Key data
| Regulation | Resolution of September 9, 2026, from the General Directorate of Energy Policy and Mines |
|---|---|
| BOE Publication | October 20, 2026 |
| Effective date | October 20, 2026 |
| Affected developer | Iberenova Promociones, SA |
| Denied project | Los Campillos photovoltaic facility (hybridization with Los Campillos wind farm) |
| Requested photovoltaic capacity | 33,825 MW |
| Associated wind farm capacity | 34 MW |
| Location | Province of Soria |
| Connection substation | Almazán 400 kV (transmission network) |
| Grid permit expiration date | May 10, 2026 |
| Regulation governing deadlines | Royal Decree-Law 23/2020 |
| Regulation preventing authorization without permits | Law 24/2013 on the Electricity Sector |
| Category | Energy |
A large-scale solar-wind hybridization project has just lost its authorization in Spain, not for technical or environmental reasons, but due to a failure in managing administrative deadlines. The Resolution of September 9, 2026, from the General Directorate of Energy Policy and Mines rejects the application from Iberenova Promociones, SA to build the Los Campillos photovoltaic facility, with a capacity of 33,825 MW, intended to hybridize with the Los Campillos wind farm, with a capacity of 34 MW, in the province of Soria.
The cause is clear and irreversible: the access and connection permits to the transmission network at the Almazán 400 kV substation expired on May 10, 2026. The reason for this expiration was failure to obtain the environmental impact statement within the deadline required by the Royal Decree-Law 23/2020. Without those valid permits, the Law 24/2013 on the Electricity Sector expressly prohibits granting the prior administrative authorization and construction authorization.
What does this resolution establish?
The resolution rejects the application for prior administrative authorization and construction authorization submitted by Iberenova Promociones. The project consisted of a 33,825 MW photovoltaic facility that would hybridize with the Los Campillos wind farm (34 MW already in operation), using the same connection point to the transmission network at the Almazán 400 kV substation.
The processing of the case was particularly complex, with the following relevant milestones:
- Attempts to process the project through simplified environmental assessment, which were archived.
- Process of accumulation and subsequent separation of related cases.
- Request for suspension of the public utility declaration.
- Failure to meet the deadline to obtain the environmental impact statement required by RDL 23/2020, which caused automatic expiration of grid permits on May 10, 2026.
- The developer did not respond to the hearing procedure prior to the denial resolution.
The legal framework that determines the outcome is twofold: RDL 23/2020 sets the deadlines for obtaining the environmental impact statement as a condition for maintaining grid permits, and Law 24/2013 establishes that without valid access and connection permits, no administrative authorization can be granted. Both regulations act in a linked manner with no margin for exception.
Economic and operational impact
The loss of authorization means for Iberenova Promociones the definitive cancellation of a project with 33,825 MW of photovoltaic capacity. In terms of investment, a solar project of this scale in Spain typically involves investments of several tens of millions of euros, in addition to costs already incurred in processing, environmental studies, engineering, and permit management over years.
Beyond the specific case, the sectoral impact is significant:
- Irreversible loss of the connection point at the Almazán 400 kV substation, which was assigned at the time and is now released for other developers.
- Impossibility of remedying the expiration of grid permits once it occurs: there is no automatic extension mechanism or rehabilitation procedure.
- Opportunity cost of the Los Campillos wind farm (34 MW), which loses the possibility of hybridization and optimization of its connection point.
- Reputational and financial risk for the developer before investors and project partners.
Who does it affect?
- Iberenova Promociones, SA: direct developer, loses authorization for the Los Campillos photovoltaic project.
- Renewable energy project developers with access and connection permits to the transmission or distribution network in processing.
- Companies with solar-wind or solar-storage hybridization projects that depend on already-assigned connection points.
- Investors and funds with participation in renewable projects in the environmental assessment phase.
- Legal and technical advisors managing authorization proceedings for generation facilities.
- Project developers who have accumulated or separated cases and may have environmental assessment deadlines at risk.
Practical example
The Iberenova case illustrates the risk mechanism with precision. The company had assigned access and connection permits at the Almazán 400 kV substation for a facility of 33,825 MW intended to hybridize with its Los Campillos wind farm of 34 MW. During processing, the project went through simplified environmental assessment (archived), accumulation and separation of cases, and a request for suspension of public utility declaration.
At no point was the environmental impact statement obtained within the deadline required by RDL 23/2020. Result: on May 10, 2026, the grid permits automatically expired. When the General Directorate processed the authorization case, Law 24/2013 left no other way out: without valid permits, no authorization is possible. The developer did not even respond to the hearing procedure.
If another developer with a similarly sized project (for example, 30-40 MW in environmental assessment) does not obtain their environmental impact statement before their grid permits expire, they face exactly the same result: automatic denial with no possibility of remediation.
What should companies do now?
- Audit the status of all valid access and connection permits: verify the expiration dates of each assigned grid permit, both in transmission and distribution networks.
- Cross those dates with the status of environmental processing: identify which projects are at risk of not obtaining the environmental impact statement before their grid permits expire, in accordance with RDL 23/2020 deadlines.
- Prioritize at-risk cases: reallocate technical and legal resources to projects with the smallest time margin between permit expiration and environmental assessment status.
- Review the case accumulation strategy: this case shows that accumulation and subsequent separation can generate delays that compromise grid permit deadlines. Evaluate whether this strategy is advisable in each case.
- Always respond to hearing procedures: Iberenova did not respond to the hearing procedure prior to denial. Participating in this procedure is the last opportunity to provide arguments or documentation before the final resolution.
- Consult with specialized advisors if there are projects with permits close to expiration: expiration is irreversible and does not allow for later remediation.
Frequently asked questions
Why was authorization for Iberenova's solar plant in Soria denied?
The General Directorate of Energy Policy and Mines denied authorization because the access and connection permits to the transmission network at the Almazán 400 kV substation expired on May 10, 2026. The reason for this expiration was failure to obtain the environmental impact statement within the deadline required by RDL 23/2020. Law 24/2013 on the Electricity Sector prevents granting administrative authorization without valid grid permits.
What happens if access and connection permits to the grid expire in a renewable project?
The expiration of access and connection permits is irreversible: there is no automatic extension mechanism or rehabilitation procedure. Without those valid permits, Law 24/2013 prevents the administration from granting the prior administrative authorization and construction authorization, which results in definitive project denial.
What deadline does RDL 23/2020 set for obtaining the environmental impact statement in renewable projects?
Royal Decree-Law 23/2020 establishes specific deadlines for obtaining the environmental impact statement as a condition for maintaining valid access and connection permits to the grid. In the case of Iberenova, failure to meet this deadline caused automatic expiration of permits on May 10, 2026. The specific deadlines applicable to each project depend on its assignment date and type, so it is essential to review the individual case file.
What is solar-wind hybridization and what regulatory risks does it have?
Hybridization consists of adding a photovoltaic facility (in this case, 33,825 MW) to an existing wind farm (34 MW at Los Campillos, Soria) to share the same grid connection point. The main regulatory risk is that grid permits assigned for hybridization have validity periods conditioned on obtaining the environmental impact statement. If this is not obtained in time, the permits expire and the project is permanently blocked.
What is the importance of the hearing procedure prior to a denial resolution?
The hearing procedure is the last opportunity the developer has to provide arguments, documentation, or objections before the administration issues a denial resolution. In the case of Iberenova, the developer did not respond to this procedure, which eliminated any possibility of influencing the outcome. Always responding to hearing procedures is a basic practical obligation in managing administrative cases.
Official source
Consult complete regulation at official source (BOE-A-2026-21854)
Notice: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://www.boe.es/diario_boe/txt.php?id=BOE-A-2026-21854
