Enel Green Power in Mudéjar: from 1,844 MW to 406 MW due to EIA — real impact

Key data

The most ambitious renewable project awarded at the Mudéjar 400 kV node has just lost more than three-quarters of its size. The Order TED/1157/2026, published on November 3, 2026, modifies the original 2022 award by which Enel Green Power España obtained 1,202 MW of access capacity at the Mudéjar node. The reason: an unfavorable EIA for one of the seven facilities in the park and restrictive conditions for the rest, issued in February 2026.

For the renewable sector and for the local administrations of Teruel and Zaragoza, the consequences are immediate and quantifiable. This is not a minor technical adjustment: it is a structural reduction that affects jobs, investments, and the territorial development model linked to just transition.

What does this regulation establish?

Order TED/1157/2026 modifies Order TED/1146/2022, which resolved the public tender called by Order TED/1182/2021 to award access capacity at the just transition node Mudéjar 400 kV. Enel Green Power España was the awardee of 1,202 MW for a set of seven facilities with a total installed capacity of 1,844 MW.

The EIA issued in February 2026 was unfavorable for one of the seven facilities and conditioned the development of the rest, which forced a complete project redesign. The modification establishes the new binding parameters:

All socioeconomic commitments have been reduced proportionally to the new capacity. The final guarantee is partially cancelled by €172.5 M, maintaining only the portion corresponding to the 264.9 MW that continue forward.

Economic and operational impact

The impact on the local economy of Teruel and Zaragoza is direct and quantifiable. The investment committed in local value chain goes from €1,541 M to €339.6 M, representing a loss of €1,201.4 M in economic activity planned for the region. In terms of employment, the project goes from generating 321 direct full-time equivalent (FTE) jobs in operation to only 71 FTE, a reduction of 250 stable jobs.

For Enel Green Power España, the partial cancellation of the final guarantee by €172.5 M releases capital, but also reduces the project scope and expected future electricity generation revenues. The company maintains the project active with the 264.9 MW of access capacity that passed environmental evaluation.

From the renewable sector perspective, this case demonstrates that an unfavorable EIA — even for just one facility within a multi-facility project — can trigger a cascading review of all awarded commitments, including financial and socioeconomic ones.

Who does it affect?

• Enel Green Power España: holder of the award, must adapt its project planning, financing, and contractual commitments to the new parameters.
• Aragon Administration (Teruel and Zaragoza): expectations for economic development linked to just transition are drastically reduced in terms of employment and local investment.
• Local value chain companies: suppliers, construction firms, and service companies that counted on contracts or expectations derived from the original project see their business potential reduced.
• Other renewable promoters with projects awarded at just transition nodes: this precedent directly affects them, as it demonstrates that commitments acquired in the tender can be revised downward if the EIA is unfavorable.
• Investors and financiers of renewable projects in Spain: must incorporate the risk of unfavorable EIA as a variable in their valuation models and due diligence.
• Red Eléctrica / REE: the reduction in access capacity at the Mudéjar node affects the planning of the transmission network in the area.

Practical example

A renewable promoter competing in a future access capacity tender at a just transition node and offering socioeconomic commitments of, for example, €500 M in local investment and 100 FTE in operation must now calculate their bid assuming that an unfavorable EIA can reduce those commitments proportionally.

Applying the reduction ratio from the Mudéjar case (approximately 78%), if one of its facilities receives an unfavorable EIA and the rest is conditioned, the commitments could end up around €110 M in local investment and 22 FTE in operation. The final guarantee provided would be partially cancelled in the same proportion, releasing capital but also reducing the project irreversibly.

This scenario requires promoters to design projects with greater environmental resilience from the tender phase, prioritizing facilities with lower risk of unfavorable EIA even if it means bidding for less capacity.

What should companies do now?

1. Review current commitments in just transition node tenders: if you have awarded projects with socioeconomic commitments, analyze whether your EIA is pending and what real risk exists of conditioning or unfavorable outcome.
2. Update financial models with capacity reduction scenarios: incorporate a 50-80% capacity reduction scenario as a risk variable in your revenue projections and return on investment.
3. Review final guarantees provided: if your project could be affected by an EIA, identify what portion of the guarantee would remain in force and what could be cancelled, to optimize cash management.
4. Communicate the Mudéjar precedent to investors and financiers: this case should be incorporated into risk documents for any renewable project in Spain that is in financing or refinancing phase.
5. Evaluate the impact on local value chain contracts: if you have agreements with suppliers or territorial commitments linked to awarded capacity, review adjustment clauses before an EIA forces you to renegotiate under unfavorable conditions.

Official source

Consult complete regulation at official source

Disclaimer: 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-2026-23086