Solar Bordecorex Norte Denied: The Real Risk of Grid Permission Expiration in Renewables

Key data

A project of 44,199 MW photovoltaic in Soria, designed to hybridize with the Bordecorex Norte wind farm (44.35 MW), is eliminated before construction. The Resolution of September 9, 2026 from the General Directorate of Energy Policy and Mines dismisses the request from Biovent Energía, SA, published in the BOE on October 16, 2026.

It is not a denial for technical or substantive environmental reasons: it is a denial due to expiration of grid access and connection permits. A timing problem that, according to the resolution itself, is a frequent bottleneck in the Spanish renewable sector.

What does this resolution establish?

The resolution dismisses the request for prior administrative authorization and construction authorization of the Bordecorex Norte photovoltaic installation. The chain of events leading to this denial is as follows:

• Project: 44,199 MW solar plant to hybridize with the Bordecorex Norte wind farm (44.35 MW) in the province of Soria.
• Planned connection: Almazán 400 kV substation, managed by Red Eléctrica.
• First obstacle: The simplified environmental assessment was filed for not meeting the requirements established by RDL 20/2022.
• Second obstacle (definitive): Access and connection permits to the Almazán 400 kV substation expired on May 10, 2026, as the environmental impact declaration was not obtained within the deadline required by RDL 23/2020.
• Legal consequence: Without valid access and connection permits, current regulations prohibit granting administrative authorization. The resolution has no alternative: it must dismiss.

The regulatory framework applied combines RDL 23/2020 (which sets deadlines for obtaining the environmental impact declaration as a condition to maintain grid permits) and RDL 20/2022 (which establishes additional requirements for simplified environmental assessment). Non-compliance with either deadline triggers automatic loss of connection permits.

Economic and operational impact

The denial of Bordecorex Norte illustrates a systemic risk for the Spanish renewable sector: the desynchronization between grid permit deadlines and environmental procedure deadlines.

Access and connection permits to the grid have limited validity. If the environmental impact assessment (EIA) procedure extends beyond that deadline—something common given the volume of pending cases—grid permits expire and the project is blocked without possibility of authorization, regardless of its technical or environmental viability.

The economic consequences for a promoter in this situation are:

• Loss of all investment made in engineering, environmental studies, and administrative processing.
• Need to restart the grid permit request process from scratch, with new access queues.
• Risk of losing the position at the connection substation, which may have been assigned to other projects.
• Reputational impact with project investors and financiers.

The resolution expressly notes that this type of situation—grid permit expiration due to delays in environmental processing—is a frequent bottleneck in the Spanish renewable sector, indicating that Bordecorex Norte is not an isolated case.

Who does it affect?

• Promoters of photovoltaic projects with valid or soon-to-expire access and connection permits.
• Promoters of hybrid solar-wind projects, where hybridization adds an additional processing layer.
• Investors and renewable infrastructure funds with projects in portfolio in environmental processing phase.
• Legal and technical advisors managing authorization files for renewable installations.
• CFOs and business development directors in energy companies with project pipelines in Spain.
• Financing entities (banks, funds) evaluating regulatory risk of renewable projects in construction phase.

Practical example

The case of Biovent Energía is the real example. The company obtained access and connection permits to connect its 44,199 MW photovoltaic plant to the Almazán 400 kV substation of Red Eléctrica, in the province of Soria. Those permits had a deadline linked to obtaining the environmental impact declaration, according to RDL 23/2020.

In parallel, the simplified environmental assessment was filed for not meeting the requirements of RDL 20/2022, further delaying the procedure. The result: when May 10, 2026 arrived, grid permits expired without an environmental impact declaration existing. From that point on, the General Directorate of Energy Policy and Mines had no legal margin to grant authorization, and the dismissal resolution was inevitable.

A promoter in a similar situation—with grid permits about to expire and EIA in processing—must urgently verify if their deadlines are aligned, or request extensions before expiration occurs.

What should companies do now?

1. Audit the status of all access and connection permits in portfolio: Identify the expiration date of each permit and the status of the associated environmental procedure. Desynchronization between both deadlines is the main risk.
2. Verify compliance with RDL 20/2022 requirements for simplified environmental assessment: Filing of the case for non-compliance with formal requirements, as happened in Bordecorex Norte, can cost critical months of processing.
3. Calculate the real time margin between grid permit expiration and the expected date for obtaining the EIA: If the margin is less than 6 months, activate preventive measures (request for extension, acceleration of environmental case, communication with the competent environmental authority).
4. Review contracts with advisors and case managers: Establish automatic alerts for grid permit expiration and environmental procedure milestones.
5. Inform investors and financiers: If there are projects in portfolio with risk of permit expiration, communicate it proactively with the mitigation plan, before the denial materializes.

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-2026-21603