a specific article, but 
on  identification  of  any  key  barriers  and  appropriate  measures  in  the  permission 
process, irrespective of to which aspect of permission they relate. 

6.4. Central provision of information 

6.4.1. Central 

independent 

information  platform  on  regulation, 

processes, projects, participation 

A central independent information platform on installation of new renewable energy plants 
could be an appropriate and reliable source of information for all parties involved in planning 
and permission of new plants. This could e.g. include information on the following aspects: 

• 
relevant regulation and legal framework, 
•  description of processes and requirements, 
• 
information on administrative charges, 
• 

information  on  options  for  public  participation,  including  public  information  on 
individual projects, 
•  provision of templates, 

46 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Portugal. 

47 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Spain. 

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•  overview over involved parties, 
•  possibly overview over current new projects. 

The proposed information platform could target all parties involved, including authorities, 
project developers and external stakeholders. Thus, it could ensure that everyone has the 
same references and expectations on the process. By focussing on one central platform, it 
becomes easier to keep it up-to-date rather than running into confusion on different levels 
of status. However, it might reduce complexity if there were separate platforms for different 
RES technologies. In any case, it appears appropriate to ensure that the operator of the 
platform is neutral and free from own interests, so that the provided information is in any 
case considered trustworthy also by sceptical stakeholders. 

Depending  on  how  such  an  information  platform  is  implemented,  there  may  be  strong 
synergies  and  interplay  with  the  proposed  measures  on  e-communication,  provision  of 
guidelines, implementation of a relevant GIS map and design of the one stop shop. 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (1) par 2 (b): Rules have to be transparent, 
•  Art. 15 (1) par 2 (c): Administrative charges have to be transparent and cost-related, 
•  Art. 16 (2): The single contact points shall provide the applicants with all necessary 

information, 

•  Art. 16 (3): The single contact point shall make available a manual of procedures for 

RES developers also online. 

Good practice examples: 

Portugal:  The  country  introduced  the  so-called  Reporte  Ambiental  Único  (RAU),  which 
serves as a single repository for the monitoring and follow-up of all procedures related to 
the EIA. All participating parties are able to access RAU and submit data. 

6.4.2. Online  (GIS)  database 

/  maps 

including  administrative 

restrictions and other relevant parameters 

A key element of good practice recommendations is the introduction of an online database 
which  can  be  ideally  accessed  as  GIS  maps.  These  maps  should  easily  allow  project 
developers to assess the level of restrictions given for specific areas and sites, and should 
therefore include e.g. the following features: 

• 

Information on restricted areas (nature conservation, aviation or military interests, 
settlements, archaeological sites, etc.) 

•  Differentiated assessment per RES technology 
•  Differentiated evaluation and display in traffic light coding:  

o  Green: generally suitable 
o  Yellow:  case-by-case  clarification  needed  (possibly 

specifications) 

o  Red: clearly restricted areas due to specific reasons 

including 

further 

Information on grid availability 

• 
•  Potential further information: 

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Simplification of permission and administrative procedures for RES installations 

o  Data on general RES potential (wind potential, solar radiation, geothermal 

gradient, etc.) 

Information on existing projects 

o 
o  Possibly link to available environmental assessments / studies / data for a 

given region  

o  For some technologies, also further information might be relevant  
Implementation of such a GIS map could easily allow planners to focus on promising areas. 
This would lead to higher efficiency of planning procedures and accordingly lower cost of 
RES deployment. Authorities are relieved as their applicants are better prepared, and they 
do not have to deal with requests relating to restricted areas. Project developers can also 
consider to focus activities on locations that require less documentation and permissions 
due to a generally high availability of grid capacity or to a foreseeable low environmental 
impact. 

In  order  to  make  use  of  synergies  and  take  an  interplay  of  measures  into  account,  the 
implementation of such a GIS map should be coordinated with the proposed measures on: 

•  Political  backing  of  RES:  Integrated  planning  system  from  national  to  local  (see 

section 6.7.1), 

•  Environmental  preassessment  by  authorities  /  centralisation  and  publication  of 

environmental data and assessments (see section 6.4.3), 

•  Central  independent  information  platform  on  regulation,  processes,  projects, 

participation (see section 6.4.1). 

Good practice examples: 

Denmark: 48 The online platform The Danish Environmental Portal (Danmarks Miljøportal) is 
a joint public partnership owned by the state, the municipalities and the regions. Covering 
the entire country, the portal includes area specific data on the environment, water, nature 
and land use. It enables authorities to update and access data across administrative units, 
sectors and geographical areas. However, private citizens and professionals can also use 
the portal to access data on different land use restrictions relating to e.g. nature protection, 
conservation,  building  lines  and  planning  in  specific  areas.  This  possibility  was  noted  as 
very valuable in the siting process by an interviewed stakeholder, as it gives developers full 
overview of all restrictions in different areas through the same databases that are used by 
the authorities. Thus, the only uncertainty left in this regard is possible archaeological finds. 

Spain: 49 Given the ambitious goals of the Spanish NECP, especially regarding solar PV and 
wind power, the Ministry for the Ecologic Transition and the Demographic Challenge has 
recently created a tool to help in strategic decision-making on the location of large solar and 
wind installations (not self-consumption and rooftop) because they involve significant use 
of land and can generate significant environmental impacts. The tool consists of a zoning 
of the environmental sensitivity of the territory. Hence, it identifies the areas of the national 
territory that present the greatest environmental conditioning factors for the implementation 
of renewable energy projects. The tool includes two maps showing the territory classified 
into 5 environmental sensitivity classes for each type of project analysed (maximum, very 
high, high, moderate and low).  

48 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Denmark. 

49 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Spain. 

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Besides,  the  Autonomous  Community  of  Castilla-La  Mancha  has  an  application  on  the 
website  called  INES  (Information  system  on  Sensitive  Spaces  in  Environmental  Impact 
Assessments), which allows to analyse the environmental effects of plans, programmes and 
projects.  It  groups  together  the  cartographic  information  on  protected  natural  spaces, 
sensitive areas, public forests and livestock trails. 

The layers of the INES map allow the user to view and consult: Protected Natural Spaces, 
Peripheral Protection Areas, Sites of Community Interest, Areas of Special Importance for 
Birds,  Protected  Areas  in  Process,  Fauna  Refuges,  Fishing  Refuges,  Geomorphology 
Wetlands,  Linear  Geomorphology,  among  others.  Besides,  the  Autonomous  Community 
offers two additional sources (online maps) to observe in greater detail Protected Areas and 
livestock trails and public forests. 

It should be noted that these tools do not exempt from the relevant EIA process, they are 
rather a guidance to ascertain the environmental conditioning factors associated with the 
locations of the installation from the early stage, which can be very useful. 

Portugal:50  Project  developers  can  assess  via  an  environmental  licensing  online  web 
platform  (SILIAMB),  if  an  EIA  for  a  project  is  necessary.  An  environmental  scoping  is 
submitted to the platform. After authorities have reviewed this scoping, a decision is made 
in regard to the necessity of a complete EIA. Although the main input to this process is the 
environmental  scoping  authorities  have  centralised  their  information  and  thereby  have  a 
basis for their decisions. 

USA: In the USA the NGO The Nature Conservancy combines data on space, nature and 
species  protection  to  locate  sites  that  are  suitable  for  wind  expansion.  By  combining 
different  data  the  online  GIS  database  “Site  Wind  Right” 51  was  created  that  is  openly 
accessible.  For  certain  species  information  is  shown  very  detailed,  but  also  more 
aggregated  data  is  depicted  in  the  map.  This  can  be  data  on  natural  habitats  and 
landscapes  or  cities.  For  project  planners  this  map  can  consulted  when  deciding  on  a 
possible location for their turbine. The map is not only accessible online but also can be 
downloaded in a high detail version.   

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (3): Competent authorities at national, regional and local level shall include 
provisions  for  the  integration  and  deployment  of  renewable  energy  in  spatial 
planning  and  public  works    effects  on  spatial  (dis)qualification  of  given  areas 
should be appropriately displayed/communicated. 

•  Art. 15 (7): MS shall carry out an assessment of their RES potential, including (where 
appropriate) spatial analysis of areas suitable for low-ecological-risk deployment  
results should be appropriately displayed/communicated. 

6.4.3. Environmental  preassessment  by  authorities  /  centralisation 
and publication of environmental data and assessments 

Particularly for wind and hydro, but also for other RES technologies, the elaboration and 
approval of the environmental assessments for new RES projects are related to both a high 

50 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Portugal. 

51  Accessible  via:  https://www.nature.org/en-us/what-we-do/our-priorities/tackle-climate-change/climate-change-stories/site-
wind-right/ (last accessed: 05.07.2021). 

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level of cost and effort. Furthermore, project developers must cope with the related risk of 
being rejected when starting the development process of a project.  

The efficiency of this could be increased by a central provision of available environmental 
studies and data relating to a given region and technology. A real gamechanger could be 
the  active  conduct  of  environmental  assessments  by  authorities  relating  to  the  relevant 
aspects for RES commissioning.  

As an effect, the initial work and analysis would not have to be duplicated, and stranded 
costs by investing in projects which turn out not to be licensable would be avoided from the 
project developers’ point of view. While a high level of uncertainty for any new project results 
in high requirements for risk management and diversification and therefore privileges large 
companies, a reduced risk to fail is particularly beneficial also for smaller project developers 
and  can  therefore  enhance  plurality  of  actors  and  competitiveness  also  for  RES 
cooperatives.  

It should be discussed whether the related cost should be socialised and paid for by tax-
money, or whether a mechanism should be introduced that the related cost is allocated to 
the benefitting project developers.  

Such central government-led activities have been considered to be particularly helpful by 
wind representatives. With a view to offshore wind, a specific challenge is imposed by the 
need for good coordination between governments when operating in the same sea basin.  

Good practice examples: 

Netherlands:52  Wozep  is  a  long-term  research  program  launched  in  2016  by  the  Dutch 
government of Economic Affairs and Climate. It is an offshore wind ecological programme, 
which  was  established  to  expand  the  knowledge  base  about  how  wind  farms  affect 
protected species so that it will be possible to arrive at the best possible estimate of the 
ecological impact during the preparations for new roadmaps (proposed areas for wind farms 
in the years to come). So far, the research has generated important insights into how wind 
farms affect birds, bats and marine mammals. These findings are included in determining 
future locations for offshore wind in the Netherlands. 

Norway: 53 The Norwegian Government has published information on the available potential 
large hydropower sites in their Master Plans for Hydropower Development until 2016, when 
the  tool  was  discontinued  as  it  has  largely  fulfilled  its  purpose.  The  remaining,  realistic 
hydropower  potential  is  about  34  TWh/year,  excluding  protected  rivers  and  hydropower 
projects that have been rejected in the past. The Master Plans also included “an order of 
priority for projects that can be considered for licensing”. 

that 

field  analyses 
Germany: 54  An  expert  explained 
(Flächenvoruntersuchungen) conducted after the development of the site development plan 
(Flächenentwicklungsplan) by the national marine authority BSH, the risk of an authorisation 
application  is  considerably  lowered:  Apart  from  the  wind  park’s  individual  technical 
specifications, more general suitability criteria such as environmental aspects or shipping 
safety have already been assessed by the competent authority. 

the  preliminary 

thanks 

to 

52 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on the Netherlands. 

53 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Norway. 

54 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

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RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art.  15  (1)  par.  2:  Administrative  procedures  shall  be  streamlined  and  within 
predictive  timeframes    environmental  pre-assessments  help  to  streamline  the 
application  process  and  reduces  the  risk  of  delays  related  to  environmental 
assessments. 

•  Art. 15 (7): MS shall carry out an assessment of their RES potential, including (where 
appropriate) spatial analysis of areas suitable for low-ecological-risk deployment  
preassessment  as  background 
low-ecological  risk 
the 
deployment. 

identification  of 

for 

•  Art 16. (7):  Deadlines for the permit-granting process shall be extended for other 
procedures  related  to  environmental  law    improved  environmental  data  and 
assessment reduces risk for such delays. 

6.5. Participation and acceptance 

6.5.1. Financial participation of affected municipalities 

In many cases, new RES projects face local opposition due to the fact that at least some 
parties see a high level of local negative restrictions by the project (particularly wind and 
hydro).  While  the  positive  effects  of  the  projects  both  in  terms  of  climate  protection  and 
economic benefit are not focussed on the local level. Thus, they are not adequately taken 
into account. Such opposition can result in a reduced level of support for the permission by 
local authorities, or the delay of the permission procedure by complaints or even lawsuits. 
The positive effects of the projects in terms of climate protection and economic benefit are 
so far not considered adequately at the local level. 

While  the  positive  effects  of  climate  protection  have  to  be  explained  by  communication 
measures, the economic benefit can be explicitly improved on the local level by allowing or 
even  requiring  financial  participation  of  affected  municipalities  in  the  revenues  of  RES 
plants. Such payments should be bound to purposes in order to increase social benefits of 
citizens, like social services (e.g. kindergarten, health services) or infrastructure (e.g. streets 
or public transportation).  

In technical terms, financial participation could be organised in different forms, e.g.: 

•  National or regional level gives funding to the local authorities for the provision of 
areas and resources, as the RES deployment contributes to reaching the national 
RES targets. 

•  Plant operators directly pay a specific fee or tax to the local authorities, which might 

depend on the produced RES volume. 

•  Plant  operators  voluntarily  make  payments  to  a  regional  association  with  the 

purpose to improve the local situation 

The  cost  of such  additional  payments  should  be  covered  by  public  funding,  as  emission 
reduction is a societal challenge. For this purpose, such funding (if being paid by the plant 
operator)  should  be  appropriately  considered  in  public  support  systems.  Furthermore,  it 
should be clear that such payments to local authorities in no way can be understood as 
corruption, but that it has a clear regulatory framework. 

Another  possibility  for  enhanced  local  economic  participation  are  options  for  investing  in 
shares of the RES projects (RES cooperations, renewable energy communities and others). 

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This voluntary alternative can probably further motivate ecological front runners at least for 
projects where this possibility is given. However, the outlined approach is considered to be 
more  effective  in  order  to  address also  the  more  opposing  parties  (who  otherwise  might 
actively complain or sue), and include those who might not have the resources to actively 
buy in such projects. 

Good practice examples: 

Denmark: 55 Four schemes are currently in place to enhance project acceptance: The so-
called  “RE-bonus  scheme”,  which  obligates  the  developer  to  pay  neighbours  an  annual 
bonus  corresponding  to  a  specified  part  of  the  capacity  of  the  plant;  the  “loss  of  value 
scheme”,  which  requires  the  developer  to  compensate  any  loss  of  value  to  residential 
property equal to or higher than 1% of the property value; the “option-to-sell scheme”, which 
allows some neighbours within a distance of six times the height of a wind turbine or 200 m 
from a ground-mounted solar PV plant to sell their property to the project developer; and 
finally the “green fund scheme”, which obligates the developer to pay EUR 11,827 (DKK 
88,000) per MW onshore wind equivalents to the relevant municipality, which can use the 
funds to support e.g. local green initiatives. 

Germany: 56 In order to increase the public acceptance for wind parks, an amendment to the 
Renewable Energy Act (EEG, 2020) was taken in the 2020, allowing plant operators to pay 
municipalities up to EUR 25,000 annually for each wind turbine in their community. 

With a further revision of the EEG  2021, the option to agree payments with the affected 
municipality has been extended also for large PV. This allows a payment of up to 0.2 ct/kWh 
for the municipality, which could equal EUR 2,000 per hectare and year. In order to enhance 
a  legally  sound  agreement  between  the  RES  producer  and  the  municipality,  a  sample 
contract for wind has been developed in cooperation with wind industry representatives and 
municipal associations (Remmers, 2021; Solarthemen, 2021). 

The feredal state of Brandenburg passed the „Gesetz zur Zahlung einer Sonderabgabe an 
Gemeinden im Umfeld von Windenergieanlagen” (Act on the payment of a special levy to 
municipalities in the vicinity of wind energy plants).57 This law forces power plant operators 
to  pay  EUR  10,000  annually  to  neighbouring  municipalities.  This  applies  for  each  wind 
turbine  that  is  operated.  If  different  municipalities  qualify  for  this,  the  payment  is  split  up 
depending on how strong they are affected. Municipalities need to use these payments for 
measures  that  increase  the  acceptance  of  wind  energy.  This  particularly  might  include 
measures  to  upgrade  the  townscape  and  local  infrastructure,  measures  to  provide 
information on the benefits of renewable energy production, the promotion of community 
events,  social  activities  or  cultural,  educational  or  recreational  facilities,  or  measures  on 
communal urban land-use planning in the field of renewable energies. It is required that the 
residents should be able to recognise a link to the funds generated from the production of 
wind energy.  

Luxembourg: 58 Luxembourg's 102 municipalities have all signed the Climate Pact, signalling 
an  intention  to  move  forward  with  the  energy  transition.  In  addition,  the  State  strongly 
encourages municipalities to disclose land that can be used for energy purposes in order to 

55 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Denmark. 

56 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

57  Gesetz 
(Windenergieanlagenabgabengesetz 
https://bravors.brandenburg.de/gesetze/bbgwindabgg 

zur  Zahlung 

einer  Sonderabgabe 

-  BbgWindAbgG),  vom  19.  June  2019, 

an  Gemeinden 

im  Umfeld 

von  Windenergieanlagen 
[Nr.  30]) ;  URL : 

(GVBl.I/19, 

58 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Luxembourg. 

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increase the number of projects. In this respect, municipalities that promote several energy 
projects  on  their  territory  receive  state  subsidies  for  their  support  to  project  developers. 
These subsidies can subsequently be reallocated to other local purposes. 

Norway: 59  Norwegian  hydropower  permits  always  have  in-built  benefit-sharing  and 
compensation  mechanisms.  These  mechanisms  have  a  long  tradition  on  Norwegian 
hydropower permitting, and they have substantial impacts on communities’ willingness to 
allow hydropower in their lands. Firstly, municipalities have come to view hydropower as a 
stable source of income due to the annual license fees and the “compulsory power” that 
they  can  either  consume  or  sell  on  an  open  market  for  profit.  Secondly,  hydropower 
producers  are  often  obliged  to  make  reparations  to  the  affected  ecosystems  and 
recreational  activities,  such  as  fishing.  The  reparations  can  take  the  form  of  an 
environmental develop fund, for example. It is important to note that some of these benefit-
sharing mechanisms are only relevant to large hydropower plants; small-scale hydropower 
projects are usually initiated by the local community and therefore, they benefit the locals 
by default.  

Netherlands:60 The Regional Energy Strategies prescribe a participation grade of 50% with 
the  locals  for  renewable  energy  projects.  The  project  developer,  together  with  the 
environment  and  the  competent  authority,  draws  up  a  participation  plan  for  each  wind 
project. Also for ground-mounted PV, similar participation plans are drawn up. These plans 
describe which stakeholders there are and what their questions, concerns and wishes are, 
how and when they will be involved in the project and how they can participate. 

There are many different forms of project participation. Local residents can take part in the 
profit  of  a  renewable  energy  projects  through  certificates  (shares)  in  the  wind  project. 
Participation  can  also  be  done  by  investing  in  bonds;  a  financial  participation  with  risk. 
Through investment, participation is possible both before and after the construction of the 
wind farm or the solar park. 

Ireland: 61  The  draft  Wind  Energy  Development  Guidelines  foresee  certain  project 
acceptance  measures.  These  provisions  have  been  included  in  the  Irish  Renewable 
Electricity  Support  Scheme.  Firstly,  project  developers  are  obliged  to  engage  in 
consultations with the local community, before applying for planning permission. Secondly, 
a community report should be prepared and should set out how the project development 
will  affect  the  local  community  and  how  local  community  participation  will  be  assured 
throughout  the  whole  lifetime  of  the  project.  Thirdly,  a  “Community  Benefit  Fund”  is 
established. The Fund will be supported from renewable electricity produced by installations 
under  the  national  support  scheme  (auctions)  (EUR  2/MWh).  Fourthly,  Community 
Ownership is promoted. This is achieved by creating a separate group of projects (the so-
called  “community-led”  projects)  that  participate  in  the  auctions  on  the  national  support 
scheme. It should be noted that these are fairly new and ambitious measures and it remains 
to be seen if they are effective. 

59 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Norway. 

60 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on the Netherlands. 

61 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Ireland. 

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6.5.2. Early  engagement  in  local  information,  dissemination,  and 

discussion 

Citizens  and  other  stakeholders’  acceptance  of  projects  plays  a  vital  role  in  renewable 
expansion. Through  the  right  participatory  approach,  the  acceptability of  projects can  be 
increased. However, information and participation need to follow certain principles. 

Information on the importance of renewable energy 

On a regional level, the understanding for the importance of renewable energies is often 
not present. For example, not all citizens understand the direct connection of a single wind 
power  plant  and  the  fight  against  climate  change.  Without  this  knowledge  the  striking 
question  of  “Why  have  renewable  energies  to  be  realised  in  my  region?”  remains  not 
answered. However, this understanding is a basis for acceptance. Therefore, the first step 
in  a  participatory  process  is  providing  information.  This  can  entail  the  handing  out  of 
information  material  or  a  discussion  between  experts  and  citizens.  In  any  case  open 
questions must be answered. 

Best  case  scenario  is  that  citizens  themselves  engage  in  project  development.  These 
projects show the highest acceptability due to local participation and the goal to benefit the 
region. In comparison to projects realised through external planners they keep the majority 
of financial benefits in the project region. 

Early, open-ended engagement 

Participation  should  start  before  projects  are  planned  in  a  region.  At  this  point  regional 
actors can jointly discuss and plan the development of the region and the role renewable 
energies will play. Stakeholders can express their views on the way space is used, which 
can be considered when spatial planning is taking place. This early participation is important 
as at this point citizens can still influence siting of renewable planning. This process is still 
very open, and its outcome is not clearly defined. Therefore, its credibility is guaranteed. 
Project planners play a minor role during this participatory step. 

Without this early participation the basis for a successful process is not there. If citizens are 
consulted during the project phase for the first time, they may assume that projects still can 
be influenced. However, areas for renewable plants are planned before projects. This may 
disappoint  citizens  and  create  the  feeling  they  are  not  taken  seriously.  They  may  ask 
themselves:  Why  are  we  participating,  if  the  project  hardly  can  be  influenced.  Still,  it  is 
important  that  planners  engage  with  citizens.  However,  the  main  goal  of  this  interaction 
should not be the siting of the power plant in the region. 

Participation during project planning 

Although the general area of a project cannot be influenced during project planning, an early 
engagement during this phase is also important. As a first step, planners should realize an 
actor  and  context  analysis  to  understand  the  surrounding  of  the  project  they  planned. 
Citizens  should  be  part  of  an  extended  project  team.  This  way  the  regional  and  social 
characteristics can be implemented in the planning process. This can entail information on 
sites that are especially suited or groups of citizens that might want to support the project 
financially. This information is left out, if planners do not enter into dialogue with citizens. 

Good practice examples: 

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France: 62  Even  if  there  is  no  obligation  to  consider  the  opinions  of  local  communities 
upstream of an onshore wind project, a wind energy company has set up an ethical charter. 
This  charter  stipulates  for  a  greater  consideration  of  the  local  community  in  order  to 
encourage  a  transparent  and  broad  communication  so  that  the  population  can  better 
understand the general framework of the development of a given project. Thanks to this 
informal impulse, parliamentary discussions should take place to provide for a legal basis 
to a public consultation in the pre-planning stage. 

Ireland: 63 Despite the fact that community engagement is not mandatory for onshore wind 
projects,  the  Wind  Energy  Ireland  (WEA),  former  Irish  Wind  Energy  Association  (IWEA), 
recommends its member to engage in  local information and dissemination activities at a 
very early stage of project development. Project developers organise venues and inform 
local  residents  door-to-door  on  the  prospective  realisation  of  an  onshore  wind  energy 
project. In this way, issues can be resolved at a very early stage and the possibility of an 
appeal later in the planning permission process can be avoided. It should also be noted that 
this approach is slowly followed in the deployment of offshore wind projects. Although the 
legislative  framework  is  not  yet  in  place,  project  developers  have  initiated  information 
campaigns for local marine communities. Main aim is to inform the local residents on the 
offshore  wind  project  and  answer  questions  on  the  possible  effects  on  marine  flora  and 
fauna. The very early engagement for offshore wind projects is based on the experience 
the members of Wind Energy Ireland have accumulated throughout the last twenty years in 
onshore wind deployment. The main lesson learnt was that without early engagement, a 
wind project could not succeed. 

Netherlands:64  Site  selection  for  offshore  wind  energy  in  the  Netherlands  takes  place 
through an extensive participative process. This participative process is a process which 
takes years in total to finish and takes into account the opinions of all stakeholders. 

The industry organisation HollandSolar, together with the relevant stakeholders, has drawn 
up, a Code of Conduct for ground-mounted PV installations. The PV sector is bound by the 
agreements  contained  in  this  Code.  Moreover,  the  Code  of  Conduct  was  signed  by  the 
nature  conservation  organisations,  which  leads  to  good  understanding  between  the 
developers of ground-mounted PV projects and potential opponents. The Code is mainly 
about a good management and good practice, but also foresees complaint procedures if 
the  rules  are  not  followed  and  has  its  own  assessment  committee  consisting  of 
representatives of sector organisations and nature conservation organisations. This helps 
to reduce resistance and thus results in significantly fewer complaint procedures against 
ground-mounted PV. 

Portugal:65  In  Portugal  it  is  possible  for  every  stakeholder  to  participate  via  a  website: 
PARTICIPA. 66 This portal acts as a digital forum in which NGOs, civil society, associations 
and  virtually  anyone  can  participate  and  issue  opinions  about  projects  placed  for  public 
consultation in the country. 

62 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on France. 

63 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Ireland. 

64 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on the Netherlands. 

65 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Portugal. 

66 https://participa.pt/ 

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UK: 67 Project developers propose a public consultation plan for their projects to the council, 
and the council approves or supplies recommendations. Typical plans include the following 
features:   

•  Public  Exhibitions  where  locals  see  the  details  of  the  emerging  project,  provide 
feedback and ask the project team any questions. This may take place in different 
localities around the site.   

•  Provision of a website and a point of contact.   
•  List of locations where hard copies of project materials will be displayed.   
•  Creation  of  a  forum  to  keep  local  community  councils  and  business  and  political 

stakeholders updated on the project progression.   

•  Creation  of  a  Community  Liaison  Forum  with  local  community  group  leaders  to 

discuss the project and the community benefit fund.  

•  Offering shared ownership on the project.  

Stakeholders  are  also  engaged  if  there  is  a  material  change  in  the  project  while  it  is  in 
planning. Locals can make representations to the council on the planning application for 
about a month after the information is submitted.  

A pre-application consultation report is submitted to the council with major applications that 
details  stakeholder  consultation  that  took  place  prior  to  the  planning  applications,  the 
feedback received and how that feedback was considered in the project. 

6.5.3. Project  independent  moderator  for  stakeholder  participation 

and problem resolution 

A project-independent moderator acts as a communication facilitator between stakeholders. 
This is important when planning the process of RES-E project realisation and in the event 
of  disputes between  project  developers  and  stakeholders. They  act  as  a  communication 
facilitator and thereby mediate between the different parties. With their support, planners 
and stakeholders such as citizens or environmental organisations can more easily come to 
a joint solution and accepted project realisation. 

Moderation between citizens and planners 

The  expansion  of  renewable  power  plants  often  leads  to  concerns  of  citizens.  The most 
prominent ones are onshore wind projects. Often concerns regarding health or the visual 
impact of power plants arise. Also, citizens may distrust project developers as their interests 
are clearly economically driven. Therefore, they may have the feeling that their concerns 
are not taken seriously when communicating with them. Project developers, on the other 
hand, are very familiar with their technologies. They know their ins and outs and may not 
be able to relate to the citizens point of view. 

A moderator can help by facilitating communication between these parties and facilitate the 
realisation of projects. Optimally their work starts early. After a project developer has chosen 
a  region  for  a  project,  they  should  approach  the  regional  community  with  the  help  of  a 
moderator. This early communication is key to prevent conflicts at a later project stage. A 
moderator  listens  and  explains  the  different  points  of  view.  They  guide  the  discussion 
between the parties and avoid disputes. The goal is to come to a project that all parties can 
accept.  

67 Description taken from responses to the RES Simplify Survey. 

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An external moderator is especially important when disputes arise. The opposition of the 
parties may be too strong to resolve the conflict on their own. Here, an external moderator 
can  be  of  great  help.  They  listen,  explain  and  enable  communication  where  it  was  not 
possible before. As disputes can arise during project planning, but also during realisation, 
moderators are needed until the plant is built and commissioned. 

Neutrality 

An  important  aspect  of  moderation  is  the  moderator’s  neutrality.  Moderation  between 
stakeholders is only possible if the moderator can blank out his personal views. This way 
the communication is not influenced and distorted. Also, stakeholders do not get the feeling 
of an unjust influence of the moderator on the project outcome. 

Regional Origins 

Second important aspect, a moderator should be well known among the stakeholders of the 
project. Especially for citizens a person with local knowledge is important. They can be sure 
that  this  person  is  familiar  with  the  situation.  Also,  they  can  relate  to  their  concerns  and 
interests. For example, there is no need to describe the importance of a local natural habitat 
to the community or a potential negative visual impact can be easily understood. In the case 
of external moderators, there may be insufficient trust in the moderator and therefore the 
citizens might be reluctant to explain certain matters to the external person.  

Moderating between planners 

Moderation  can  not  only  be  important  between  citizens  and  project  developers,  but  also 
between developers themselves. Conflicts may arise if two parties plan a similar project for 
a region. They may have already invested resources in the project and want to go forward. 
To minimize the losses of all parties, a moderator can help to find an outcome. E.g. they 
can find a new location for a project or developers may realise a project jointly. This can 
also come to a more efficient use of regional resources. The moderator in this case does 
not need to be a single person. Rather a process led by the authorities themselves can help 
to find a solution to this problem. 

Moderation between planners and interest groups 

Conflicts  may  also  arise  between  planners  and  organisations.  This  can  be  nature 
conservation  organisations  that  want  to  avoid  a  negative  impact  on  species  and 
ecosystems. Here, an independent moderator can also help to mitigate conflicts. This can 
be  a  single  person,  but  also  a  committee  of  experts  from  both  sides.  Ultimately,  this 
committee fulfils the same functions as a moderator between citizens and planners. 

Moderation between planners and authorities 

A clear conflict resolution mechanism should also be implemented for project developers in 
order to settle disputes between project developers and authorities and grid operators. This 
should help solving disputes in an efficient manner before an ordinary (civil) court. 

Good practice examples: 

Austria:68 One of the tasks of the Austrian Energy Regulator (Energy Control Austria) is to 
act as an arbitration board in case of grid access denials and other grid connection related 
disputes (§12 (1) E-Control Act 2011). Within the framework of the grid connection approval 

68 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Austria. 

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procedure, applicants also have the option of contacting the PV-Austria working group on 
grids in the event of complaints. 

Austria:69  The  Austrian  Energy  Regulator  (Energy  Control  Austria)  acts  as  an  arbitration 
board in case of grid access denials and other grid connection related disputes. Within the 
framework of the grid connection approval procedure, applicants also have the option of 
contacting the PV-Austria working group on grids in the event of complaints. Stakeholders 
tend to consider the complaint procedure to be effective provided that all those involved act 
in good faith.  

Germany: 70 Since 2007, the Federal Ministry for Environment runs a clearing authority for 
the resolution of conflicts concerning the deployment of renewable energy sources in the 
context  of  the  Renewable  Energy Sources  Act.  Its service  is  free  of  charge  and  it  offers 
information on ongoing and past disputes. 

Netherlands:71 The sector organisation HollandSolar has drawn up in correspondence with 
all  stakeholders  a  Code  of  Conduct  for  ground-mounted  PV  installations.  The  sector  is 
bound by the agreements included in the Code of Conduct. The code of conduct was also 
co-signed  by  nature  organisations,  which  results  into  a  situation  of  good  understanding 
between  project  developers  of  ground-mounted  PV  and  opposing  parties.  The  Code  of 
Conduct mainly works around good management and good practice. The Code of Conducts 
even  foresees  complaint  procedures  if  the  rules  are  not  followed  and  has  its  own 
assessment committee with the sector organisations together with nature organisations. In 
general, everyone always agrees with the decisions made by the committee. This results 
into much less resistance and thus much less appeal procedures against ground-mounted 
PV. 

Poland: 72 In Poland, there is a Coordinator for negotiations to the President of the Polish 
Energy Regulatory Office (ERO), which is responsible for conducting out-of-court dispute 
settlement procedures between the renewable energy prosumers and energy companies 
(e.g. grid operator in the area where the micro-installation is located). 

Among other things, the Coordinator deals with the questions related to the grid connection 
of micro-installations and provision of electricity transmission or distribution services. The 
key role of the Coordinator is to help the parties to resolve the dispute. His key tasks are 
therefore to bring the parties' positions closer together and to propose a solution to them. 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 16 (5): Easy access for applicants to simple procedures for the settlement of 
disputes including, where applicable, alternative dispute resolution mechanisms. 

•  Art. 16 (7):  Deadlines for the permit-granting process shall be extended for other 
procedures  related  to  environmental  law  judicial  appeals,  remedies  or  other 
proceedings  before  a  court  or  tribunal,  and  to  alternative  dispute  resolution 
mechanisms    improved  provisions  for  conflict  resolution  reduces  risk  of  such 
delays. 

69 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Austria. 

70 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

71 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on the Netherlands. 

72 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Poland. 

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6.6. Eased procedures 

6.6.1. Eased procedures for the repowering of existing power plants 

After power plants reach the end of their lifetime, different scenarios may follow. They may 
stop  their  operation,  or  they  are  repowered  to  match  today’s  technological  standards. 
Repowering is especially attractive when operators receive a subsidy. Also, it can contribute 
to renewable expansion goals as retrofitted power plants show higher capacities. Sites are 
well known, accepted and infrastructure is already present. 

Easier  permitting  procedures  for  repowering  can  help  to  capitalise  on  all  these  positive 
effects. Old plants already have run through different procedures and assessments. These 
have shown that the power plant can be realised at the corresponding site. New permissions 
and assessment therefore should only comprise possible new impacts. For example, if a 
retrofitted wind power plant has a considerably larger height, a new assessment considering 
its impact on the avifauna or shadow casting could be necessary. An assessment on its 
impact on bats is not necessary as for the old plant has been shown that no bats live in the 
area. Also for an environmental assessment (e.g. with a view to the protection of species), 
the responsible authorities must take prior restrictions of the old installation into account as 
a baseline. This way it is ensured that the assessment of the power plant still suffice the 
demands of the permitting procedure. At the same time, additional expenses and time loss 
for planners are reduced to the extent possible. 

With respect to repowering of hydropower plants, it is proposed that renovations should be 
possible within certain capacity limits without further permits, at least if the environmentally 
relevant hydrological parameters do not change (like minimum flow or hydro-peaking). The 
expected ecological relevance and the applicability of this simplification could be subject to 
an assessment by local authorities (or at least authorities which are well familiar with the 
local  conditions).  This  assessment  could  be  conducted  e.g.,  in  the  context  of  a  formal 
hearing. Furthermore, compensation measures for negative effects on landscape have to 
take  into  account  compensation  measures  which  already  have  been  provided  for  the 
previous installation. 

Good practice examples: 

France:  The  administrative  requirements  to  refurbish  hydropower  plants  is  eased.  If  an 
operator does not increase the capacity of a power plant when refurbishing it, an EIA is not 
required. Also, if the capacity increase remains below 20% without any substantial effects 
on the environment, no permission is needed. The initial assessment of the expected effects 
is based on the judgement of local authorities. 

Germany: In June 2021, the Federal Parliament has passed legislation that for permitting 
procedures  for  repowering  of  wind  only  changes  compared  to  the  status  quo  should  be 
assessed rather than the effects of an assumed green-field installation, as was the case so 
far. Also, for an environmental assessment e.g. with a view to the protection of species the 
responsible  authorities  must  take  prior  restrictions  of  the  old  installation  into  account  as 
baseline. Thus, if a repowering project leads to improvements compared to the status quo 
this has to be acknowledged. Furthermore, compensation measures for negative effects on 
landscape  have  to  take  into  account  compensation  measures  which  already  have  been 
provided for the previous installation. Besides this, the new legislation only requires a public 
hearing in case the project developer requests this (Solarthemen, 2021). However, it should 
be stated that such activities for stakeholder involvement are considered beneficial in order 
to increase public acceptance. 

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Portugal:73 The publication of Decree Law 76/2019 represented a significant legislative step 
towards enabling RES to play a bigger role in the country’s energy mix. Specifically, the 
changes made in the electricity production licensing regime with the intent to enable the 
existence of hybrid plants (art. 4, par. 3 “[…] installation of new units in an already existing 
power plant that uses a different power source”) are to be commended, as hybridisation 
(especially  for  the  wind  sector)  is  one  of  the  main  strategies  for  increasing  electricity 
production from RES in the country. 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 16 (6): Simplified and swift permit-granting process for repowering. 
•  Art. 16 (8): Option to establish a simple-notification procedure for grid connections 

for repowering projects. 

6.6.2. Eased procedures for RES self-supply and small-scale RES 

Easing and simplifying procedures for projects is a simple approach to speed up permitting. 
It  helps  project  developers  and  authorities  alike  and  increases  the  speed  projects  are 
realised with. By simply reducing the number of necessary permits for projects, they need 
to prepare less documents. Authorities, on the other hand, receive less applications and 
therefore can use their resources to permit large and important projects. 

The  questions  arise:  In  what  cases  are  simplified  procedures  applicable?  What  does  it 
entail?  Clearly  this  should  not  apply  to  every  project.  Large  procedures  that  thoroughly 
assess  a  project  can  be  necessary.  Especially  for  large  scale  project  that  have  a 
considerable impact on nature and citizens, this is necessary. The impacts of small-scale 
projects on the other hand are often negligible. They often consist of few plants and have 
low capacities. 

Also, similar things can be said about self-consumption projects. They are realised on the 
project developer’s own ground and their impact can be compared to the one of small-scale 
projects.  Easier  procedures  for  self-consumption  projects  can  help  to  nudge  citizens  to 
investing themselves. With lower transaction costs for the realisation of the project barriers 
are smaller and potentially more investments may follow. 

Also, the number of necessary assessments can be reduced. If only low impacts may follow 
from a project, it becomes obsolete to conduct assessments. This way planners can save 
time. 

Among  the  EU  Member  States  different  versions  of  easy  permitting  exist.  Those  are 
described in the following. 

Good practice examples: 

Austria: 74 In Upper Austria there is an exemption from the electricity generation licence for 
small hydropower plants with a capacity of up to 400 kW. This is seen as a simplification of 
the procedure. 

The Building Code in the province of Carinthia was mentioned as a positive example. The 
Code  is  currently  being  revised  and  will  stipulate  that  all  PV  systems  installed  on  a  roof 

73 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Portugal. 

74 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Austria. 

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should  be  completely  notification-free.  This  would  mean  significantly  less  effort  for  the 
planning of these systems (PV stakeholder, 2020). 

Czechia: Procedures are simplified for rooftop PV projects with a capacity of up to 50 kWp. 
For these projects no building permit is needed. Previously this limit was set at 20 kWp. The 
basis for this is the amendment of the State Energy Policy from 2015. 

Lithuania: 75 The stakeholders surveyed perceive the simplified grid connection procedure 
for renewable power systems with the capacity of less than 30 kW as good practice. The 
grid connection of these small-scale systems does not require many documents and the 
connection is organised quickly. Moreover, all documents and the grid connection status 
can be viewed online when logged on the operator’s website. 

Norway: 76 For hydropower installations that fulfil the criteria for the sales license, the license 
is  usually  approved  automatically  and  rather  quickly.  Even  if  the  license  is  manually 
processed by an NVE officer, the licensing time is usually limited to 2–4 weeks. The Altinn 
online application system is connected to the Brønnøysund company registry, and retrieves 
company information from there.   

Portugal:77  A  new  legislation  aims  at  simplifying  the  licensing  rules  and  regulatory 
procedures  applied  to  production  units  for  self-consumption  (unidade  de  produção  para 
autoconsumo – UPAC). For certain facilities (depending on the installed capacity), a mere 
notification to the Directorate-General of Energy and Geology is required in order to start 
operating the unit (for others not even that is required), which is a positive reinforcement for 
small  and  medium-sized  photovoltaic  producers  as  well  as  owners  of  small/mini  wind 
turbines. 

Small power plants with a capacity of up to 1 MW can apply for a fast application via a web 
page to gain the grid connection permit. 

Portugal:78 For certain small-medium sized power plants, it is only necessary to notify the 
(Portuguese)  Directorate-General  of  Energy  and  Geology  (DGEG)  of  their  intention  to 
connect  the  unit  to  the grid  –  and, for  specific cases,  not even  a  notification is  required. 
Such instrument provides agility to photovoltaic projects that fit in the criteria, reducing costs 
and optimising time efficiency of projects. 

Romania: 79 For years, there were no prosumers in the Romanian electricity market due to 
a  legal  gap:  it  was  not  clear  if  the  prosumers  should  be  treated  like  other  electricity 
producers  and  therefore  be  required  to  obtain  an  official  classification  according  to  the 
Statistical Classification of Economic Activities in the European Community (Nomenclature 
statistique  des  activités  économiques  dans  la  Communauté  européenne  -  NACE  code 
D35). In 2018, Law 220/2008 was amended and the amendments now allow commercial 
prosumers up to 100 MW/ location to operate without a NACE code. This facilitates a much 
faster interaction with the local authorities before the certification and authorisation stages. 

75 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Lithuania. 

76 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Norway. 

77 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

78 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Portugal. 

79 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Romania. 

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Slovenia: 80  Slovenia  has  implemented  the  RES-E  Self-supply  Decree  (2019),  with  which 
individual self-supply, self-supply in buildings with several apartments and communities that 
jointly install facilities for the production of energy from renewable sources are promoted. 
The decree was adopted and changed to remove administrative barriers in the formation of 
community self-sufficiency and to simplify the process of connecting devices to the power 
grid, e.g. by lifting the capacity limit of community devices. So far, the implementation of the 
new  regulation  has  worked  well  and  brought  a  significant  acceleration  of  administrative 
procedures. 

Spain:81 The Autonomous Community of Andalucía does not request a building permit for 
self-consumption units with power up to 10 kW.  

UNEF  and  SolarPower  Europe  conducted  a  study  and  reported  that  in  many  European 
countries (as Germany, the Netherlands, Italy, Sweden, among others) self-consumption 
units only require a prior notification to the municipality. Others, however, require a building 
permit, which can delay the process up to 8 months. 

Sweden:  In  Sweden,  the  licensing  procedure  for  a  small  geothermal  heat  pump  is 
determined by the local municipality. In some municipalities, no permit is necessary and a 
simple  notification  to  the  Geological  Survey  of  Sweden  suffices.  In  the  most  densely 
populated areas, such as Stockholm, a permit is needed, and processing the application 
takes a couple of months. According to EGEC, the permitting process duration for shallow 
geothermal should not exceed 2 months (EGEC, 2021a). 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (1) par. 2 (b): Rules shall be objective, transparent and proportionate and do 

not discriminate between applicants. 

•  Art.  15  (1)  par.  2  (d):  Simplified  and  less  burdensome  authorisation  procedures, 
including  a  simple-notification  procedure,  for  decentralised  devices,  and  for 
producing and storing energy from renewable sources. 

•  Art. 16 (3): The contact point shall address also small-scale and self-consumption 

projects. 

•  Art. 16 (5): Permit-granting process shall not exceed one year for RES-E installation 

<150 kW (in extraordinary circumstances: two years). 

•  Art. 17 (1): Simple-notification procedure for grid connections for self-consumers of 

renewables and demonstration projects (<10.8 kW). 

•  Art. 17 (2): Simple-notification procedure for grid connections for installations with 
10.8 kW up to 50 kW, provided that grid stability, grid reliability and grid safety are 
maintained. 

6.7. Clarified priority for RES in administrative processes 

80 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Slovenia. 

81 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Spain. 

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6.7.1. Political  backing  of  RES:  Integrated  planning  system  from 

national to local level 

The need for regional and local action for RES deployment can be opposed by actors who 
have a focussed view on local restrictions, thus following a NIMBY (“not in my backyard”) 
strategy. Understanding of the need for a local contribution and the motivation of regional 
and local authorities and other actors can be enhanced by a general area planning strategy, 
which includes a consistent breakdown of national targets on the regional and local level. 
Specific measures should be implemented to legally ensure the availability of sufficient land 
area for a target-compliant RES development (e.g. x% of national area for wind power). At 
the same time, some flexibility on specific sites still remains in the hands of local actors. 

Good practice examples: 

France: The National Assembly and Senate adopted the Renewable Energy Acceleration 
Bill to boost the deployment of renewable energy sources in February 2023. 82 Among other 
major  legislative  changes,  the  law  empowers  local  authorities  to  propose  so-called 
acceleration zones 83. In line with the law, these zones shall have the potential to accelerate 
the production of renewables, contribute to the solidarity of supply between territories, pose 
no risk of water nor land pollution, should consider the need to diversify renewables, and 
should not be placed in national parks and natural reserves. Implementation of such zones 
is dependent on the coming decree, which is expected to be adopted in 2023 or in 2024 
only. 

Germany: The German Renewable Energy Act requires the federal states to report to the 
federal government on the status of renewables. This particularly includes permitted RES 
installations, the progress of repowering, and the area of land which is available for further 
wind energy deployment according to regional and urban land-use plans. If the available 
area  is  not  sufficient,  reasons  and  proposals  for  improvement  have  to  be  provided. 
Monitoring  reports  are  assessed  by  a  cooperation  committee  of  the  Federal  Ministry  of 
Economy and Energy and the federal states. Based on the committee’s assessment, the 
Federal Government report on the progress of RES deployment with a view to reaching the 
RES 
further  measures  (Tagesspiegel 
Background 2021). 

targets  and  provides  recommendations 

for 

Furthermore,  Germany  introduced  an  area-related  target  for  wind  power  plants.  The 
Onshore Wind Energy Law (Windenergieanlagen-an-Land-Gesetz) defines that 2% of the 
national  area  needs  to  be  designated  for  wind  energy  projects  by  2032  and  1.4%  until 
2027.84 

Greece: PV can be deployed on high yield agricultural land. 0.5% of agricultural land can 
be used to realise PV projects. In the region of Attica and the Greek Islands this share is 
even 1%. 

Luxembourg: 85  The  102  municipalities  of  the  country  have  all  signed  the  Climate  Pact, 
signalling their intention to move forward with the energy transition. In addition, the State 
strongly encourages municipalities to disclose land that can be used for energy purposes 
in  order  to  increase  the  number  of  projects.  In  this  respect,  municipalities  that  promote 

82  LOI  n°  2023-175  du  10  mars  2023  relative  à  l'accélération  de  la  production  d'énergies  renouvelables.  URL : 
https://www.legifrance.gouv.fr/dossierlegislatif/JORFDOLE000046329719/ 

83 des zones d'accélération pour l'implantation d'installations terrestres de production d'énergies renouvelables 

84  Gesetz  zur  Festlegung  von  Flächenbedarfen  für  Windenergieanlagen  an  Land  (Windenergieflächenbedarfsgesetz  -
WindBG); URL: https://www.gesetze-im-internet.de/windbg/BJNR135310022.html 

85 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Luxembourg. 

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several energy projects on their territory receive state subsidies for their support to project 
developers. These subsidies can subsequently be reallocated to other local purposes. 

Romania:  Romania  has  introduced  a  legislation  that  opens  lands  outside  of  settlement 
areas for the realization of RES-projects. Through the amendment of Land Law No. 18/1991 
projects now can be realised on areas with medium fertility classes.  

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (3): Member States shall ensure that their competent authorities at national, 
regional  and  local  level  include  provisions  for  the  integration  and  deployment  of 
renewable energy in spatial planning and public works. 

6.7.2. Define RES as public interest 

Permission  of  RES  projects  also  depends  on  how  their  environmental  benefit  is  ranked 
compared  to  any  restrictions  which  derive  from  their  installation  and  operation.  Such  a 
weighting is relevant both for administrative decisions and also possible subsequent legal 
cases. In order to clarify the high value of renewables for fighting climate change on the 
global level, renewables should be legally defined as issue of public interest. This would 
relieve  project  developers  from  the  obligation  to  individually  prove  the  public  interest  for 
their individual projects, and would enhance that this benefit is properly taken into account.  

This recommendation is also reflected by the recent Commission Staff Working Document 
on Guidance to Member States on good practices to speed up permit-granting procedures 
for  renewable  energy  projects  (EC  2022b).  This  guidance  stipulates  that  “[…]  Member 
States should clarify in their national legislation that the planning, construction and operation 
of plants for the production of energy from renewable sources, their connection to the grid 
and the related grid itself are presumed as being in the overriding public interest and in the 
interest of public safety, in view of the legislative proposal amending and strengthening the 
provisions  of  Directive  (EU)  2018/2001  related  to  administrative  procedures.”  Member 
States should thus implement this recommendation in their national regulatory framework. 

Good practice examples: 

Austria:  Austrian  Renewable  Energy  Expansion  Act  (EAG)  –  adopted  in  March  2021  – 
includes significant milestones toward the ambitious goal to produce 100% of the country’s 
electricity  from  renewables  by  2030.  The  legislation  allocates  investment  grants  and 
subsidies for solar, wind and biomass projects. In 2023, a Renewable Energy Accelerated 
Expansion Act (EABG) is going to be drafted for renewable energy systems. It aims, among 
others, to reduce bureaucracy for all RES which are, due to their size or technology, not 
obliged to pass an Environmental Impact Assessment (EIA) process. 

Germany:  The  concept  of  overriding  public  interest  has  been  established  through  the 
Renewable  Energy  Act  (EEG)  that  was  amended  in  July  2022.  Based  on  this,  lawsuits 
against RES-projects on certain grounds can be dismissed as their expansion is in public 
interest. In Mecklenburg Vorpommern this was already applied by a court. There climate 
protection and security of supply prevailed over the protection of historical monuments in 
the weighing process. 

France:  The  Renewable  Acceleration  Law  introduced  the  Imperative  Reason  of  Major 
Public Interest (RIIPM) for renewables. However, in contrast to the German example, it only 
applies to certain facilities for renewable energy production. They can automatically benefit 
from the RIIPM principle, which is used as an argument for a positive application approval 
if  the  conditions  given  by  the  implementing  decree  are  met.  Also  wind  and  solar  were 
classified  as  public  utilities  under  the  Renewable  Acceleration  Law  adopted  in  February 
2023. 

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RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (3): Member States shall ensure that their competent authorities at national, 
regional  and  local  level  include  provisions  for  the  integration  and  deployment  of 
renewable energy in spatial planning and public works. 

6.7.3. Ensure that responsible authorities are fit for purpose 

Authorities should be put in a position that they can make robust decisions on applications 
within the required deadlines or even faster. This can comprise several specific measures: 

•  A sufficient number of staff should be available in order to deal with the applications. 
•  The responsible staff persons have to be trained in order to have a sufficient level 
of  expertise  for  the  relevant  aspects  which  have  to  be  considered  during  a 
permission process by that authority. 

•  This can also be supported by the establishment of central departments with experts 
on specific issues which can provide assistance to responsible authorities on the 
regional and local level. As an option, this could be organised within the framework 
of the OSS. 

The  effectiveness  of 
implementation of the following recommendations: 

these  measures  should  be  supported  by  an  appropriate 

•  OSS:  when  planning  and  implementing  this  organisation,  a  key  success  factor  is 
obviously  an  adequate  planning  of  the  required  human  resources.  The  specific 
design  of  responsibilities  could  comprise  the  provision  of  expert  support  for 
local/regional authorities within their respective responsibilities for admission. 

•  Clarified roles and processes: The organisation of the permission process should 
include an assessment on the required human resources and expertise on the level 
of all authorities involved, allowing for an alignment with the available staff. 

•  Monitoring process for identification of regulatory barriers: This monitoring process 
should  also  include  not  only  regulatory  aspects  in  a  narrow  sense,  but  also 
specifically  assess  bottlenecks  in  the  permission  processes  which  can  be  an 
indicator of an insufficient level of staff or expertise in the individual authorities. 

•  Use  of  e-communication, 

individual  projects:  The 
including  monitoring  of 
implementation of this measure should provide the necessary knowledge in order to 
identify a lack of resources, so that this can be adapted appropriately.  

•  Guidance  and  best  practice:  Measures  in  this  field  can  be  designed  so  that  they 
contribute  to  capacity  building  and  a  sufficient  level  of  expertise  amongst  the 
responsible staff in the permission procedure. 

Good practice examples: 

Finland: 86  As  onshore  wind  has  expanded  rapidly  within  the  last  decade  in  Finland,  the 
municipal  authorities’  expertise  with 
increased  drastically.  Municipal 
environmental and construction authorities exchange information with each other and have 
begun to network country-wide. In addition, construction permit decisions from projects all 
across Finland are public documents, and can be consulted as examples when in doubt.   

it  has  also 

86 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Finland. 

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Germany: The government used funds from the Recovery and Resilience Plan to increase 
the  staff  of  permitting  authorities  and  appeal  courts.  In  a  number  of  regions  the  permit-
granting processes were hindered or slowed down by capacity-related bottlenecks , which 
targeted funds will address by allowing for more staffing, the development of streamlined 
processes, adoption of IT infrastructure, and so on. 

RED  II  requirements  whose  implementation  is  enhanced  by  this  good  practice 
recommendation:  

•  Art. 15 (1) par. 2 (a): Administrative procedures are streamlined and expedited at 
the appropriate administrative level within predictable timeframes  the assignment 
of  responsibilities  obviously  also  depends  on  the  qualification  of  the  respective 
authorities. 

6.8. Technology specific best practice 

Different  RES  technologies  face  different  barriers  within  the  respective  RES  permission 
processes. To some extent they require specific measures in order to overcome the existing 
obstacles. With a view to the technology specific best practices for permitting procedures, 
such summaries of the specific needs and requirements for good practice measures were 
derived  in  collaborative  workshops  with  stakeholders  from  European  associations  of  the 
corresponding technologies. 

Figure 6-4 gives an overview over the priorities which stakeholders assigned to different 
best-practice recommendations in the course of the technology-specific workshops which 
have  been  conducted  for  the  identification  and  discussion  of  best-practice.  Participants 
have been asked to assign priority points for those best-practice recommendations which 
they considered the most relevant. Those priority points are also displayed in Figure 6-4  
(e.g.  yellow  for  photovoltaics).  It  should  be  noted  that  the  number  of  participants  of  the 
different workshops differed significantly. Therefore, a meaningful priority can be particularly 
derived  from  the  relative  number  of  “priority  points”  per  technology,  rather  than  by 
comparison  with  the  absolute  numbers.  Besides  best-practice  recommendations  which 
have been presented and proposed by the project team, participants also had the possibility 
to propose further recommendations (displayed in yellow shapes in Figure 6-4). 

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Figure 6-4: Overview over prioritisation of different good practice recommendations by consulted stakeholders 
in the technology-specific workshops 

6.8.1. Wind  

In many European Member States wind power is a key technology for reaching the RES 
targets, at least in the electricity sector. A specific barrier for wind derives from the effects 
of increasingly high wind turbines on ecological systems (bird protection), on landscape and 
actual or perceived impairment of residents. Furthermore, the high turbines conflict to some 
extent with military and aeronautical interests (see section 2.3.1.3.2).  

Within the technology-specific workshop, stakeholders expressed particularly the relevance 
of the following best-practice recommendations: 

•  Cooperative monitoring mechanism for the identification and removal of regulatory 

barriers (see section 6.3.3),  

•  Activities to reduce conflicts with military and aeronautical interests (see below), 
•  Use  of  e-communication,  including  a  mechanism  for  monitoring  project  progress 

(see section 6.2.1), 

•  One  Stop  Shop  /  consolidation  into  one  single  application  process  (see  section 

6.2.2), 

•  Online (GIS) database / maps including administrative restrictions and other relevant 

parameters (see section 6.4.2), 

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•  Environmental  preassessment  by  authorities  /  centralisation  and  publication  of 

environmental data and assessments (see section 6.4.3). 87 

A  specific  recommendation  with  respect  to  wind  therefore  relates  to  activities  to  reduce 
conflicts with military and aeronautical interests.  

Wind-specific  best  practice  recommendation:  the  European  Commission  should 
initiate  best-practice  guidelines  for  the  Member  States  on  measures  to  reduce 
conflicts with military and aeronautical interests. 

Such activities could take place on various levels. Technical investment measures could 
include  the  implementation  of  additional  or  of  high-performance  radar,  or  the  specific 
support  of  specific  compatible  wind  turbines.  Improvements  could  also  be  done  on  the 
operational  field.  Operators  could  provide  remote  controlling  powers  for  installations  to 
military which can be used specifically when needed. Also, best-practice standards for the 
assessment of omni-directional radio beacon could be adapted and measures to achieve a 
fair balance between different interests can be appropriate. This can include a re-design of 
areas  which  are  dedicated  for  training  flights,  or  even  financial  compensation  by  wind 
developers. With  respect  to  the  permission  procedure,  stakeholders  have  also  proposed 
that it would be helpful if military approval would not be necessarily acceptance or refusal, 
but could be conditional, depending on specified adaptations.  

Best practice examples: 

France: 88 So-called stealth wind turbines, developed by a French company and used by the 
state-controlled  utility  EDF  (Electricité  de  France),  allow  the  wind  turbines  and  radars  to 
coexist without affecting the operation of the latter, because turbine blades are designed to 
minimise interference with radar systems. First requests for connections of such new wind 
turbines have already been received by the Regional Directorates for the Environmental, 
Development and Housing. 

Given  the  fact  that  the  security  constraints  represent  the  biggest  obstacle  in  the  site 
selection  for  onshore  wind,  the  French  Civil  Aviation  Authority  (La  Direction  générale  de 
l’Aviation  civile  -  DGAC)  re-evaluated  areas  that  might  be  suitable  for  wind  energy 
development, namely “Training sector at very low altitude” and “Tactical flight sector”. As a 
consequence  of  this,  13.3%  of  land  was  made  available  for  the  development  of  this 
technology.  

The  DGAC  and  Air  Force  (Armée  de  l'Air)  has  worked  on  the  development  of  radar 
interference assessment tools together with wind energy developers in order to have a more 
transparent dialogue. A similar tool is being developed for military radars. 

Estonia:89  The  Estonian  government  decided  in  late  2019  that  it  will  invest  in  the 
development of renewable energy in Ida-Viru county, by making the necessary investments 
to improve air surveillance capabilities, in other words financing the purchase of an extra 
radar  for  that  region.  According  to  the  initial  plan,  the  radar  will  be  ready  to  become 
operational in 2024, which would ease the height restrictions for wind turbines in parts of 
North-eastern Estonia. 

87 Although this best-practice recommendation has not been assigned a majority of the “priority points”, discussions revealed 
that this aspect is considered crucial by wind power representatives. 

88 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

89 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Estonia. 

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Finland: 90 In the recent years, the limiting effect of the Defence Forces on the onshore wind 
installations  in  the  country  has  been  addressed  increasingly  in  Finland.  The  current 
government’s  programme,  too,  mentions  the  negative  effects  and  pledges  to  conduct 
assessments on how to diminish them. A governmental working group has been set to work 
on combining the needs of both wind power sector and Defence Forces better in the future 
as  wind  power’s  role  in  de-carbonising  the  Finnish  electricity  system  will  be  significant. 
According to an official from the Ministry of the Environment, the working group will deliver 
its  first  report  in  spring  2021.  The  Defence  Forces,  too,  are  willing  to  increase  the 
compatibility  of  their  military  technology  and  the  pressure  to  install  more  onshore  wind 
turbines in the country. 

6.8.2. Additional specifics for offshore wind  

Offshore  wind  has  some  additional  specifics  which  should  be  taken  into  account.  For 
offshore wind, the need for coordination of activities in open sea by several governments 
imposes further challenges. Furthermore, grid access requires specific attention as offshore 
wind parks usually are remote to existing grid. Therefore, grid extension and grid access 
have to be planned consistently. 

It should be highlighted that the fundamental requirement for the implementation of a One 
Stop Shop and further coordination is already planned to be expanded on the multi-national 
level by current EU legislative initiatives.  

Best practice examples: 

Germany: 91 Under previous regimes, the German offshore wind deployment had become 
increasingly constrained by the development of its grid infrastructure, which saw a slower 
realisation  speed  than  the  construction  of  the  actual  wind  parks.  This  problem  was 
essentially  solved  by  the  current  regulatory  system,  a  legal  expert  outlines:  The 
development  of  area  development  plans  (Flächenentwicklungsplan  –  FEP)  as  central 
reference  for  the  spatial  development  of  German  offshore  capacities  also  includes  the 
respective offshore grid development into the planning. Consequently, this will essentially 
lead  to  a  synchronisation  of  wind  park  and  grid  development  as  the  FEP  provides  grid 
operators with a more long-term planning basis, while wind park developers have a shorter, 
yet sufficiently long realisation period after a successful bid in the auction. 

6.8.3. Solar 

Increased  electricity  production  by  photovoltaics  is  –  besides  wind  -  in  many  European 
Member States the major RES technology in order to reach RES targets in the electricity 
sector. In terms of permission procedures, there are significant differences between ground-
mounted PV systems and rooftop PV systems. While the first type of PV plants usually has 
a comparably high capacity and is planned by professional RES developers, the latter type 
is often very small-scale and planned and operated by non-professionals. This also includes 
an  increasing  share  of  prosumers  which  use  all  or  part  of  their  production  for  self-
consumption. 

Within  the  technology-specific  workshop,  solar  stakeholders  expressed  particularly  the 
relevance of the following best-practice recommendations: 

90 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Finland. 

91 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

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•  Eased procedures for RES self-supply and small-scale RES (see section 6.6.2),  
•  One  Stop  Shop  /  consolidation  into  one  single  application  process  (see  section 

6.2.2), 

•  Use  of  e-communication,  including  a  mechanism  for  monitoring  project  progress 

(see section 6.2.1),  

•  Financial participation of affected municipalities (see section 6.5.1),  
•  Online (GIS) database / maps including administrative restrictions and other relevant 

parameters (see section 6.4.2).  

The  request  for  eased  procedures  for  RES  self-supply  and  small-scale  RES  projects 
obviously relates particularly to rooftop PV. One proposal for such a simplification could be 
an  exemption  from  construction  permit  for  rooftop  PV,  and  very  simple  authorisation 
procedures. It has also been proposed that consumer-based projects could be subject to 
easier procedures particularly with respect to grid connection.  

6.8.4. Small hydropower 

Hydro power has in many cases a major share in national RES electricity production, as 
this technology is well established and has been introduced since many decades. At the 
same time, it mostly has a limited role in the further expansion of RES shares towards the 
2030 and 2050 RES targets. Reason being that potentials are already tapped  to a large 
extent and conflicts with other public goods (environment and others) are limiting the further 
increase  of  hydro  capacities.  Still,  there  is  further  hydro  potential  to  be  addressed,  and 
specific attention should be put on the role of repowering of existing hydropower plants.  

Within  the  technology-specific  workshop,  hydro  stakeholders  expressed  particularly  the 
relevance of the following best-practice recommendations: 

•  Environmental  preassessment  by  authorities  /  centralisation  and  publication  of 

environmental data and assessments (see section 6.4.3),  

•  Eased procedures for the repowering of existing power plants (see section 6.6.1),  
•  Cooperative monitoring mechanism for the identification and removal of regulatory 

barriers (see section 6.3.3),  

•  Adaptation of the Water Framework Directive (see below). 

Environmental pre-assessment is considered to be of good help, as has shown also the 
example of Norway, where 8000 hydro sites were identified by the national regulatory body 
NVE  and  published.  This  led  to  a  high  share  of  applications,  and  also  to  lower  cost  for 
project developers. 

With respect to repowering, proposed approaches include that refurbishments should be 
allowed within specific capacity limits without the project developer having to obtain further 
permissions, at least if environmentally relevant hydrological parameters do not change (like 
minimum flow or hydro-peaking). The expected ecological relevance and the applicability 
of  this  simplification  could  be  subject  to  an  assessment  by  local  authorities  (or  at  least 
authorities  which  are  well  familiar  with  the  local  conditions).  This  assessment  could  be 
conducted  e.g.  in  the  context  of  a  formal  hearing.  Thus,  a  more  comprehensive  re-
application procedure and particularly an EIA would only be required in case substantial 
effects of the planned measure can be expected. With respect to grid-connection, a simple 
notification procedure according to art. 17 (8) RED II could be applied. 

A monitoring mechanism for the identification and removal of administrative barriers has 
been  assumed  to  be  particularly  helpful.  This  mechanism  identifies  immoderate  or  even 
discretionary  application  of  regulation  by  local  administration  to  prevent  further  hydro 

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deployment beyond legal and administrative requirements. Another measure to generally 
provide  political  and  administrative  support  for  the  installation  of  hydro  power  plants  is 
considered to be the definition of hydro as being of public interest for its intrinsic qualities 
(flexible provision of renewable energy, supporting the integration and higher penetration of 
solar and wind) rather than on a case-by-case basis (see section 6.7.2). 

Stakeholders  have  furthermore  formulated  the  need  for  a  redefinition  of  the  Water 
Framework Directive (WFD), particularly relating to an enforcement of the cost-efficiency 
principle  which 
technology-specific  best-practice 
the  WFD  as 
recommendation:  

is  stipulated  by 

Hydro-specific best practice recommendation: Adaptation of the Water Framework 
Directive. 

A hydro-power specific recommendation which has been brought forward by stakeholders 
refers to a redefinition of the Water Framework Directive (WFD), particularly relating to an 
enforcement of the cost-efficiency principle which is stipulated by the WFD. This means that 
permitting authorities should be obliged to prove the cost-efficiency of mitigation measures 
which  they  require  over  and  above  those  measures  which  are  defined  based  on  an 
environmental  impact  assessment.  For  the  assessment  of  the  cost-efficiency,  authorities 
should  consider  the  value  of  flexible  and  reliable  provision  of  renewable  electricity  and 
weight  this  against  the  benefit  of  achieving  or  preserving  good  status  by  its  additional 
requirements. For this purpose, these benefits should be duly assessed. More generally, 
there should be a better alignment of the renewable energy and environmental goals in the 
RED II and the WFD, so that it becomes clear to which extent hydropower projects can be 
considered to be projects of overriding public interest in the sense of the WFD, and thus are 
licensable  by  responsible  authorities.  A  harmonised  and  balanced  implementation  of  the 
WFD then should be ensured e.g. by appropriate guidelines, as authorisation decisions fall 
within the competence of national, regional or local authorities.     

6.8.5. Geothermal 

Geothermal energy has some specifics which also must be considered when discussing 
permission procedures. It can be used for generation of electricity, but a large share of the 
geothermal energy relates to the provision of heat. As the transportability of heat over long 
distances is quite limited, its application is more dependent on the existence of a heat grid 
and  heat  sinks  in  the  proximity  of  the  geothermal  installation.  In  terms  of  feasible 
installations, it is worth distinguishing between different types of geothermal installations. 
Shallow geothermal installations, which are mostly an end-consumer product, are operated 
in the form of ground source heat pumps (GSHPs) and in the form of underground thermal 
energy storage (UTES). With a depth of lower than 500 m, mining law is sometimes not 
applicable. Besides this, deep geothermal installations on an industrial scale can be used 
for district heating systems. With depths of up to 6 km such plants are typically governed 
by mining law (EGEC, 2021a). 

Within the technology-specific workshop, geothermal stakeholders expressed particularly 
the relevance of the following best-practice recommendations: 

•  One  Stop  Shop  /  consolidation  into  one  single  application  process  (see  section 

6.2.2), 

•  Early engagement in local information, dissemination, and discussion (see section 

6.5.2),  

•  Delegated Act for geothermal licenses and permits (see below). 

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The  GEOENVI  project  (Batini,  2021)  as  well  as  statements  by  the  geothermal  branch 
organisation  EGEC  (EGEC,  2021a)  highlight  also  the  high  relevance  of  various  further 
recommendations as described in sections 6.2 to 6.7. These include: 

•  Environmental  preassessment  by  authorities  /  centralisation  and  publication  of 
environmental data and assessments (see section 6.4.3); in this case: availability of 
subsurface data, particularly when being partly or fully financed by public funds, 

•  Online (GIS) database / maps including administrative restrictions and other relevant 

parameters (see section 6.4.2), 

•  Clear roles and processes (see section 6.2.3), 
•  Clarified  priority  for  RES  in  administrative  processes  (see  section  6.7),  more 
specifically  by  the  development  of  a  detailed  National  Geothermal  Development 
Plan, and by ensuring the sufficient level of skills and knowledge, 

•  EU guidance document on implementation of relevant regulation provisions in arts. 
15, 16 RED and art. 8 IEMD (see section 6.3.1) and Public provision of guidelines 
and documentation templates on the national level for authorities, project developers 
and  stakeholders  (see  section  6.3.2),  particularly  on  permitting  in  Environmental 
Impact Assessments suitable for deep geothermal projects. 

The implementation of One Stop Shops has been pointed out to be of central relevance for 
geothermal planners and operators. However, due to the variety of plants and stakeholders, 
the  One  Stop  Shops  should  be  different.  Depending  on  the  plant  size  the  contact  point 
should be located on a local or higher level. This way the need for local contact for small 
and private actors and the need for a high level of (central) expertise for large installations 
are sufficiently balanced. As special fields of responsibility, geothermal stakeholders have 
stressed that this authority should – for large geothermal installations - also be responsible 
to guarantee grid connection and dispatchability for power projects.  

As  the  competent  authority  for  all  geothermal-related  issues  and  permits,  the  new 
geothermal authority would be capable of evaluating the proposed projects in a holistic and 
professional way, including the assessment of the project’s technical and financial details 
(EGEC, 2021a). In addition to granting permits, the authority should be responsible for the 
development of national long-term geothermal development plans. The plans could include 
the geothermal potential of the country, identify suitable areas for geothermal development, 
define the country’s contribution of geothermal energy to the EU decarbonisation targets 
and ensure grid availability for geothermal electricity and heat. 

More publicly available data about geothermal projects that are already commissioned or 
currently developed would help spread accurate information about geothermal technologies 
and therefore increase public acceptance (Geoenvi, 2019a). The GEOENVI report also calls 
for  establishing  a  European  minimum  standard  for  data-sharing,  which  would  provide 
Member States with the option to expand transparency beyond the standard. While creating 
this  standard,  special  attention  should  be  paid  to  the  selection  of  confidential  and  non-
confidential data.  In order to ensure environmental safety and easier geothermal project 
development, maps could be drawn to identify suitable sites. Some cities and regions of EU 
Member States have already compiled such maps, such as the region of Murcia in Spain 
(Sanner, 2021). The Murcia map indicates the suitability of the subsurface conditions for 
geothermal energy production across the region, dividing the land into three “traffic light” 
categories: green areas are considered as safe for geothermal projects, yellow areas have 
to be assessed individually, and red areas are no-go zones (Sanner, 2021). Similar open-
source, traffic light maps could be used for other regions with a potential for geothermal 
development, as well. Ideally, the mapping and planning of geothermal resource use should 
be undertaken by a national or regional geothermal authority. 

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Stakeholders  have  formulated  the  need  for  a  delegated  act  for  geothermal  licenses  and 
permits as technology-specific best-practice recommendation:  

Geothermal-specific best practice recommendation: A Delegated Act for Geothermal 
Licenses and Permits. 

A  Delegated  Act  regulating  the  provision  of  geothermal  licenses  and  permits  has  been 
strongly proposed to streamline the various layers of permitting. For this purpose, art. 15 
RED should be amended. Stakeholders have requested that such a Delegated Act should 
outline harmonised rules on licensing and permitting of geothermal projects. Furthermore, 
it should implement the “Simplified Life Cycle Assessment (LCA) Model” as developed by 
the GEOENVI project EGEC 2021). This model is supposed to evaluate the environmental 
performance  of  geothermal  projects,  particularly  in  comparison  to  fossil  alternatives 
(Geoenvi, 2019c). 

6.8.6. Solar thermal 

The situation of solar thermal energy is, like geothermal energy, to some extent different to 
other RES technologies discussed in this report, as it is particularly capable of providing 
heat energy. This can be realised by on-site installations for self-consumption, but also on 
a  larger  scale  for  feeding  in  the  heat  grid.  A  major  barrier  for  such  larger  solar  thermal 
installations is based on the fact that district heating systems generally are privately owned 
and  not  connected  with  each  other.  Feed-in  by  third  parties  is  always  subject  to  private 
negotiations, as there is no obligatory right e.g. for operators of solar thermal installations 
for feed in of RES heat in heat grids. 

Within the technology-specific workshop, solar thermal stakeholders expressed particularly 
the relevance of the following best-practice recommendations: 

•  Public provision of guidelines and documentation templates on the national level for 

authorities, project developers and stakeholders (see section 6.3.2), 

•  RES priority access also for heating grids (see below), 
•  Consideration / prioritisation of suitable areas for heat use (e.g. urban areas / close 

to district heating pipeline) (see below). 

Stakeholders assigned high priority to the public provision of guidelines on how to assess 
RES  heat  supply  in  district  heating.  This  particularly  should  include  guidance  on  how  to 
evaluate applications based on cost and performance, harmonising possible requirements 
across  the  country  and  RES  heat  technologies.  With  a  view  to  the  European  level,  one 
approach  could  also  be  a  requirement  for  Member  States  to  define  the  framework  and 
possible exemptions for RES heat to be classified as “efficient district heating” in the sense 
of art. 24 RED II. However, it was highlighted that an assessment of the competitiveness of 
RES heat can hardly be clearly regulated on EU level, but should leave sufficient room for 
a case-specific assessment. More specifically, the EU could either publish EU guidelines 
on how competitiveness and technical feasibility of RES-E could be generally defined, or to 
oblige Member States to have a national consultation on how to define a clear framework 
on the national level. Thus, this request by stakeholders is also strongly supporting best-
practice  recommendation  on  an  EU  guidance  document  for  Member  States  on  the 
implementation  of  relevant  articles  of  the  RED  II  (see  section  6.3.1  on  EU  guidance 
document on implementation of relevant regulation provisions in arts. 15, 16 RED and art. 
8 IEMD). 

Solar thermal-specific best practice recommendation: RES priority access and feed-
in also for heating grids 

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It is recommended that similar to RES electricity installations also RES heat installations 
get a priority access for grid connection and feed-in of the respective energy.  

This would increase bankability of RES heat projects when there is a clear perspective for 
participation  in  the  RES  heat  system.  It  would  also  push  district  heat  operators  to  make 
changes in their overall energy supply, either by adding own heat generation or by adding 
external RES heat supply. The general priority for RES heat could also be supplemented 
by an obligation to increase RES shares in case of extensions of district heating systems. 

Solar thermal-specific best practice recommendation: Priority of suitable areas for 
heat use 

The  implementation  of  solar  thermal  energy  is  bound  to  a  good  connection  to  the  heat 
consumer,  either  directly  or  via  a  district  heating  grid.  Therefore,  the  suitable  sites  for 
implementation  are  quite  limited  compared  to  electricity  production.  By  pre-assessing 
suitable areas for RES heat and providing a priority for RES heat, such sites which are in 
urban areas or close to district heating pipelines could be made available and thus support 
the  increase  of  RES  installations.  Based  on  such  pre-assessments  and  clear  priorities, 
negotiations  regarding  land  use  rights  could  be  facilitated  and  project  developers  would 
increase their options for land use. 

If the planning and prioritisation would not only consider the current status of projects and 
technology, but also reserve areas at least in the mid-term, the use of available sites could 
be decided based on the most suitable technology.  

Synergies could also be tapped related the mapping of heat needs, which is conducted at 
national level with local level granularity (Annex VIII Energy Efficiency Directive – EED ((EU) 
2018/2002) 92),  and  the  requirements  of  art.  15  (3)  RED  II,  which  stipulates  that  Member 
States  should  encourage  local  and  regional  administrative  bodies  to  include  renewable 
heating and cooling in the planning of the city infrastructure. 

Best practice examples: 

Austria: Austrian solar thermal stakeholders have published a white paper on good practice 
for land use with a view to solar thermal installations in Styria. This proposes a preference 
to areas which are already in use (e.g. close to traffic). If such areas are not available, the 
use of green land is suggested, while an overall ecological concept has to be part of the 
application. Furthermore, areas around cities should be prioritised for heat over electricity, 
as heat cannot be transported as well as electricity. A similar priority should apply in areas 
close to existing heat pipelines, with the threshold distance being depending on the size of 
the  plant.  The  paper  also  proposes  to  introduce  a  classification  of  land  use  as  “use  for 
energy” (Mauthner et al., 2021). 

92 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2018.328.01.0210.01.ENG 

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7. Outline for the optimised processes and supporting IT 

infrastructure that are compliant with RED II 

7.1. Objective and methodology 

Within the scope of this project, a general outline for optimised processes and supporting 
IT infrastructures that are compliant with RED II has been elaborated. This should cover the 
permission-related  aspects  as  stipulated  by  art.  15,  16  and  17  RED  II.  These  aspects 
include the following: 

•  How  to  organise  simplified  and  less  burdensome  authorisation  procedures, 
including a simple notification procedure, for decentralised devices (art. 15.1), 

•  Digital design of One Stop Shops (not more than one contact point for the entire 
process) and encompassing permit granting process, comprising all procedures (art. 
16.1), 

•  Provide the applicant with all necessary information (art. 16.2), 
•  Applicants shall be allowed to submit relevant documents also in digital form (art. 

16.2), 

•  Manual of procedures, including information online (art. 16.3). 

The task does not provide recommendations on the specific IT infrastructure but provides 
generic  process  guidelines  and  addresses  what  requirements  this  entails  for  the  IT 
infrastructure. This includes the interface between the permitting authority and the project 
developer, and the way the interface is managed during the permitting process, including 
the documentation of all relevant information in the process. This also includes the role of 
third parties and the public where needed. Furthermore, the task covers processes that are 
internal to the permitting authority and where changes can for example help to speed up 
the  process.  Finally,  it  also  covers  processes  beyond  individual  projects  and  in  between 
projects. How can the documentation of experiences and results that have been achieved 
in  one  project  and  by  one  authority  be  made  accessible  for  other  projects  and  other 
authorities and developers? 

In order to achieve the described objectives, the methodology as described in sections 2.2.2 
and  3.1  has  been  adapted  in  order  to  address  also  the  specific  needs  of  RED  II 
requirements. The applicability of different best practice recommendations with respect to 
specific RED II requirements has been assessed in order to provide broad support for an 
efficient implementation of RED II requirements. Furthermore, the relevance of the identified 
best  practice  recommendations  for  the  different  process  steps  has  been  assessed  and 
described. This should support Member States to either generally implement best practice 
recommendations  as  appropriate  for  the  whole  process,  but  also  to  focus  on  individual 
process steps if it becomes obvious that permission procedures face particular barriers in 
these process steps. 

This  includes  the  process  steps  that  are  considered  essential  for  developing  renewable 
energy projects as described in section 2.2, and outlined in the following Figure 7-1: 

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Site selection

Electricity 
production 
license

• Acquisition of the project-site (by purchasing or renting it)
• Any needed process to make it legally suitable, e.g.

• initiate changes with regard to local development plans and zoning
• possibly including Strategic Environmental Impact Assessments etc.

• Necessary processes to obtain the license to produce electricity
• (this license has in different countries different names, such as electricity production license, electricity generation 

license or exploitation authorisation)

Pre-application 
process

• Process before submitting an application for a permit to the competent authority, where the authority provides an 

advice on the subsequent application to make the application successful

Administrative 
authorisation 
process

• All processes that have to be obtained from authorities to construct a renewable energy installation, e.g.

• building permit
• environmental permission including an Environmental Impact Assessment (EIA)
• technology-specific permission, for example a water permit for hydro or a radar permit for wind power plants);

Grid connection 
permit process

• The formal process to obtain the permission to connect the installation to the grid as well as additional processes that 

might be necessary to actually connect the installation

Corporate legal-
fiscal processes

• All necessary processes to incorporate (if this is legally required) or to become member of a certain association or to 

become liable for taxation or to become exempted from it respectively

• Such requirements are particular burdensome for smaller and decentralised devices

Other relevant 
processes

• Any country specific processes which are not listed above

Source: RES Simplify 

Figure 7-1: Overview over relevant process steps for admission procedures 

7.2. Relevance  of  best  practice  recommendations  for 
individual steps of an optimised permission process 

7.2.1. Introduction and general recommendations 

When striving to optimise processes, it is not always possible to clearly identify a specific 
barrier  to  be  addressed,  or  to  anticipate  the  effect  of  any  change  of  the  admissions 
procedure, taking the complexity and possible interactions into account. Furthermore, when 
processes  are  to  be  optimised  for  the  permission  of  renewable  installations,  drafting  a 
blueprint  process  in  order  to  be  adapted  across  all  European  Member  States  does  not 
appear to be a promising approach. Firstly, such an approach could hardly take the diversity 
of national administration systems and state structures into account and ensure consistency 
of all interactions. Secondly, effects of technical and geographical differences could not be 
considered appropriately, including RES potentials, grid situation, and differences between 
different RES technologies in the different countries.  

Still, the general principles and good practice recommendations outlined in section 5 are 
elaborated in order to give general guidance for optimising RES permission processes and 
for addressing major barriers to new RES installations which have been identified. The best 
practice recommendations which are described in section 5 are rarely only relevant for one 

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single  process  step,  but  mostly  apply  generally  to  several  of  those  process  steps  or 
specifically address the coordination and interaction between the different process steps.  

A key recommendation in that respect is that roles and processes have to be clearly defined 
and  communicated  for  a  given  site  and  technology.  Country  analysis  and  stakeholder 
discussions have revealed that in many Member States responsibilities and processes are 
not only complex, but also non transparent both for authorities and for project developers. 
Therefore, it seems essential to define and to clearly describe the process which has to be 
followed  in  an  application  process,  and  the  responsibilities  of  the  parties  involved.  The 
design of the process should take the following elements into account: 

•  A clear sequential description of the application process should be provided. 
• 

Individual  responsibilities  of  authorities  (and  other  parties)  should  be  clearly 
assigned. 

o  The establishment of a central “responsible” authority should be considered, 

or at least implemented in the form of a One Stop Shop.  

o  The  number  of  involved  parties  should  be  clearly  restricted  in  order  to 

improve efficiency of the process. 

•  Transparency on required documentation for each process step should be provided. 
o  Repetitive requests for (further) data and documentation should be avoided 

by appropriate rules. 

o  Each documentation should only be required once. 
•  Clear deadlines for each step of the process should be defined. 

o  Rules should be defined with respect to the effect of a deadline not being 
kept (e.g. classification as approval, start of an alternative “bypass” process, 
etc.). 

•  Depending on complexity, size and technology, the process should include a multi-
tier application approach, from initial screening to general eligibility and clarification 
of details. 

•  The process should sufficiently take specific differences into account: 

o  Size of project (capacity), 
o  Technology, 
o  Type  of  project  (new  installation,  repowering,  self-consumer  installation, 

etc.). 

•  Concerns from other interests (environmental, archaeological, military or aviation) 
should be formulated at an early stage in order to avoid a late appearance of show-
stoppers. 

•  The process design should include a clear framework on complaint procedure and 

deadlines for challenging a permission. 

•  An appropriate IT infrastructure should be set up. 

Such a process description can be elaborated on different levels of details from national to 
local level, depending on possible differences of the processes and involved parties. Ideally, 
it should include also cooperation with stakeholder associations which are relevant in the 
given sphere of action in order to increase acceptance and reduce the risk of complaints 
throughout the process. 

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Besides these recommendations on the general process design, the following list gives an 
overview over the recommendations which can be applied on different levels and refer to 
different process steps: 

•  6.2.1  Use  of  e-communication,  including  a  mechanism  for  monitoring  project 

progress, 

•  6.2.2 One Stop Shop / consolidation into one single application process, 
•  6.2.3 Clear roles and processes, 
•  6.3.1 EU guidance document on implementation of relevant regulation provisions in 

arts. 15, 16 RED and art. 8 IEMD, 

•  6.3.2  Public  provision  of  guidelines and  documentation  templates  on  the  national 

level for authorities, project developers and stakeholders, 

•  6.3.3  Cooperative  monitoring  mechanism  for  the  identification  and  removal  of 

regulatory barriers, 

•  6.4.1 Central independent information platform on regulation, processes, projects, 

participation, 

•  6.4.2 Online (GIS) database / maps including administrative restrictions and other 

relevant parameters, 

•  6.4.3 Environmental preassessment by authorities / centralisation and publication of 

environmental data and assessments, 

•  6.5.1 Financial participation of affected municipalities, 
•  6.5.2 Early engagement in local information, dissemination, and discussion, 
•  6.5.3 Project independent moderator for stakeholder participation , 
•  6.6.1 Eased procedures for the repowering of existing power plants, 
•  6.6.2 Eased procedures for RES self-supply and small-scale RES, 
•  6.7.1 Political backing of RES: Integrated planning system from national to local, 
•  6.7.2 Define RES as public interest, 
•  6.7.3 Ensure that responsible authorities are fit for purpose. 

In case that it is deemed necessary to put a focus on individual process steps for which e.g. 
the barrier assessment of section 2.3 has revealed that major barriers exist and the process 
step in general needs to be improved, the following chapters give advice on which measures 
might be specifically helpful. 

7.2.2. Site selection 

Site selection

• Acquisition of the project-site (by purchasing or renting it)
• Any needed process to make it legally suitable, e.g.:
• Initiate changes with regard to local development plans and zoning;
• Possibly including Strategic Environmental Impact Assessments etc.

The process step of site selection could be enhanced by several of the outlined best practice 
recommendations.  In  order  to  ensure  on  a  high  level  that  sufficient  land  and  sites  are 
available for a target-compliant RES development, regional planning should be based on 
comprehensive RES targets and an estimation of the appropriate contribution of a given 

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region for RES deployment (see 6.7.1 Political backing of RES: Integrated planning system 
from national to local). For the enhancement of general public acceptance, already at this 
stage  appropriate  measures  for  stakeholder  involvement  can  be  taken  into  account. 
Amongst others, this includes early consultation and participation of relevant stakeholders 
for the definition of regional RES development plans (e.g. 6.5.2 Early engagement in local 
information, dissemination, and discussion). 

As a starting point for site selection, project developers can be supported by a GIS database 
which  gives  clear  spatial  information  on  which sites  are  eligible  in  principle  for  the  given 
project  and  technology  type,  and  which  administrative  and  technical  issues  have  to  be 
individually  clarified  for  a  given  site  (see  6.4.2  Online  (GIS)  database  /  maps  including 
administrative restrictions and other relevant parameters). The data basis for the indication 
of environmental restrictions and challenges per area and technology can be improved by 
public activities for the provision of environmental assessments. This could comprise active 
environmental pre-assessments by public authorities, but at least build on the provision of 
relevant  existing  data  for  interested  project  developers  (see  6.4.3  Environmental 
preassessment  by  authorities  /  centralisation  and  publication  of  environmental  data  and 
assessments). Provision of information in the mentioned database could even include or be 
supplemented by information on grid availability for a given site. If project developers know 
about general grid constraints, they can contribute to solving grid constraints rather than 
increasing  existing  ones.  Related  cost  for  grid  connection  which  also  depends  on  the 
available grid capacity can also be a relevant aspect in the stage of site selection. Already 
at  this  stage,  project  planners  could  improve  their  site  selection  process  based  on 
information in which regions or municipalities a specific monetary compensation is possible 
or required towards the local authorities, thus affecting project finance on the one hand, but 
also the probability of high acceptance and chances for the realisation of the project (see 
6.5.1 Financial participation of affected municipalities). 

With respect to different RES technologies and project types, some specifics have to be 
taken into account. For the repowering of existing plants, the site is already defined and not 
subject  to  a  site-selection  process  for  new  plants.  But  also  for  installations  for  self-
consumption and small-scale RES, the site is particularly depending on the location of the 
investor rather than on best potential; however, there is to some extent choice with respect 
to the technology type to be applied by such an investor (PV, solar thermal, geothermal, 
etc.).  For  Wind  and  PV,  the  process  step  of  site  selection  and  the  described  supportive 
measures  are  highly  relevant,  and  the  wind-specific  best-practice  recommendation  on 
measures related to increased compatibility with aviation and military needs relates to this 
process step. Hydro plants often are complex technologies and installations which need a 
high  level  of  individual  expertise  already  at  early  stage  which  can  hardly  be  “centrally 
supported”. For installations for the use of geothermal and solar thermal energy, it is worth 
pointing out that the site-selection is more related to availability of grid and heat sinks, and 
to market conditions for grid access. 

7.2.3. Electricity production license 

Electricity 
production 
license

• Necessary processes to obtain the license to produce electricity
• This license has in different countries different names, such as electricity 
production license, electricity generation license or exploitation authorisation

The process step of obtaining the license to produce electricity is enhanced by a lot of the 
recommendations  which  are  described  under  “General  recommendations”.  This  includes 
e.g.  e-communication  (see  6.2.1:  Use  of  e-communication,  including  a  mechanism  for 
monitoring project progress, the installation of a One Stop Shop (see 6.2.2: One Stop Shop 
/ consolidation into one single application process), a clear definition and communication of 
responsibilities  and  processes  (see  6.2.3:  Clear  roles  and  processes)  and  general 

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for 

measures 
transparency  (e.g.  see  6.3.2:  Public  provision  of  guidelines  and 
documentation  templates  on  the  national  level  for  authorities,  project  developers  and 
stakeholders or 6.4.1: Central independent information platform on regulation, processes, 
projects, participation). 

With respect to obtaining an electricity production license it seems particularly important to 
consider that the specific requirements for planners and operators are appropriate to the 
type of operator, and to the type of installation. With respect to repowering of existing plants, 
an extension of the electricity production license should not be a relevant barrier depending 
on  comprehensive  requirements  (see  6.6.1:  Eased  procedures  for  the  repowering  of 
existing power plants). RES self-supply and small-scale RES can be considered another 
special case for obtaining the electricity production license, as also those actors probably 
have  a  comparably  low  level  of  expertise  and  experience,  and  the  respective  individual 
plants have a limited relevance from the system perspective. Thus, it should be considered 
whether such plants should need a license at all, or whether this can just be based on a 
simple notification procedure (see 6.6.2: Eased procedures for RES self-supply and small-
scale RES).  

Good practice examples specifically referring to the electricity production license: 

Austria:93 In Upper Austria there is an exemption from the electricity generation licence for 
small hydropower plants with a capacity of up to 400 kW. This is seen as a simplification of 
the procedure. 

Portugal:94 The publication of Decree Law 76/2019 represented a significant legislative step 
towards enabling RES to play a bigger role in the country’s energy mix. Specifically, the 
changes made in the electricity production licensing regime with the intent to enable the 
existence of hybrid plants (art. 4, par. 3 “[…] installation of new units in an already existing 
power plant that uses a different power source”) are to be commended, as hybridisation 
(especially  for  the  wind  sector)  is  one  of  the  main  strategies  for  increasing  electricity 
production from RES in the country. 

A new legislation aims at simplifying the licensing rules and regulatory procedures applied 
to production units for self-consumption. For certain facilities (depending on the installed 
capacity), a mere notification to the Directorate-General of Energy and Geology is required 
in order to start operating the unit (for others not even that is required), which is a positive 
reinforcement  for  small  and  medium-sized  photovoltaic  producers  as  well  as  owners  of 
small/mini wind turbines. 

7.2.4. Pre-application process 

Pre-
application 
process

• Process before submitting an application for a permit to the competent 
authority, where the authority provides an advice on the subsequent 
application to make the application successful.

The pre-application process step is enhanced by some of the general recommendations 
outlined  above  (see  section  7.2.1).  It  also  has  some  overlap  with  the  described 
recommendations  for  site  selection  (see  section  7.2.2)  depending  on  where  individual 
process steps are allocated.  

93 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Austria. 

94 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Portugal. 

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The  basic  precondition  for  a  smooth  pre-application  process  is  the  integration  of  such  a 
process step in national administration plans at first hand. This should be clarified in a multi-
step application process (see section 6.2.3: Clear roles and processes).  

A critical aspect in order to obtain a meaningful advice obviously includes that the contacted 
authority has the necessary competences to make a preliminary judgement on the proposal. 
This is, amongst others, enhanced by the recommendations on the One Stop Shop (see 
6.2.2: One Stop Shop / consolidation into one single application process) and by measures 
to  ensure  that  responsible  authorities  are  fit  for  purpose  (see  section  6.7.3:  Ensure  that 
responsible authorities are fit for purpose). It is advisable that already at this early stage, 
possible conflicts with other interests and opposition by stakeholders are considered and 
taken into account (see section 6.5.2: Early engagement in local information, dissemination, 
and discussion). 

Good practice example specifically referring to the pre-application process: 

UK: 95 Project developers propose public consultation plans for their projects to the council, 
and the council approves or supplies recommendations. Typical plans include the following 
features:   

•  Public  Exhibitions  where  locals  see  the  details  of  the  emerging  project,  provide 
feedback and ask the project team any questions. This may take place in different 
localities around the site.   

•  Provide a website and a point of contact.   
•  List the locations where hard copies of project materials will be displayed.   
•  Contact local community councils and business and political stakeholders to keep 

them updated on the project progression.   

•  Create a Community Liaison Forum with local community group leaders to discuss 

the project and the community benefit fund.  

•  Offer shared ownership on the project.  

Stakeholders  are  also  engaged  if  there  is  a  material  change  in  the  project  while  it  is  in 
planning. Locals can make representations to the council on the planning application for 
about a month after the information is submitted.  

A pre-application consultation report is submitted with major applications that details that 
stakeholder  consultation  that  took  place  prior  to  the  planning  applications,  the  feedback 
received and how that feedback was considered in the project. 

7.2.5. Administrative authorisation process 

Administrative 
authorisation 
process

• All processes that have to be obtained from authorities to construct a r 
enewable energy installation, e.g.
• building permit;
• environmental permission including an Environmental Impact Assessment 
(EIA);
• technology-specific permission, for example a water permit for hydro or a 
radar permit for wind power plants.

The  process  for  obtaining  the  administrative  authorisation  for  the  construction  of  a 
renewable  energy  installation  can  include  many  different  individual  process  steps  and 

95 Description taken from responses to the RES Simplify Survey. 

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individual authorisations. Therefore, not only a sound definition of the individual steps, but 
also  a  good  coordination  of  the  whole  process  is  key  in  order  to  enhance  the  whole 
administrative authorisation. Basically, all of the good practice recommendations which are 
listed  under  section  7.2.1  “Introduction  and  general  recommendations”  are  therefore  of 
relevance for the administrative authorisation. 

7.2.6. Grid connection permit process 

Grid 
connection 
permit 
process

•The formal process to obtain the permission to connect the installation to the 
grid as well as additional processes that might be necessary to actually connect 
the installation.

The process to obtain the grid connection permit differs from the other described process 
steps particularly by the involvement of the grid operator as an extra player (at least in the 
“back  office”).  Still,  a  lot  of  the  general  recommendations  are  also  relevant  for  the  grid 
connection. It should be facilitated by e-communication and be covered by the activities of 
the One Stop Shop, based on clear roles and processes which are described in transparent 
guidelines  (see  sections  6.2.1:  Use  of  e-communication,  including  a  mechanism  for 
monitoring project progress, 6.2.2: One Stop Shop / consolidation into one single application 
process,  6.2.3:  Clear  roles  and  processes  and  6.3.2:  Public  provision  of  guidelines  and 
documentation  templates  on  the  national  level  for  authorities,  project  developers  and 
stakeholders).  

With respect to the recommended establishment and provision of an online GIS database 
on  the  suitability  of  different  areas  (see  section  6.4.2:  Online  (GIS)  database  /  maps 
including administrative restrictions and other relevant parameters), a specific feature might 
be information on grid availability for a given site. It should be pointed out that particularly 
with respect to grid connection, eased procedures for repowering, small-scale RES and for 
self-consumption RES should apply due to the limited impact of the individual installations 
on the grid. In general, it should be ensured that connection of RES installations and the 
feed-in of RES energy is generally prioritised over conventional energy. 

Good practice examples specifically referring to the grid-connection process: 

Finland:96 During the survey, the stakeholders expressed a high overall level of satisfaction 
with their interaction with the DSOs and the TSO, Fingrid. Both levels of grid administration 
and development are regarded as fluent and transparent. Fingrid is very willing to enable 
connection  of  the  fast-growing  wind  power  sector  to  the  grid.  The  good  communication 
between  RES  installations  and  Fingrid  has  developed  through  years  of  cooperation  and 
being open to each other's needs, leading to mutual benefit. Stakeholders in the wind power 
sector  emphasised  the  grid  operator’s  willingness  to  being  updated  about  the  future 
prospects of the wind power sector, and its interest in being notified about projects that are 
still in development or planning stages. Project developers have a good working relationship 
with Fingrid, enabling them to have conversations together about the future development of 
the main grid and access to it. Fingrid is willing to make reparations to the grid in order to 
ensure access to wind power facilities. Unlike local grid operators in Finland, Fingrid also 
has a clear and consistent pricing system. 

96 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Finland. 

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Germany: 97  The  ‘principle  of  priority’  guarantees  renewable  energy  sources  preferential 
treatment for grid connection over other energy plants. 

France: 98 The Grenelle II Law introduced the Regional grid connection plan for renewable 
energies  (Schéma  régional  de  raccordement  au  réseau  des  ENR  -  ENR'S3EnR)  to 
accelerate the connection to the electricity network and, moreover, to mutualise the costs 
throughout  the  territory.  This  planning  tool  enables  the  Regional  Directorates  for  the 
l'Environnement,  de 
Environment,  Planning  and  Housing  (Direction  régionale  de 
l'Aménagement et du Logement – DREAL) and project developers to closely monitor the 
development  of  the  electricity  network  throughout  the  country.  In  addition,  these  plans 
provide planning and anticipation of grid connections.  

Lithuania: 99 Stakeholders surveyed for the RES Simplify project perceive the simplified grid 
connection procedure for renewable power systems with the capacity of less than 30 kW 
as good practice. The grid connection of these small-scale systems does not require many 
documents and the connection is organised quickly. Moreover, all documents and the grid 
connection status can be viewed online when logged on the operator’s website. 

Norway: 100  As  energy  act  license  and  hydropower  license  are  both  often  granted  by  the 
national regulatory authority Norges vassdrags- og energidirektorat (NVE) (depending on 
the size and potential impacts of the installation), the processes run parallel to each other 
and the processes can be coordinated within the same authority. In addition, NVE and the 
national grid operator Statnett are engaged in dialogue during the licensing process and the 
assessment of grid capacity for hydropower projects. Collaboration and dialogue ensure the 
potential  situation  of  granting  grid  capacity  or  a  hydropower  license  for  a  project,  and 
denying it of the other.  

Poland: 101 In Poland, there is a Coordinator for negotiations to the President of the Polish 
Energy Regulatory Office (ERO), which is responsible for conducting out-of-court dispute 
settlement procedures between the renewable energy prosumers and energy companies 
(e.g. grid operator in the area where the micro-installation is located). 

Among other things, the Coordinator deals with the questions related to the grid connection 
of micro-installations and provision of electricity transmission or distribution services. The 
key role of the Coordinator is to help the parties to resolve the dispute. His key tasks are 
therefore to bring the parties' positions closer together and to propose a solution to them 
(art. 31a Energy Law). 

Portugal:102 For certain small-medium sized power plants, it is only necessary to notify the 
(Portuguese)  Directorate-General  of  Energy  and  Geology  (DGEG)  of  their  intention  to 
connect  the  unit  to  the grid  –  and,  for  specific cases,  not even  a  notification is  required. 
Such instrument provides agility to photovoltaic projects that fit in the criteria, reducing costs 
and optimising time efficiency of projects. 

97 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Germany. 

98 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on France. 

99 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Lithuania. 

100 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Norway. 

101 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Poland. 

102 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Portugal. 

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Small power plants with a capacity of up to 1 MW can apply for a fast application via a web 
page to gain the grid connection permit. 

Slovenia: 103 Slovenia has implemented the RES-E Self-supply Decree (2019), with which 
individual self-supply, self-supply in buildings with several apartments and communities that 
jointly install facilities for the production of energy from renewable sources are promoted. 
The decree was adopted and changed to remove administrative barriers in the formation of 
community self-sufficiency and to simplify the process of connecting devices to the power 
grid, e.g. by lifting the capacity limit of community devices. So far, the implementation of the 
new  regulation  has  worked  well  and  brought  a  significant  acceleration  of  administrative 
procedures. 

7.2.7. Corporate legal-fiscal processes 

Corporate 
legal-fiscal 
processes

• All necessary processes to incorporate (if this is legally required) or to become 
member of a certain association or to become liable for taxation or to become 
exempted from it respectively
• Such requirements are particular burdensome for smaller and decentralised 
devices

Corporal legal-fiscal processes are strongly dependent on the national framework and the 
administrative process. In this respect the basic precondition for smooth operation are all 
best practice recommendations which relate to the fields of administrative communication 
and processes (see section 6.2), Guidance and best practice (see section 0), and to the 
Central provision of information (see section 6.4). The particular challenge for planners and 
operators of small and decentralised devices should be appropriately addressed by eased 
procedures for such stakeholders and devices (see section 6.6). 

Good practice examples specifically referring to corporate legal-fiscal processes: 

Norway: 104 For hydropower installations that fulfil the criteria for the sales license, the license 
is  usually  approved  automatically  and  rather  quickly.  Even  if  the  license  is  manually 
processed by an NVE officer, the licensing time is usually limited to 2–4 weeks. The Altinn 
online application system is connected to the Brønnøysund company registry, and retrieves 
company information from there.   

7.3. Relevance of best practice recommendations for an 
optimised implementation of RED II key requirements  

An optimised process for the permission of RES installations has to take into account all 
requirements which are stipulated by art. 15, 16 and 17 RED II. Table 7-1, Table 7-2 and 
Table  7-3  provide  an  overview  on  how  the  recommendations  which  are  described  in 
sections 6.2 to 6.7 and in section 0 support the implementation of RED II requirements. This 
overview thus provides recommendations on how to reach the objectives set in the RED II 
by an optimised permission process. 

Table 7-1: Overview over specific key requirements from the RED II (art. 15) with respect to admission 
procedures and best practice recommendations supporting the respective RED II requirements 

103 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Slovenia. 

104 Description taken from RES Simplify National Report. For further information and references pls. see Annex 1: RES Simplify 
National Report on Norway. 

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RED II 
reference 

Specific key requirement for 
permission procedure 

Art. 15 (1) 
par. 2 (a) 

Administrative procedures are 
1) streamlined and  
2) expedited at the appropriate 
administrative level and  
3) predictable timeframes 

Best practice recommendations 
supporting the respective RED II 
requirements 

Ad 1) 6.2.1 Use of e-communication, including 
a mechanism for monitoring project progress 

Ad 1, 2, 3) 6.2.3: Clear roles and processes 

Ad 1, 3) 6.4.3: Environmental preassessment 
by authorities / centralisation and publication 
of environmental data and assessments 

Ad 2) 6.2.2: One Stop Shop / consolidation 
into one single application process 

6.7.3: Ensure that responsible authorities are 
fit for purpose 

Art. 15 (1) 
par. 2 (b) 

Rules are  
1) objective, transparent and proportionate,  
2) do not discriminate between applicants 
and  
3) take fully into account the particularities 
of individual renewable energy technologies 

Ad 1, 2, 3) 6.2.3: Clear roles and processes 

Ad 1) 6.3.2: Public provision of guidelines and 
documentation templates on the national level 
for authorities, project developers and 
stakeholders  

Ad 2) 6.6.2: Eased procedures for RES self-
supply and small-scale RES 

Ad 3) 6.2.2: One Stop Shop / consolidation 
into one single application process 

6.4.1: Central independent information 
platform on regulation, processes, projects, 
participation 

6.2.1 Use of e-communication, including a 
mechanism for monitoring project progress 

6.2.2: One Stop Shop / consolidation into one 
single application process 

6.2.3: Clear roles and processes 

6.6.2: Eased procedures for RES self-supply 
and small-scale RES 

6.4.2: Online (GIS) database / maps including 
administrative restrictions and other relevant 
parameters 

6.7.1: Political backing of RES: Integrated 
planning system from national to local 

6.7.2: Define RES as public interest 

6.6.2: Eased procedures for RES self-supply 
and small-scale RES 

6.8.5: Geothermal technology-specific best 
practice  

6.8.6: Solar thermal technology-specific best 
practice 

Art. 15 (1) 
par. 2 (c) 

Administrative charges are transparent and 
cost-related; and 

Art. 15 (1) 
par. 2 (d) 

Simplified and less burdensome 
authorisation procedures, including a 
simple-notification procedure, are 
established for decentralised devices, and 
for producing and storing energy from 
renewable sources 

Art. 15 (3)   Member States shall ensure that their 

competent authorities at national, regional 
and local level include provisions for the 
integration and deployment of renewable 
energy in spatial planning and public works.  

Member States shall encourage local and 
regional administrative bodies to include 
RES H&C in the planning of city 
infrastructure where appropriate, and to 
consult the network operators to reflect the 
impact of energy efficiency and demand 
response programs as well as specific 
provisions on renewables self- consumption 
and renewable energy communities, on the 
infrastructure development plans of the 
operators. 

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RED II 
reference 

Specific key requirement for 
permission procedure 

Art. 15 (7)  MS shall carry out an assessment of their 
RES potential, including spatial analysis of 
areas suitable for low-ecological-risk 
deployment and potential for small-scale 
household projects. 

Best practice recommendations 
supporting the respective RED II 
requirements 

6.4.2: Online (GIS) database / maps including 
administrative restrictions and other relevant 
parameters 

6.4.3: Environmental preassessment by 
authorities / centralisation and publication of 
environmental data and assessments 

6.7.1: Political backing of RES: Integrated 
planning system from national to local 

Table 7-2: Overview over specific key requirements from the RED II (art. 16) with respect to admission 
procedures and best practice recommendations supporting the respective RED II requirements 

RED II 
reference 

Specific key requirement for 
permission procedure 

Art. 16 (1) 

Establishment of one or more contact points 
which shall, upon request by the applicant, 
guide through and facilitate the entire 
administrative permit application and 
granting process, including all the relevant 
administrative permits to build, repower and 
operate RES plants. 

Art. 16 (2) 

The contact point shall  
1) guide the applicant through the 
administrative permit application process in 
a transparent manner up to the delivery of 
final decisions by the responsible 
authorities, 
2) provide the applicant with all necessary 
information and 
3) involve, where appropriate, other 
administrative authorities.  

Best practice recommendations 
supporting the respective RED II 
requirements 

6.2.2: One Stop Shop / consolidation into one 
single application process 

6.2.3: Clear roles and processes 

6.3.2: Public provision of guidelines and 
documentation templates on the national level 
for authorities, project developers and 
stakeholders 

6.2.2: One Stop Shop / consolidation into one 
single application process 

6.2.3: Clear roles and processes 

6.3.2: Public provision of guidelines and 
documentation templates on the national level 
for authorities, project developers and 
stakeholders 

6.4.1: Central independent information 
platform on regulation, processes, projects, 
participation 

Art. 16 (2) 

Applicants shall be allowed to submit 
relevant documents also in digital form. 

6.2.1: Use of e-communication, including a 
mechanism for monitoring project progress 

Art 16 (3) 

The contact point shall  
1) make available a manual of procedures 
for RES developers also online,  
2) addressing also small-scale and self-
consumers projects.  

Online information shall indicate the contact 
point relevant to the applicant's application. 

6.2.2: One Stop Shop / consolidation into one 
single application process 

6.2.3: Clear roles and processes 

6.3.2: Public provision of guidelines and 
documentation templates on the national level 
for authorities, project developers and 
stakeholders 

6.4.1: Central independent information 
platform on regulation, processes, projects, 
participation 

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RED II 
reference 

Specific key requirement for 
permission procedure 

Art. 16 (4) 

Art. 16 (5) 

Permit-granting process (cf. par 1) shall not 
exceed two years, including all relevant 
procedures of competent authorities (in 
extraordinary circumstances: three years). 

Permit-granting process (cf. par 1) shall not 
exceed one year for RES-E installations 
<150 kW (in extraordinary circumstances: 
two years). 

Art. 16 (5) 

Easy access for applicants to simple 
procedures for the settlement of disputes 
including, where applicable, alternative 
dispute resolution mechanisms. 

Best practice recommendations 
supporting the respective RED II 
requirements 

Ad 2) 6.6.2: Eased procedures for RES self-
supply and small-scale RES 

6.2.1: Use of e-communication, including a 
mechanism for monitoring project progress 

6.2.3: Clear roles and processes 

6.2.1: Use of e-communication, including a 
mechanism for monitoring project progress 

6.2.3: Clear roles and processes 

6.6.2: Eased procedures for RES self-supply 
and small-scale RES 

6.2.2: One Stop Shop / consolidation into one 
single application process 

6.2.3: Clear roles and processes 

6.3.3: Cooperative monitoring mechanism for 
the identification and removal of regulatory 
barriers 

Art. 16 (6) 

Simplified and swift permit-granting process 
for repowering (length <1 year, in 
extraordinary circumstances <2 years). 

6.2.1: Use of e-communication, including a 
mechanism for monitoring project progress 

6.2.3 Clear roles and processes 

6.6.1 Eased procedures for the repowering of 
existing power plants 

6.2.1: Use of e-communication, including a 
mechanism for monitoring project progress 

6.2.3 Clear roles and processes 

6.4.3 Environmental preassessment by 
authorities / centralisation and publication of 
environmental data and assessments 

6.3.3: Cooperative monitoring mechanism for 
the identification and removal of regulatory 
barriers 

6.2.1: Use of e-communication, including a 
mechanism for monitoring project progress 

6.2.2: One Stop Shop / consolidation into one 
single application process 

6.2.3: Clear roles and processes 

6.6.1: Eased procedures for the repowering of 
existing power plants 

Art. 16 (7)  Mentioned deadlines shall be extended for 

the duration of other procedures like 
obligations under applicable Union 
environmental law, judicial appeals, 
remedies and other proceedings before a 
court or tribunal, and to alternative dispute 
resolution mechanisms. 

Art. 16 (8)  Option to establish a simple-notification 

procedure for grid connections for 
repowering projects (cf. art 17(1)). 

Permission upon notification to the relevant 
authority where no significant negative 
environmental or social impact is expected. 
That authority shall decide within six months 
of receipt of a notification whether this is 
sufficient. Where the relevant authority 
decides that a notification is sufficient, it 
shall automatically grant the permit. Where 
that authority decides that the notification is 
not sufficient, it shall be necessary to apply 
for a new permit and the time- limits 
referred to in paragraph 6 shall apply. 

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Table 7-3: Overview over specific key requirements from the RED II (art. 17) with respect to admission 
procedures and best practice recommendations supporting the respective RED II requirements 

RED II 
reference 

Specific key requirement for 
permission procedure 

Art. 17 (1) 

Simple-notification procedure for grid 
connections for renewables self-consumers 
and demonstration projects (<10.8 kW) 
upon notification to the DSO. 

DSO may within a limited period (1 month) 
reject the requested grid connection or 
propose an alternative grid connection point 
on justified grounds of safety concerns or 
technical incompatibility of the system 
components.  

Art. 17 (2)  Optional simple-notification procedure for 

installations with 10.8 kW up to 50 kW, 
provided that grid stability, grid reliability 
and grid safety are maintained. 

Best practice recommendations 
supporting the respective RED II 
requirements 

6.2.1: Use of e-communication, including a 
mechanism for monitoring project progress 

6.2.2: One Stop Shop / consolidation into one 
single application process 

6.2.3: Clear roles and processes 

6.6.2: Eased procedures for RES self-supply 
and small-scale RES 

6.2.2: One Stop Shop / consolidation into one 
single application process 

6.2.3: Clear roles and processes 

6.6.2: Eased procedures for RES self-supply 
and small-scale RES 

Source: RES Simplify 

7.4. IT infrastructure 

Optimised  processes  require  adequate  IT  infrastructure.  RED  II  contains  a  number  of 
requirements that necessitate this. Optimised processes that are compliant with the RED II 
need to fulfil the following functions: 

1.  Provide information to applicants (arts. 16.2, 16.3). 

2.  Facilitate  the  information  flow  from  applicants  to  authority  (arts.  16.1,  16.2). 
According  to  art.  16.2  RED  II,  applicants  shall  be  allowed  to  submit  relevant 
documents in digital form. 

3.  Besides  these  explicit  requirements  concerning  the  interface  between  applicants 
and  authorities,  there  is  also  a  need  for  optimal  processes  within  and  between 
authorities,  to  make  the  process  as  effective  and  efficient  as  possible,  which  is 
needed to meet the requirements of the RED II, for example to stick to time limits. 

In the following, we present a number of infrastructure issues that need to be considered in 
order  to  meet  these  requirements.  Some  of  these  issues  have  already  been  addressed 
above, but are presented here in a structured way, focusing specifically on IT infrastructure. 

A  wide  range  of  existing  "client  portal"  or  "customer  service"  software  platforms  are 
commercially available. Using existing platforms is typically less cost intensive then having 
a new platform developed. 

1)  Provide information to applicants 

IT  infrastructure  should  support  applicants’  access  to  requisite  information.  This  entails 
establishing necessary repositories of data where necessary information is collected and 
made available. This should cover a range of issues that are all accessible through a single 
platform. This way IT infrastructure supports the development of single contact points. 

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•  There needs to be information provided on all steps of the permitting processes and 
what is required by the applicant. In countries in which the regional authorities have 
a lot of administrative power and different requirements are in place, there should 
also  be  a  central  up  to  date  information  point  on  all  these  differences  between 
regions. 

•  The  IT  platform  should  also  provide  the  applicants  with  information  they  need  to 
prepare their project and their application. For example, this can include a GIS which 
includes all constraints that can exist at a local level (military, radar, protected areas, 
projected  grid  development,  local  planning  etc.)  as  well  as  data  that  has  already 
been collected on these constraints and that developers can use to select and plan 
appropriate sites.  

•  There also needs to be transparent information on the permitting platform itself on 
how  it  works  and  the  platform  should  provide  user  support,  including  access  to 
support  staff.  This  is  also  to  make  sure  that  replacing  conventional  systems  with 
digital ones does not delay processes because users encounter problems for which 
they cannot find a solution. 

2)  Facilitate information flow from applicants to authorities 

Besides channelling information from authorities to applicants, IT infrastructure should also 
facilitate information flow in the other direction. Most importantly, developers should be able 
to  submit  application  documents  digitally,  but  such  a  platform  could  enable  further 
communication from the applicant. 

IT infrastructure should be the basis for a single contact point, but should not become a 
black box for applicants.  

Black box means that a project developer loses the possibility to interact with the people 
that actually examine the project in the different administrations and the developer does not 
know which procedure takes how much time and why. As a result, the developer has no 
chance  to  react,  because  there  is  only  a  digital  single  contact.  The  above-mentioned 
support can contribute to addressing this potential black box problem. What is also needed 
is a tracking system that allows applicants to follow their application through the process 
and  see  the  progress  made  in  assessing  its  project.  Moreover,  while  this  transparency 
should reduce the need for applicants to contact the authority and ask about the process, 
there should also be staff available that applicants can contact. This also needs to be made 
transparent in the IT system. 

The  two-way  communication  between  applicants  and  authorities  (requirements  to  both 
provide information to the applicant and to facilitate the information flow from applicants to 
authorities)  should  be  combined  in  one  central  platform.  This  should  ensure  that  all 
information is in one place for a project at hand.  

The  platform  should  enable  communication,  including  questions,  answers,  comments  in 
both directions. Ideally, this replaces communication via email or on the phone, so that all 
information can be stored and tracked in one place. This also increases the flexibility for 
example in the case of staff changes, both on the side of the applicant and the authority. 

Based on this, the platform can have a broader scope beyond the individual project. It can 
also  enable  information  exchange  as  well  as  learning  between  projects  and  avoid 
“reinventing the wheel”. Questions that have already been clarified for a previous project 
and answers that have been provided should be made accessible via this platform, both for 
the authority and the applicants – obviously ensuring the required project confidentiality. 

Moreover, the platform can have a similar function between authorities, not just between 
projects.  It  can  act  as  a  central  information  point  where  decisions,  experiences,  data 
sources etc. are made available between authorities, so that they can learn from each other, 

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use each other’s resources and do not have to repeat the work that has already been carried 
out by other authorities. 

Thus, the central platform can also contribute to the third function, to optimise processes 
within and between the authorities. 

3)  Optimal process within authorities 

Finally,  IT  infrastructure  should  not  only  support  interaction  between  authorities  and 
applicants, but should also contribute to the effective and efficient processing of applications 
within the authorities. 

Depending on the type of data that is being submitted, the data should not just be provided 
in digital form, but rather digital & machine readable. Processes can be sped up significantly 
if it is possible to parse and validate data on the platform side automatically. 

Some  of  the  above-mentioned  features  can  increase  internal  efficiency  and  therefore  IT 
solutions  should  be  designed  to  support  these  objectives.  First,  the  central  platform  can 
also be used as knowledge management system for the involved authorities. 

Second, a tracking system can make the process transparent for applicants as well as those 
experts  working  within  authorities,  i.e.  ensure  that  the  employees  of  the  authorities  can 
clearly identify a specific permitting process with a unique application number and always 
know  where  an  application  is  located  in  the  process,  who  is  responsible  for  which  step, 
which steps can be worked on in parallel and who is responsible next. It also allows the 
authorities  to  manage  the  timing  of  the  individual  process  steps.  This  is  all  the  more 
important  in  a  single  contact  point  approach  where  different  authorities  have  to  ensure 
coordination between each other. Finally, such a system cannot just help manage individual 
applications,  but  it  can  also  be  used  to  analyse  indicators  across  applications  and  thus 
identify bottlenecks in the process that lead to long processing times. 

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8. Conclusions 

The aim of this report was to provide decision-makers with accurate and in-depth insights 
on  the  most  challenging  administrative  barriers  impeding  the  widespread  deployment  of 
renewable  energy  technologies  in  EU  Member  States,  Iceland  and  Norway. 105  These 
barriers were linked to two of the most critical steps for RES deployment, namely permit-
granting  and  grid  connection  procedures.  To  complement  this,  the  report  also  identified 
good and best practices as examples of how Member States deal with these administrative 
issues, to establish lessons learnt that could be generalised and applied in other national 
contexts.  These  best  practices  could  stimulate  and  streamline  permitting  in  European 
countries for both new renewable energy installations and projects that are being repowered 
–  the  latter  are  becoming  increasingly  important  as  a  number  of  RES  markets  matures. 
Finally, this report provides a comparative assessment of recent legislative developments 
in  EU  Member  States,  and  shows  how  national  policymakers  can  establish  optimal 
procedures and support digital infrastructure in a way that is consistent with relevant legal 
requirements imposed by RED II. 

To achieve its objectives, this report employed a comprehensive multi-step methodology 
centered  on  mapping  the  permit-granting  and  grid  connection  procedures  for  relevant 
renewable energy technologies in target countries (i.e. the 27 EU Member States, Norway, 
and Iceland). This traced the main steps and associated permissions that arise during the 
completion of a renewable energy project. It also identified the most common and significant 
barriers  to  obtaining  approvals  from  competent  regional  and  national  authorities  or 
connecting to the grid from grid operators. The mapping exercise was complemented by a 
cross-country  benchmarking,  which  used  a  set  of  performance  indicators  designed  to 
identify  cases  where  permitting  procedures  appear  comparatively  efficient  and  effective, 
enabling us to further assess these regulations and consider them as best practices to be 
shared as part of project dissemination activities. 

The  primary  barriers  to  the  diffusion  of  renewable  energy  technologies  in  the  target 
countries  were  non-technical,  such  as  weak  support  schemes,  market  entry  barriers, 
administrative  barriers,  and  grid  issues.  Administrative  barriers  became  increasingly 
important and pressing as they impede the expansion of RES markets. In line with RES 
Simplify results, administrative and grid issues account for approximately 46% of all barriers 
(ranging from weak support schemes to third party issues), and this proportion is expected 
to increase in the future. For some renewable energy technologies, such as wind and solar 
PV,  administrative  barriers  are  becoming  more  critical  than  policy  barriers  related  to 
domestic financial support schemes. These renewables are thus competitive in the given 
context, but a number of other barriers have emerged that impede their rapid diffusion as 
their markets mature. 

This report also compiles an extensive list of good and best practices in administrative and 
grid connection procedures from target countries. We identified lessons learnt that could be 
applied to other contexts, including Member States, process steps, or technologies. These 
can be used as input to inform further policy development at the national or regional level. 
Results  were  based  on  a  four-step  data  collection  process  consisting  of  (1)  desktop 
research,  (2)  expert  interviews,  (3)  an  online  survey,  and  (4)  stakeholder  workshops. 
Desktop research covered a wide array of literature and interviewees comprised a host of 
experts involved in various roles with renewable energy projects. Data gathered from these 

105  It should be noted that the vast majority of deliverables of the RES Simplify project were scheduled in the years 2020, 
2021, and 2022 respectively. In the light of the foregoing, the information provided in this report might not necessarily reflect 
the status quo at the time of its publication.  

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Simplification of permission and administrative procedures for RES installations 

streams of information became the bases of 29 comprehensive National Reports, which we 
finalised betwen November 2020 and July 2021. 

The list of potential good practices was reviewed and analysed to prioritise universal policy 
options or best practices that could be applied more broadly. Identified best practices, along 
with the main findings on existing barriers, were disseminated through a series of 52 events. 
These efforts aimed to engage public policymakers, regulators, private sector stakeholders, 
and civil society groups to validate preliminary findings. Events also offered a platform to 
discuss  and  shape  RED  II  policies  that  EU  Member  States  were  in  the  process  of 
transposing into national legislation. The Consortium then assessed RED II’s arts. 15, 16 
and 17 state of implementation in early-2022, which it then monitored between April and 
December  2022  to  trace  how  EU  Member  States  implemented  specific  measures.  This 
allowed us to identify additional good practices to simplify and accelerate renewable energy 
project permitting. 

During the final phase of the project, the Consortium sought to condense findings and single 
out best practices that offered general policy guidance.  We grouped good practices into six 
different categories – or “fields of action” – to condense the lessons learnt into more general 
recommendations. Policy makers and other stakeholders can take these into account when 
implementing  and  developing  measures  aimed  at  enhancing  permission  procedures. 
Furthermore,  guidance  for  optimised  processes  and  supporting  IT  infrastructure  was 
introduce to support Member States in permitting and complying with the needs of RED II. 

Finally,  RES-Simplify  project  has  been  running  for  a  number  of  years,  during  which  the 
Consortium has provided an in-depth, continuous analysis of barriers and best practices 
that hinder the deployment of renewables. Our findings suggest that a plethora of barriers 
remain throughout the EU, Iceland, and Norway most of which are administrative and grid 
related. As the pieces for an EU framework have fallen into place, these still need to be 
transposed  into  national  legislation  and  enforced  to  allow  for  the  energy  transition  to 
accelerate  in  these  countries.  During  the  period  of  our  inquiry,  we  saw  states  make 
tremendous progress in overcoming many of these barriers and our ability to identify many 
good practices indicate that regulatory frameworks are generally evolving. The findings and 
recommendations of this project offer a solid basis for further action; which is much needed 
considering the long and challenging path ahead of the EU to meet its climate and energy 
targets. 

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Annex 

National Reports for 27 EU Member States, Iceland and Norway are available at the following 
website: <https://www.eclareon.com/en/projects/res-simplify>.  

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