ISF A Gudiña Solar Park (60 MW): Denied Due to Permit Expiration in 2026

Key data

A photovoltaic project of 60.72 MW in the province of Ourense is definitively cancelled. The General Directorate of Energy Policy and Mines has rejected the application from Amber Solar Power Veintinueve, SL to build the «ISF A Gudiña Solar» park, through a resolution published on June 27, 2026 in the BOE (BOE-A-2026-13996). The reason is not technical or environmental: it is the expiration of grid permits due to failure to meet an administrative milestone on time.

What does this resolution establish?

The resolution rejects the application for prior administrative authorization, administrative construction authorization, and declaration of public utility for part of the evacuation infrastructure of the «ISF A Gudiña Solar» photovoltaic park.

The root cause is the expiration of access and connection permits to the transmission grid, which occurred on December 18, 2024. According to the Royal Decree-Law 23/2020, renewable installation developers must demonstrate a series of administrative milestones to keep their grid permits valid. The fourth milestone requires having obtained administrative construction authorization before that date. Amber Solar Power Veintinueve, SL failed to demonstrate this.

The determining factor that blocked the advancement of the file was the action of the CNMC (National Commission for Markets and Competition), which issued three consecutive negative reports on the economic-financial capacity of the developer. Without a favorable report from the CNMC, the procedure could not advance to construction authorization, making it impossible to meet the milestone on time.

The developer argued delays in issuing mandatory reports and claimed to have acted diligently, but these arguments were not considered sufficient to reverse the resolution.

Economic and operational impact

The economic consequences for Amber Solar Power Veintinueve, SL are immediate and severe:

• Total loss of access and connection permits to the transmission grid, which are the most valuable asset in the processing phase of a renewable project.
• Impossibility of resuming the project without initiating a new complete procedure, which means returning to the beginning of the grid access queue, with the associated costs and timelines.
• Loss of all investment made in processing: impact studies, engineering, administrative fees, economic guarantee, and accumulated legal costs over years of proceedings.
• The project of 60.72 MW represents a potential investment of tens of millions of euros that remains indefinitely blocked.

For the sector in general, this resolution reinforces a clear message: the economic-financial soundness of the developer is as critical as the technical viability of the project. A negative report from the CNMC can be fatal to the file if it blocks advancement to the corresponding milestone.

Who does it affect?

• Amber Solar Power Veintinueve, SL: developer directly affected by the definitive denial.
• Renewable energy developers with photovoltaic or wind projects in processing under the RDL 23/2020 regime, especially those approaching administrative milestone deadline dates.
• Investors and funds participating in renewable developer vehicles with valid grid permits, who must verify the status of milestone accreditation.
• Legal advisors and energy processing consultants managing files before the General Directorate of Energy Policy and Mines.
• Financing entities (banks, debt funds) that evaluate the viability of renewable projects in development phase: the economic-financial capacity of the developer is now an explicit and documented risk.

Practical example

Imagine a developer with a 50 MW solar park in processing, with grid access permits obtained in 2022. The fourth milestone of RDL 23/2020 requires demonstrating administrative construction authorization before the assigned deadline.

During the process, the CNMC requests documentation on the economic-financial capacity of the developer. If the developer does not provide sufficient guarantees and the CNMC issues a first negative report, the file becomes paralyzed. If this repeats with a second and third negative report —as happened in the case of Amber Solar Power Veintinueve, SL with «ISF A Gudiña Solar»— the procedure cannot advance to construction authorization.

If the milestone deadline arrives without construction authorization being obtained, the grid permits automatically expire, as occurred on December 18, 2024 in this case. The result: total loss of the project and need to start from scratch, competing again for grid capacity in a market with high demand.

What should companies do now?

1. Audit the status of milestones for all projects in portfolio: review which RDL 23/2020 milestones are pending and what are the accreditation deadline dates for each file.
2. Verify the validity of access and connection permits: confirm with Red Eléctrica de España (REE) or the corresponding grid operator that permits have not expired or are not at imminent risk.
3. Prepare economic-financial capacity documentation in advance: given that the CNMC may request this accreditation and issue negative reports that paralyze the file, have robust financial documentation ready before it is required.
4. Consult with specialized energy processing advisors if there is risk of not meeting any milestone on time, to explore extension options or well-founded arguments before expiration occurs.
5. Evaluate the viability of restarting the procedure if permits have already expired: analyze the cost-benefit of a new file against the project value, considering current grid access timelines.

Official source

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Notice: This article is purely informational in nature 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-2026-13996