Key data
| Regulation | Resolution of July 20, 2026, from the Directorate General for Energy Policy and Mines |
|---|---|
| BOE Publication | August 13, 2026 |
| Effective date | August 13, 2026 |
| Affected developer | Solaria Promoción y Desarrollo Fotovoltaico, SLU |
| Denied project | Carina Solar 9 — 49.4 MW photovoltaic plant in Toledo province |
| Reason for denial | Expiration of access and connection permits to the Lucero 220 kV substation, communicated by Red Eléctrica de España on October 25, 2024 |
| Category | Energy / Renewables |
| Year | 2026 |
A 49.4 MW photovoltaic project with all environmental approvals in order has just been blocked in the final stretch. Not due to environmental problems, not due to neighborhood opposition, but due to the expiration of a technical grid connection permit. The Resolution of July 20, 2026 from the Directorate General for Energy Policy and Mines rejects the application from Solaria Promoción y Desarrollo Fotovoltaico, SLU for the Carina Solar 9 plant, located in Toledo province.
The case illustrates starkly the regulatory risk that threatens renewable projects in advanced processing: the expiration of grid permits can nullify years of work and millions in prior investment, even when all other authorizations are in order.
What does this resolution establish?
The resolution rejects the application for prior administrative authorization and construction administrative authorization for the Carina Solar 9 photovoltaic installation and its evacuation infrastructure. The key milestones of the case are as follows:
- Favorable environmental impact declaration: obtained in February 2023.
- Prior administrative authorization: granted in May 2023.
- Expiration of access and connection permits to the Lucero 220 kV substation: communicated by Red Eléctrica de España (REE) on October 25, 2024.
- Solaria's arguments: the company argued procedural defects in the hearing and requested the reversal of proceedings.
- Final decision: the Administration maintains the denial proposal, considering that the expiration of grid permits is an essential requirement for construction authorization and cannot be remedied through procedural arguments.
Within the Spanish regulatory framework, grid access and connection permits are a sine qua non requirement to obtain construction authorization for a generating facility. Without them, processing cannot advance, regardless of the status of other authorizations.
Economic and operational impact
The economic impact of this denial is twofold: direct and indirect.
Direct impact for Solaria: the Carina Solar 9 project accumulated investments in environmental impact studies, engineering, permit management and administrative processing for at least two years (from before February 2023). All that investment yields no immediate return as the plant cannot be built. Additionally, the connection capacity reserved at the Lucero 220 kV substation is lost, requiring initiation of a new connection point request process if the project is to be relaunched.
Indirect impact for the sector: this case sets a clear precedent. The expiration of grid permits is not a defect that can be remedied through arguments. The Administration confirms that once expired, there is no margin for reversal of proceedings. This increases the operational risk of all projects in processing that have grid permits with approaching expiration dates.
For a 49.4 MW project, the costs of environmental and technical processing prior to construction can easily reach several hundred thousand euros, not counting the opportunity cost of lost generation capacity.
Who does it affect?
- Solaria Promoción y Desarrollo Fotovoltaico, SLU: directly affected as the developer of the denied project.
- Developers of photovoltaic solar plants with projects in advanced processing that have grid access and connection permits approaching expiration.
- Investors and renewable infrastructure funds that have stakes in solar projects in construction authorization phase.
- Legal advisors and energy consultants managing renewable project portfolios in Spain.
- CFOs and financial directors of energy companies with photovoltaic project pipelines, who must review the status of grid permits for each asset.
- Asset managers and due diligence teams in solar project development transactions.
Practical example
The Carina Solar 9 case itself is the most illustrative example available. Solaria obtained in February 2023 the favorable environmental impact declaration and in May 2023 the prior administrative authorization: two high-cost milestones with lengthy processing that are normally interpreted as signals that the project is on track.
However, the access and connection permits to the Lucero 220 kV substation expired on October 25, 2024, before construction authorization could be requested and obtained. When Solaria attempted to defend its position by arguing procedural defects and requesting reversal of the case, the Administration rejected the argument and maintained the denial.
The result: a 49.4 MW project with all environmental approvals in order is paralyzed by an expired technical permit. Any developer with a project in a similar situation—prior authorization granted but construction authorization pending—must immediately verify the validity of their grid permits.
What should developers do now?
- Immediately audit grid access and connection permits for all projects in portfolio: verify expiration dates for each permit and the status of the corresponding construction authorization processing.
- Identify at-risk projects: any project with prior administrative authorization granted but construction authorization pending, and whose grid permits are approaching expiration, should be treated as critical priority.
- Contact Red Eléctrica de España (REE) to learn the exact status of connection permits for each project and explore whether extension or renewal mechanisms exist before expiration.
- Accelerate construction authorization processing in projects with grid permits approaching expiration, prioritizing human and legal resources in those cases.
- Review contracts with investors and partners to identify regulatory risk clauses linked to grid permit expiration, and notify if applicable.
- Consult with specialized energy legal counsel if expiration has already occurred, to assess whether challenge options exist or if it is more efficient to initiate a new connection point request process.
Frequently asked questions
Why is Carina Solar 9 denied if it already had a favorable environmental impact declaration and prior authorization?
Because in Spain, construction authorization for a generating plant requires, as an essential requirement, valid grid access and connection permits. The Carina Solar 9 permits for connection to the Lucero 220 kV substation expired on October 25, 2024, according to Red Eléctrica de España communication. Without that permit, the Directorate General for Energy Policy and Mines cannot grant construction authorization, regardless of the status of other authorizations.
Can Solaria appeal the denial of Carina Solar 9?
The resolution records that Solaria already argued procedural defects in the hearing and requested reversal of proceedings, arguments that the Administration rejected while maintaining the denial proposal. The resolution was published in the BOE on August 13, 2026. Solaria could file administrative or contentious-administrative appeals, but the Administration's position is clear: the expiration of grid permits is an insurmountable obstacle in ordinary administrative proceedings.
What happens if grid connection permits expire before obtaining construction authorization?
As this case confirms, the expiration of access and connection permits prevents obtaining construction authorization. The developer loses the capacity reservation at the connection point (in this case, the Lucero 220 kV substation) and must initiate a new request process with the grid operator, with the timelines and uncertainty that entails. All prior investment in environmental and administrative processing does not disappear legally, but the project is paralyzed until new grid permits are obtained.
How can I know if my grid connection permits are approaching expiration?
Access and connection permits are granted by the transmission network operator (Red Eléctrica de España, REE) or by distributors, depending on the voltage level. Expiration dates are stated in the permit grant resolution. It is advisable to review directly with REE or the corresponding distributor the status of each permit, especially if the project has been in processing for more than two years without obtaining construction authorization.
Does this resolution affect only Solaria or is it a precedent for other developers?
The resolution directly affects Solaria Promoción y Desarrollo Fotovoltaico, SLU and the Carina Solar 9 project (49.4 MW, Toledo). However, it establishes a relevant regulatory precedent for all solar plant developers in processing: the Administration confirms that the expiration of grid permits is not remediable through procedural arguments and that reversal of proceedings does not apply in these cases. Any developer with projects in a similar situation must act preventively.
Official source
Consult complete regulation at official source (BOE-A-2026-17718)
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-2026-17718