One interesting area of contention is the level of government where a permitting decision for a renewable energy project sits. Spain is perhaps the greatest example of this, as permitting for projects below 50MW in size take place at the autonomous community level; those over 50MW go to the National Government . In general, proponents feel that it is easier to get approval at the regional level, and as a result, there is a prevalence of projects 49.X MW in size. Whilst this is an interesting phenomenon, it has a couple of negative impacts:
- There is more permitting work pushed onto the regional government, which may have less capacity and technical expertise to manage this effectively. This may result in extended permitting timeframes, or corners being cut, or both.
- Where there is not good visibility between projects being permitted at a Regional and National level (and according to some, there is not), projects can be permitted which exceed the capacity of the transmission line, as neither tier of government was aware of the other.
What this highlights clearly though is that industry will generally choose the path of least resistance – to gain time and cost savings – when undertaking the development process. Where there are opportunities created (e.g. build 3 x 49.9MW solar arrays, rather than 1 x 150MW one) a savvy developer will take full advantage. As scale grows, the trend may be shifting slightly; Iberdrola’s Cedillo solar farm is 375MW in size – and done as a single project. The team who worked on it noted that, as a large company, Iberdrola was comparatively better resourced and able to work through the National government’s approvals process. Even so, the nearby Majada Alta and San Antonio plants are both 49.97MW each.
Interestingly, in Scotland, the same 50MW rule applies to onshore wind (anything over 50MW is a UK Government decision). This, however, does not appear to have had the same impact as it has in Spain – which suggests that the process of working through the local authority confers little advantage to going through the central government.
This is a good lesson for policy-makers to think about how and where thresholds are set, and what kind of behaviour may result from them.