Response to the public consultation of the European Commission concerning the EU initiative for renewable energy projects – permit-granting processes & power purchase agreements (12 April 2022) and call for adequate amendments under the current legislative debate concerning the amendments to the renewable Energy Directive (RED III Process)

EREF is the European federation of national renewable energy associations from across EU Members States representing all renewable energy sectors. Since more than 20 years, the federation defends the interests of independent power, fuel and heating and cooling-production from renewable sources and promotes nondiscriminatory access to the energy market. EREF strives to create, maintain and further develop stable and reliable framework conditions for renewable energy sources, strongly advocating for the full decarbonisation of the European energy systems and markets, which need to be transformed and based on 100% more decentralized generation from all renewable sources.


EREF supports this EU Commission’s initiative that an „EU level guidance is needed to highlight the most pervasive permit-related and administrative barriers to renewable energy projects as well as general challenges in the transposition of the relevant articles of the Renewable Energy Directive, and to showcase corresponding examples of good practice”. There is indeed „a need to highlight the remaining obstacles preventing PPAs from reaching their full potential to deliver additional renewables generation capacity, and to provide good practice examples/solutions in this regard”


Permit-granting processes and administrative procedures can be regarded as the biggest bottlenecks for a fast and large-scale renewable energy development in the EU.


We do have several comments and would like to encourage the Commission to integrate them in its planned guidance document. EREF will focus on the first part, the permit granting processes. EREF is convinced that the setup of this guidance document needs to go hand in hand with further efforts the EU institutions need to do under the current legislative procedures, e.g., the REDIII debate. We furthermore call for more flexibly under the CEEAG rules.

Full text can be found in attached PDF.

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