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REPOTEN 2 Environmental Permitting: Keys to Meeting 2030 Deadlines

10/6/26
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Rosario Hernández
Head of Knowledge
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Environmental Permitting: Deadlines, Required Documentation, and Steps to Secure Funding Before 2030

A new boost for the renewal of Spain's renewable energy fleet

On May 22, 2026, the Ministry for Ecological Transition and Demographic Challenge (MITECO) published the provisional resolution proposal for the second call of the CIRCULAR REPOWERING program (REPOTEN 2). It selects 149 projects — 80 for wind modernization and 69 for the renovation of hydroelectric facilities up to 50 MW — distributed across 16 autonomous communities, with a budget of 512 million euros from NextGenEU funds.
The territorial distribution largely reflects the historical map of renewable energies in Spain. Galicia leads the list with 35 projects — 25 in wind farms and 10 in hydroelectric plants — followed by Andalusia and Castilla y León, with 24 projects each. These three communities account for 55% of all selected actions. The rest are distributed across almost the entire national territory, with the sole exception of the Balearic Islands.
The actions must be completed before June 30, 2030, with the possibility of extension until the end of that year. This timeframe, which at first glance seems ample, narrows considerably when the actual deadlines for environmental processing are taken into account.

Why environmental processing is not the last step, but the first

One of the most common mistakes in these types of projects is to address the environmental assessment when the engineering is already finalized. In repowering projects, this can be particularly costly: any adjustment in the layout of wind turbines, the design of access roads, or the location of auxiliary infrastructure resulting from the EIA process may require redesigning already developed technical solutions.
Initiating environmental processing in parallel with the project — not after — is the most efficient decision, both in terms of timelines and costs.

Environmental factors that make a difference in repowering

Repowering is not a new installation, but neither is it a simple equipment upgrade. From an environmental perspective, it involves:

Fauna and habitat assessment. Replacing old wind turbines with larger machines and different rotational dynamics alters the risks to avifauna and bats. It is necessary to update flight and collision studies, incorporating updated methodologies and, where appropriate, automatic detection and shutdown systems. In territories like Galicia or Castilla y León, with a high density of wind farms in migratory corridors or near Natura 2000 sites, this analysis requires particular rigor.

Illustration 1. Goldfinches and Linnets. Source: Ideas Medioambientales.

Archaeological and cultural heritage. Earthworks associated with the adaptation of roads, assembly platforms, or cabling trenches require prior archaeological prospecting and potential monitoring during execution. Galicia, with one of Europe's highest densities of archaeological heritage — petroglyphs, hillforts, megalithic necropolises — represents a paradigmatic case where this factor can lead to significant route modifications or corrective measures. Andalusia, for its part, presents an equally complex situation in mountainous areas or locations with superimposed historical cultures.
Landscape integration. Although repowering reduces the number of wind turbines — in the first REPOTEN call, each new machine replaced approximately seven old ones — the increase in height and visual impact demands a review of the landscape impact analysis, especially in protected areas or those with high perceptual value. In Castilla y León, with extensive visual basins and natural parks surrounding many wind farm sites, this factor carries specific weight in the evaluation.
Ecological flows and river continuity in hydropower. In the case of hydroelectric facilities, modernization offers the opportunity — and in many cases the obligation — to incorporate environmental improvements that MITECO considers a valuable criterion: fish passages, systems to guarantee minimum ecological flow, and restoration of habitats associated with the river section. Galicia and Castilla y León, which concentrate most of the 69 selected hydroelectric projects, have rivers of high ecological value, where these requirements are particularly relevant.

Social license: the most underestimated factor

Administrative processing can be managed. Timelines can be planned. What is harder to recover is the trust of local communities when it has not been properly managed from the outset.
In locations with a long history of wind or hydroelectric operation — as is the case in many of the territories featured in this call — there is accumulated social capital, positive or negative, that should be evaluated before initiating any participatory process. Identifying key stakeholders, anticipating potential conflict areas, and designing an honest communication strategy adapted to the territory are actions that have a very low cost compared to the delays that unmanaged local opposition can generate.

Illustration 2. Citizen participation in projects. Source: Ideas Medioambientales.

The importance of planning

The final resolution of REPOTEN 2 is expected to arrive throughout 2026. From then on, processing the project, developing the engineering, and obtaining all necessary authorizations takes time — for projects of this scale, usually more than two years. Thus, to ensure execution before the 2030 deadline, works would have to begin, at the latest, in 2028. This is why coordinating the environmental process from now on can make all the difference.

Let's talk about your project

If you have a wind farm or a hydroelectric facility that falls within the scope of REPOTEN 2, or if you are considering applying for future calls, Ideas Medioambientales can help you plan the environmental processing with sufficient anticipation to avoid compromising deadlines.

At Ideas Medioambientales, we support developers throughout the entire cycle of environmental, archaeological, and social processing for repowering projects, from preliminary phases to obtaining authorizations:

• Pre-feasibility or preliminary viability studies, with the possibility of analyzing historical data associated with the repowering project.
• Environmental impact studies and coordination with the competent environmental authority.
• Impact studies on Historical-Artistic and Archaeological Heritage and coordination with the competent authority.
• Archaeological prospecting and monitoring during construction.
• Fauna studies (avifauna, chiropterans, herpetofauna), with protocols adapted to current requirements.
• Botanical studies and studies of habitats of community interest.
• Landscape integration analysis.
• Social impact studies and public participation and social license processes.
• Coordination with water authorities on hydroelectric projects.
• Environmental monitoring and surveillance during construction and operation.

Figure 3. Vegetation census. Source: Ideas Medioambientales.

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