Brussels, March/April 2026
Renewable energies — incl. wind, solar, hydropower, bioenergy, geothermal and ocean energy
— are Europe’s most cost-effective, most strategically secure and most rapidly scalable energy
assets. They are the cheapest sources of electricity and heat generation available, and total
system cost of a renewables-based pathway remains substantially lower than any alternative.
Faster permitting and grid connection is how Europe can make this cost advantage available
to its citizens, communities, industries and economy — reducing energy bills, strengthening
supply security and building a resilient, decentralised energy system.
Yet IRENA has explicitly warned that permitting delays and grid bottlenecks are driving up
renewable energy costs in Europe compared to the rest of the world, undermining this
advantage. An estimated €7.2 billion worth of renewable electricity was curtailed in 2024
alone. Removing these barriers is therefore both an economic and a strategic imperative.
EREF strongly supports the Proposal’s objectives. The first priority must be swift, full and
consistent implementation of the permitting improvements agreed under RED III, as delays in
transposition remain and infringement procedures against all Member States are pending. The
Permitting Directive must build on this agreed framework. Beyond that, the current text must
deliver more harmonised implementation and close carve-outs risking national fragmentation.
EREF strongly suggests the co-legislators strengthen the Directive across the following areas:
- Prioritise implementation: reduce the transposition deadline to one year after adoption;
permit-granting provisions must take effect at the earliest possible date. - Make acceleration binding: tacit approval (Art. 16b), no-go area limitation (Art. 15c)
and the overriding public interest presumption (Art. 16f) must be genuine obligations;
broad carve-outs must be closed. - Extend and align the repowering regime: all key renewable technologies must benefit
from exemptions under Art. 16c; land status changes must not unintentionally block
repowering; co-location and hybridisation must be facilitated across all renewable
technologies in acceleration areas. - Binding grid connection timelines: Art. 17 must set clear deadlines; grounds for refusal
must be narrow and objectively defined; system operators must actively propose
alternatives where capacity is constrained. - Proportionate benefit-sharing: harmonised measures strengthening community
benefits are welcomed, but must not duplicate national schemes or burden
independent producers and SMEs; the facilitator must be strictly voluntary and publicly
funded, ensuring meaningful participation without creating additional barriers to small-
and medium-sized producers. - Fix the upstream bottleneck: a binding 12-month deadline for regulatory approval of
network development plans (Art. 40a, Electricity Directive) is essential; without it,
downstream acceleration risks being structurally undermined.
The Permitting Directive must work for all renewable energy producers — independent
producers, SMEs and energy communities as much as large-scale developers — to deliver a
system that is fast, fair and fit for a fully renewables-based Europe. Please find EREF’s detailed
amendment proposals and reasoning in the attachment.
For more information, please contact
Prof. Dr. Dörte Fouquet
Director
doerte.fouquet@eref-europe.org
Dirk Hendricks
Secretary General
dirk.hendricks@eref-europe.org
European Renewable Energies Federation (EREF)
Avenue Marnix 28, 1000 Brussels
+32 2 204 44 00
info@eref-europe.org
www.eref-europe.org