23 February 2024

EREF welcomes the plans to accelerate and simplify permit granting procedures for
renewable energy development, as foreseen in the amended Renewable Energy
Directive (REDIII).

Embedding the interim measures of last year’s Emergency Regulation into the
Renewable Energy Directive will fast-track new installations and related network
expansion, which are now of overriding public interest and should significantly reduce
lengthy and burdensome procedures for project developers, investors, producers as
well as network operators. Under the new rules following the RED III, Member States
will have to introduce shorter procedural deadlines and designate acceleration areas.
Previously designated areas can be exempt from repeated environmental
assessments when installing new plants as well as repowering can be carried out with
environmental impact assessments limited to the change to the original project.

Article 15c RED III foresees the designation of renewables acceleration areas of low
environmental risks by national authorities until end of February 2026. The Directive
gives Member States the possibility to exclude biomass and hydropower from these

With climate change progressing faster than envisaged, decarbonisation of our
societies and industries must take place much faster. And for this ambitious task and
to reach greater energy independency, EREF underlines that all renewable energy
technologies must be used.

As introduction of our proposals for a good guidance document we would like to
emphasize upfront, that acceleration areas have to be open to and for all renewable
energy sources. The guidance document should not discriminatorily focus only on
onshore and offshore wind and solar projects.

It is equally important that the guidance document should enable Member States to
broaden the scope of renewables acceleration areas with renewable energy sources
needed for the provision of sustainable heating and cooling.

Concerning our input for a good guidance by the EU Commission to the Member
States, EREF recalls that already the previous RES Directive (EU) 2018/2001
strengthened both bioenergy and hydropower as technologies both complying with the
strict conditions under EU and national legislation on nature and water protection. The
potential exclusion of individual renewable energy technologies from the acceleration
areas would go against the original purpose of this Directive, namely, to promote
renewable energies. Such an exclusion would also expropriate an important local and
regional contribution towards the energy system transformation towards a 100%
renewable energy-based society. It would be a systemic error to discriminate some
renewable energy technologies “cum grano salis” and to undervalue their important
social and environmental benefit for the local integrated system change, also under
the current acceleration quest.

Due to latest innovative technical solutions, small hydropower and good ecological
status of a river can go hand in hand harmoniously.

The Guidance document needs to clarify that hydropower is not a threat to the
ecological status of rivers if ecological requirements are met, e.g., sufficient
environmental flows (minimum water flows) and fish migration aids. Ecological
monitoring of watercourses very often reveals stretches of water used for power
generation where there is not only a minimal difference to the unused stretches but a
specific biodiversity resilient to draught.

The application of overriding public interest by the Member States must not
discriminate between hydroelectric power plants according to their size, de facto
excluding the smallest ones, since most of them will not have the means to finance
the additional studies generated by their failure to recognize the major public interest
of their projects. Small hydropower provides major positive environmental externals
such as groundwater recharge, biodiversity reserve and flood protection. The
European small hydropower industry is regarded as world leader, offering the
complete range of technical solutions which comply with even the strictest
environmental laws and regulations. This should be echoed in the guidance document
– also in view of Europe’s Net Zero industry ambition.

Around 25,000 small hydropower plants provide annually 13 million households in the
EU with electricity and contribute already to the EU’s decarbonization by saving CO2
emissions from energy production.

The guidance needs to underline the contribution of small hydro to grid stability,
providing security of supply and black start capability. A recent assessment on
potential of small and micro hydropower in the EU estimates an additional yearly
production of 79 TWh of green electricity feasible – under the strictest environmental
constraints.1 Small hydropower can therefore make an important contribution to
achieving the REPowerEU objectives to increase Europe’s energy independence and to
speed up its decarbonisation.

All Member States should plan acceleration areas to support the construction of new
hydroelectric plants at already existing dams and the modernization and repowering of
existing hydroelectric power plants, provided a sustainable hydropower use is ensured.
In this way, the Member States can develop and utilize the potential of hydropower to
remain a significant and sustainable contributor within the renewable energy family
towards the replacement of fossil and nuclear power plants.

Examples of potential sites for acceleration areas include existing transverse
structures that are not passable for fish. According to the Water Framework Directive
(WFD), river continuity must be achieved by 2027. Designating these areas as
acceleration zones would speed up the process and facilitate implementation.

The inclusion of bioenergy into the designation of acceleration areas is equally crucial.
Scientific evidence demonstrates that biogas- and biomethane production can bring
positive externalities including economic, social, and environmental benefits. Biogas and
Biomethane projects contribute to cost savings, greenhouse gas emission reductions,
creation of jobs and improved waste management.2 On biogas and biomethane, EREF
would like to request that the Guidance Document addresses the following:

The biogas and biomethane sector holds immense potential to deliver new production
capacities once the barriers, such as long permitting times, have been removed: the
main production technology – anaerobic digestion (AD) – is an advanced biological
technology with more than 20,000 production facilities, including more than 1,300
facilities producing biomethane. A further advantage is that these processes are based
on a European supply chain, thus contributing to resilience by reducing resource
dependency from third countries. Moreover, the sector benefits from a rich availability
of sustainable feedstock, including in the areas identified in the RED III, with the main
feedstock potential for AD in 2030 coming from manure, agricultural residues, and
industrial wastewater.

The renewable acceleration areas for biogas and biomethane should be mapped and
assessed at a local level based on those zones with abundant sustainable feedstock
availability and developed gas infrastructure, so that the injection into the gas grid of
future production projects will likely to be technically feasible and economically
reasonable. The introduction of a zoning approach with areas where biogas and
biomethane production gets prioritised is essential for the improvement of the
permitting process: in these areas aimed at fostering sustainable biomethane, the
permitting process is expected to be faster. In addition, the Guidance should
recommend cooperation of national authorities with gas grid operators to carry out
this mapping exercise accurately. Facilitating collaboration between local authorities,
Member States, TSOs and DSOs is essential for mapping biomethane production
potential and the current gas grid infrastructure. Furthermore, administration and
permitting officers should be provided with the necessary guidance to grasp project
complexity and work in digitalised environments. This is crucial, as there can be a lack
of knowledge of biogas and biomethane production processes within competent
authorities, especially in areas where there are few biogas and biomethane sites and
little experience with the technology.

We strongly recommend to give Member States more guidance in taking renewable
heat projects into account in the designation process.

On mapping of areas for Solar PV, EREF would like to see a specific reflection in the
Guidance document: For solar PV projects, the mapping should be technology-specific
and focused on ground-mounted solar PV installations. Acceleration areas for rooftop
PV do not make sense since these projects are typically already exempted from
environmental impact assessment and take less than one year to be authorised.

The mapping should not lock in limited, rigid zones for renewable energy development.
Instead, the mapping should identify favourable zones with potential for PV
development (preferably ground-mounted) that equate to higher than the national
solar targets. Contrary to other technologies such as wind, the purpose of the mapping
should not be to concentrate projects in strictly delimited areas. Since solar PV
projects are adaptable and versatile by nature, they should therefore benefit from a
different approach.

The quest for more wind energy: The Guidance Document should ensure transparency
and clarity especially also in view of goals to be achieved. When identifying and
designating renewable acceleration areas for wind, it’s crucial to base the selection on
specific and transparent criteria. Member States’ mapping of renewable deployment
areas should align with the EU’s 2050 Climate & Energy goals, focusing on carbon
neutrality beyond just the 2030 objectives. Once acceleration areas have been
established, adding new ones could prove to be challenging. Member States should
act on the opportunity as mentioned above to use Article 15 c paragraph 4 to expedite
permitting processes. Converting existing designated suitable wind energy areas into
acceleration areas could significantly speed up permitting for wind energy.

When designating optimal onshore wind areas, precision is key and needs to be
ensured by the Guidance Document. However, we urge to not limit the application of
renewable acceleration areas only to specific areas such as degraded land. In
Germany, many older turbines will be ready for repowering in areas where the
environmental status-quo might have changed over time. Acceleration areas would be
the legal tool for easier repowering in those cases. Therefore, we caution not to set any
more regulations on top of the ones laid out in the directive limiting this ability. This
ensures that Member States can designate a significant size of renewables
acceleration areas to fulfil their respective renewable energy deployment goals by

Moreover, designating renewable acceleration areas should not increase bureaucratic
procedures even further, but should further reduce the necessary efforts. This could
otherwise lead to even slower permitting. There is already a need for qualified
permitting staff at the national level.

The role of spatial planning is to support renewable energy project development by
creating extra facilitated zones for deployment, engaging local authorities at an early
stage, and providing developers with the right level of information regarding both the
development potential and site constraints. However, the expertise of project
developers should be recognised when defining sites for renewable energy projects:
they have a valuable know-how in siting projects and are already working with local
authorities on the issue of public acceptance. The role of national authorities should
therefore be separate from that of project developers.

All relevant information must be freely and publicly available in a usable format (e.g.
The renewables mapping should be used to provide information to public
authorities and project developers on the availability of renewable resources, the
status of land, biodiversity sensitivities, as well as of the presence of grid

The whole exercise, and in particular the methodology and key criteria for the
designation of favourable areas and renewable acceleration areas, needs to be
coordinated at national level or higher, rules need to be established in the Guidance
We cannot rely only on local authorities alone. This would risk resulting in
different methodologies being used and arbitrary decision at local level. The Guidance
Document should also ask Member States, when designating a renewable acceleration
area, to specify why renewable energy projects in this area are not expected to have
significant environmental impact and, accordingly, what should be the scope of the
screening at project level, in particular what would be “highly likely to give rise to
significant unforeseen adverse effects in view of the environmental sensitivity of the
geographical areas”.

Finally, the Guidance Document should emphasise that the designation of acceleration
areas for renewable energy projects must not result in renewable energy projects not
being approved elsewhere or in the permitting process being made more difficult
outside the acceleration areas than it is today.

In concluding we would also encourage the Commission to guide on some specific
measures, regarding inter alia broader spatial planning considerations, land use,
stakeholder engagement and public participation which could focus on issues such as:

To encourage Member States to designate areas where supply, storage and demand
of renewable energy are co-located.
Think of ports, industrial clusters, and areas where
new technologies can easily be deployed next to existing projects, which are already
operational. Also encourage Member States to provide for dedicated administrative
teams from the central and local authorities to speed up permitting processes in each
acceleration area.

To examine within each Member State how political decision-making from the
authorities who have to decide on granting permits of energy generation or energy
infrastructure projects can be accelerated. This may allow issues to be dealt with more
quickly. Examples such as the establishment of specific councils or state committees
in the field of energy generation or energy infrastructure can be included in the
evaluation study.

To create an infrastructure (i.e. data safe houses) to help Member States facilitating
more efficient sharing of information between industries, grid operators and
authorities within renewables acceleration areas. The regulation for competition within
the European Union has to enable this sharing of information.

To establish in the guidelines a regular event to share best practices with and between
Member States in speeding op the development of projects and permitting processes
within acceleration areas. Start every project with a joint project organization, staffing,
governance, planning etc.. Part of this is also a public participation plan, in which it
becomes clear which stakeholders are involved in each phase of a project.

1 Quaranta, E., Bódis, K., Kasiulis, E., McNabola, A., & Pistocchi, A. (2022). Is there a residual and hidden
potential for small and micro hydropower in Europe? A screening-level regional assessment. Water
Resources Management, 36(6), 1745-1762.
2 Gas for Climate, Manual for National Biomethane Strategy, 2022, p. 7.

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