Iberdrola loses 43.89 MW solar in Soria: keys to renewable regulatory risk

Key data

A 43.89 MW project that was to be hybridized with an already operational 44 MW wind farm in Soria has just been permanently blocked. Not due to neighborhood opposition, not due to lack of solar resource, but due to a procedural failure: the environmental impact assessment (EIA) did not arrive on time.

The Resolution of September 9, 2026 from the Directorate General of Energy Policy and Mines, published in the BOE on October 16, 2026, dismisses the application by Iberdrola Renovables Castilla y León, SA, for prior administrative authorization and construction of the Ventosa del Ducado photovoltaic installation. The reason is clear and leaves no room for interpretation: the access and connection permits to the Almazán 400 kV substation of Red Eléctrica expired on May 10, 2026.

What does this resolution establish?

The resolution denies prior administrative authorization and administrative construction authorization for the Ventosa del Ducado photovoltaic plant. The project intended to hybridize the new solar installation with the homonymous wind farm already in operation (44 MW), sharing the connection point to the Almazán 400 kV substation managed by Red Eléctrica.

The chain of causes leading to the denial is as follows:

• The RDL 23/2020 establishes a maximum deadline for obtaining the environmental impact assessment (EIA) as a condition for maintaining valid access and connection permits to the grid.
• Iberdrola Renovables Castilla y León did not obtain the EIA within that deadline.
• As a consequence, the access and connection permits to the Almazán 400 kV substation expired on May 10, 2026.
• The Law 24/2013 on the Electricity Sector expressly prohibits granting administrative authorization to a project that does not have valid access and connection permits.
• Iberdrola did not respond to the hearing procedure prior to the denial resolution, which means it did not submit objections or additional documentation.

The result is a firm denial resolution. There is no possibility of remediation: the permits are already expired and the project cannot continue under this procedure.

Economic and operational impact

For Iberdrola Renovables Castilla y León, the loss is twofold. On one hand, connection rights already granted for 43.89 MW at a 400 kV node are lost, a scarce and high-value asset in the Spanish renewable market. On the other, all investment in project processing is lost: technical studies, engineering, administrative fees, and dedicated team time over years.

For the renewable sector in general, the impact is regulatory and risk management in nature:

• Access and connection permits have expiration deadlines linked to procedural milestones, especially obtaining the EIA.
• A delay in environmental processing, even if beyond the developer's control, can cause irreversible loss of the connection point.
• Solar-wind hybridization, an increasingly widespread strategy to optimize existing infrastructure, is exposed to the same risk if the EIA is not obtained on time.

Who does it affect?

• Developers of photovoltaic and wind projects with valid access and connection permits who have not yet obtained the EIA.
• Companies processing solar-wind or solar-storage hybridization projects under the same connection point.
• Investment funds and financiers of renewable projects in the administrative processing phase.
• Legal advisors and energy consultants managing project portfolios with access permits in different phases.
• Business development management for renewable energy in utilities and independent power producers (IPPs).

Practical example

The Iberdrola case itself is the most illustrative example. The company had access and connection permits granted to connect 43.89 MW photovoltaic to the Almazán 400 kV substation, leveraging the infrastructure of the Ventosa del Ducado wind farm (44 MW) already operating in Miño de Medinaceli (Soria).

The hybridization strategy makes technical and economic sense: the connection point is shared, the generation curve is optimized by combining wind and solar production, and investment in evacuation infrastructure is reduced. However, environmental processing did not advance at the pace necessary to keep the access permits alive.

On May 10, 2026, without the EIA obtained, the permits automatically expired by application of RDL 23/2020. When the Directorate General of Energy Policy and Mines initiated the hearing procedure prior to denial, Iberdrola did not submit objections. The denial resolution was inevitable: without valid access permits, Law 24/2013 does not allow granting authorization. The project is blocked and connection rights are lost.

What should developers do now?

1. Audit the status of all access and connection permits in portfolio: identify the expiration date of each permit and the procedural milestone that keeps them valid (especially the EIA).
2. Verify compliance with RDL 23/2020 deadlines: check whether each project has obtained the EIA within the required deadline or if there is imminent risk of expiration.
3. Establish early alerts on environmental processing: obtaining the EIA does not depend solely on the developer, but it is the developer's responsibility to actively monitor and, if there is risk of delay, act before permits expire.
4. Always respond to hearing procedures: in this case, Iberdrola did not respond to the hearing procedure prior to denial. Although the outcome would probably have been the same, not responding closes any possibility of alleging mitigating circumstances or requesting alternative measures.
5. Review hybridization strategy: solar-wind or solar-storage hybridization projects should be treated with the same procedural diligence as a new project, as they share the same risks of permit expiration.
6. Consult with specialized advisors in energy regulation if there are doubts about the status of permits or applicable deadlines under RDL 23/2020 and Law 24/2013.

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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-2026-21604