Wind Repowering And Greenfield Projects: Building A Robust And Sovereign Electrification By Restoring Stakeholder Confidence

Read a French language version of this update.

The publication of the decree on Multiannual Energy Program (PPE 3) on 12 February 2026, after several years of delays, marks a pivotal milestone by finally establishing a planning framework for the 2026–2035 period. Building on this, the launch of renewable energy tenders on 2 April 2026, including, notably, quotas dedicated to onshore wind power, within which repowering tends to be prioritised — should help put this framework into practice and reignite, albeit still in a measured way, investment momentum.

However, the return of a planning framework is not enough to resolve the structural challenges currently facing the wind energy sector. The marked slowdown in the pace of grid connection, rising costs (financing, equipment, supply chain), persistent challenges with local acceptance and the increasing number of legal challenges to projects are simultaneously weighing on developers and investors, contributing to a gradual erosion of the sector’s willingness or ability to invest.

In addition to these operational constraints, there is persistent political uncertainty regarding France’s energy trajectory, fueled by shifting policy priorities and planning that is sometimes perceived as lacking clarity. In this context, the PPE 3, while establishing a framework, also includes a review clause set for 2027. This clause is intended to allow for a revision of the PPE, so that, if necessary, the objectives and support mechanisms can be adjusted in light of changes in electricity consumption and installed capacity as documented in a Report on the Evolution of Electricity Consumption, the development of carbon-free electricity generation capacity, and the development of carbon-free flexibility measures, to be published by the government. This flexibility creates a degree of uncertainty regarding medium-term trajectories and investment signals.

At the same time, PPE 3 is the subject of significant litigation before the Council of State. Several appeals alleging abuse of power were filed between February and April 2026, primarily by associations, citizen groups, and activist organisations, challenging both the legality of the decree’s use (in the absence of a programming law) and the substance of the chosen energy trajectory itself.

At this stage, at least five appeals have been filed, and no decision to annul the decree has been issued: the decree therefore continues to be in effect during the proceedings, which fall directly under the jurisdiction of the Council of State, ruling in the first and final instance. The results of the 11th period of the PPE2 onshore wind tender, which closed on 21 May 2026 and whose 39 successful projects, representing 808 MW at a weighted average price of €77.08/MWh, were designated on 7 July 2026, illustrate both the vitality of the sector and the growing weight of repowering, which accounted for approximately 66 percent of the awarded capacity. The tender was oversubscribed by more than three times, demonstrating that developer interest remains strong despite increasingly challenging market conditions, while also highlighting that the tendered volumes are insufficient to meet market demand.

At the same time, the predominance of repowering among the successful projects suggests that competition for the limited available capacity increasingly favours projects with lower costs and reduced development risks.

A further tender period, calibrated at 1,000 MW and restricted to projects already holding a valid environmental authorisation, is expected to open in the autumn of 2026. Whether these successive tender rounds, and the level of capacity they make available, will be sufficient to restore investor confidence remains an open question.

Energy Transition Enters a New Phase

France benefits from largely decarbonised electricity thanks to renewable energies and nuclear power. However, the French economy remains highly dependent on imported fossil fuels, as many end uses are not electrified: oil and gas still account for a cost of approximately €60 billion per year, with sharp upward variations during energy crises.

Reducing this dependence therefore constitutes a major sovereignty issue. Geopolitical tensions, energy market volatility, strain on the supply and price of fossil fuels, as well as vulnerabilities in supply chains serve as a stark reminder that the energy transition is no longer merely a climate issue, but also a matter of security and sovereignty.

PPE 3 has been long awaited, undermining investor confidence and severely affecting developers and all stakeholders in the renewable sector due to a lack of visibility. But it is finally here, and to address our dependence on hydrocarbons, it provides for a vast electrification plan combining the revival of nuclear power with support for decarbonised energies. The objective is to shift final energy consumption from approximately 60 percent fossil fuels today to 60 percent decarbonised energy consumption by 2030.

This strategy relies on a progressive and massive electrification of end uses such as development of electric vehicles, deployment of heat pumps and transformation of industrial processes. It will also be necessary to manage the increase in electricity demand linked to the digital sector (notably data centers).

The French electricity system faces a dual challenge: rapidly increasing decarbonised generation capacity while securing supply in an unstable international context.

In this context, onshore wind retains a central role, despite an ongoing debate over acceptability and development conditions. Technologically mature, economically competitive and rapidly deployable, it constitutes one of the pillars of renewable electricity generation. Installed capacity in France has progressively evolved with the commissioning of increasingly powerful wind turbines. Nevertheless, capacity development in France cannot rely on a single model.

Repowering and greenfield development now appear to be two inseparable levers, destined to mutually reinforce one another, although the government seems to prioritise repowering through PPE3.¹

Repowering: Producing More and Better Where Wind Energy Is Already Established

Repowering consists of renewing an existing wind farm at the end of its life cycle by replacing old turbines with higher performance wind technology. Repowering thus differs from the identical renewal of an end-of-life wind farm. In certain cases, it also allows for a reduction in the number of masts for equivalent power output.

With constant or near constant land use, depending on the characteristics of the renewed project, this approach often makes it possible to double or even triple the installed production capacity, while allowing for a better landscape footprint and improving the acoustic performance of the facilities. In other words, the purpose of repowering is to improve the performance of renewed wind farms with facilitated local acceptability.

Indeed, local acceptability remains a determining factor in the development of the wind sector. In this respect, repowering serves as a lever for optimising existing installations, likely to improve their yield without intensifying the saturation effects perceived at the level of certain territories. It allows the project to integrate into territories already familiar with wind energy, engaging elected officials, residents and economic players who understand its effects and benefits.

Public authorities have made no mistake about it. The Multiannual Energy Program clearly makes the renewal of existing wind farms a priority axis for the development of onshore wind. The objective is clear: to optimise existing assets to save time in a race against the clock imposed by climate targets and the rise in electricity needs.

A Legally and Technically Demanding Exercise

While repowering may, at first glance, appear to simplify project development, this assessment must be qualified considering the operational and legal constraints attached to it and the reality on the ground. It is not a mere replacement of parts or technical modernisation, but a fully-fledged project, subject to applicable legal and regulatory provisions, and in particular the provisions of the Environmental Code and the Energy Code.

As such, each operation requires a precise analysis of the nature of the proposed modifications to determine whether they constitute a significant (notable) or substantial (substantiel) modification within the meaning of the Environmental Code, a qualification upon which the applicable procedure, processing times and litigation risk directly depend. The circular of 20 March 2026, which replaced the previous circular of January 2025, although devoid of normative value, provides useful elements of interpretation and a reading frame, and contributes to strengthening the predictability of the administrative framework. It specifically targets the increase of the height threshold from 33 percent to 35 percent, below which the modification, in the absence of any sensitivity, constitutes a significant rather than substantial modification.

From a real estate perspective, existing land rights must be audited and, where necessary, adapted through the execution of amendment agreements: modification of layouts, evolution of easements and extension of contractual terms.

Environmentally, the impact assessment must be updated to reflect the actual state of the environment, under the scrutiny of administrative authorities and the administrative judge.

Finally, the issue of grid connection, which is often underestimated, must not be overlooked. Repowering must be treated as a modification of the connected facility, which can lead to changes in power, voltage, protection and sometimes the connection point itself. In practice, it is therefore necessary to revalidate the entire connection scheme with the grid operator and to enter into an amendment to the connection agreements, which requires careful anticipation.

Greenfield Development: A Strategic Necessity to Meet Demand

However essential it may be, repowering will not suffice to meet the scale of needs associated with the growing electrification of the economy. France’s commitment to a progressive and massive electrification of the economy, driven by electric vehicles, heat pumps, industrial electrification and the digital sector, demands a net and sustainable increase in installed capacities.

From this perspective, greenfield projects remain essential. They enable the mobilisation of new production areas, a better territorial distribution of installed capacities and a strengthening of the overall resilience of the electricity system. As such, they also constitute a key driver for achieving the long-term trajectories established by national and European energy policies.

Abandoning the development of greenfield projects on the grounds of administrative complexity or public acceptability appears strategically questionable, given France’s ambition to preserve its energy sovereignty. Conversely, a balanced articulation between the creation of new facilities and the renewal of existing wind farms appears to be the only way to enable the sector to satisfy at the same time economic, industrial and climate requirements.

Nevertheless, the specifications of the new onshore wind tender period published on the CRE (Energy Regulatory Commission) website in early April (period no. 11 of the onshore wind tender) specify that only installations having obtained a valid authorisation or equivalent authorisation under the same article, meaning it has acquired an enforceable character, are eligible. Consequently, an authorisation containing a condition precedent that has not been satisfied is not eligible. This implies that archaeological diagnostics must have been carried out and therefore that the INRAP report has been issued. This restriction on the scope of eligibility is likely to make greenfield wind projects currently under development less competitive.

Restoring Confidence: A Key Condition for Success

The success of this new phase of the energy transition relies on a central factor: confidence.

Firstly, the confidence of economic stakeholders in the stability of the regulatory framework, the clarity of public objectives and the consistency of energy policies over time. Normative volatility, the accumulation of procedures and uncertainty regarding trajectories currently affect investment capacity and slow down the mobilisation of capital. Secondly, the confidence of territories and citizens in the ability of wind projects, whether repowering or greenfield, to integrate sustainably into their environment, share the value created locally, and concretely contribute to the country’s energy independence.

The trajectory adopted for onshore wind, which is relatively moderate (PPE 3 sets a target of 35 to 40 GW of onshore wind capacity by 2035, compared to a previous target of 45 GW), sends an ambiguous signal to industrial players and investors, while the development of new projects requires long cycles, anticipatory capabilities and significant financial commitments.

By favoring a limited progression of capacities, largely based on the renewal of existing wind farms, PPE 3 tends to reduce market growth prospects. While this prudence may certainly address local acceptability constraints, it weakens the structuring of the value chain and limits the ability of stakeholders to plan their investments.

Finally, the introduction of a review clause in 2027, although offering a degree of adjustment flexibility, weakens the confidence that is nonetheless essential for mobilising stakeholders.

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The levers of repowering and greenfield must therefore not be pitted against one another. The successful development of wind energy relies on their coordination. Repowering accelerates and consolidates existing assets, whereas greenfield projects stem from a dynamic of long-term projection and structuring.

While the decree relating to PPE 3 establishes an orientation in favor of renewing onshore wind farms, the tender specifications published by the Energy Regulatory Commission (CRE) in early April 2026 provide, in a balanced manner, for the possibility of bidding for repowering projects, without excluding or restricting access for greenfield projects.

Legally, there is no explicit mechanism excluding greenfield projects from the tender. Projects undergoing repowering represented 27 percent of the capacity submitted during this tender period. However, the results of the most recent onshore wind call for tender whose results were published on 7 July 2026 confirm a trend: repowering projects accounted for approximately 66 percent of awarded capacity and submitted bids at a weighted average price of €76.84/MWh, compared with €85.26/MWh for non-repowering projects.

The energy regulator (CRE) has acknowledged that repowering projects are on average already more competitive than other projects. While this does not amount to a de jure or de facto exclusion of greenfield projects, the CRE notably declined to introduce reserved volumes or bonus mechanisms for repowering on the grounds that such incentives are unnecessary, it reflects a structural economic advantage that the current tender design does little to offset.

This dynamic is notably explained by their increased competitiveness, resulting from the optimisation of sites already in operation and the management of land and administrative constraints. This could ultimately induce a de facto exclusion effect on greenfield projects, without this resulting from any explicit normative provision. It remains to be seen whether the next onshore wind call for tenders, for which bids are to be submitted in the autumn of 2026 and which is expected to be restricted to projects already holding their environmental authorisation, will confirm or temper this apparent shift towards repowering.

From a forward-looking perspective, this evolution calls for vigilance by the regulator regarding the maintenance of effective competitive conditions and the preservation of a balance between the renewal of the existing projects and the development of new capacities, which is essential to achieve long term objectives.

Footnote

1. Article 3 of Decree No. 2026 76 of February 12, 2026, relating to the multiannual energy programming.