On 14 July 2025, the Directorate-General for Energy and Geology (DGEG) published an explanatory note clarifying the arrangements applicable to the refitting of renewable power stations, in particular wind power. Refitting consists of the total or partial replacement of the generating equipment of a renewable power station, without altering its location, as defined in Article 3 of Decree-Law 15/2022 of 14 January, in its current wording.
With regard to electrical licensing, the DGEG explanatory note clarifies that refitting does not require a new prior checking procedure. Only the following are required:
- Endorsement to the existing permission, if the application is made between the production licence/prior registration and the operating licence/certificate;
- Change to the existing permission, if the application is made after the issue of the operating licence/certificate.
In terms of environmental licensing, the refitting of primary solar or wind power projects is exempt from prior assessment and decision on whether to subject them to an environmental impact assessment (EIA). For wind power projects, the DGEG clarified that the following are considered refitting – and, therefore exempt from EIA and case-by-case analysis – cases in which all ground-level infrastructure is contained within a 150-metre strip on either side of an imaginary line connecting the centre of all wind turbines to the wind farm substation (or each cluster, if applicable).
