New Special Spatial Planning Framework For Renewable Energy Sources Under Public Consultation

Our Administrative Law Briefing Special Edition analyses the new Special Spatial Planning Framework for Renewable Energy Sources which is now under public consultation, including:

A.   Scope of the New RES Framework
B.   Wind Farms
C.   PV Parks
D.   Offshore Wind Farms and PV Parks
E.   Energy Storage Installations (Batteries)
F.   Key Takeaways for Investors and Developers

The Greek Ministry of Environment and Energy has published for public consultation a new draft Joint Ministerial Decision approving the revised Special Spatial Planning Framework for Renewable Energy Sources and its accompanying Strategic Environmental Impact Assessment (the New RES Framework). The New RES Framework will replace the existing Special Spatial Planning Framework for Renewable Energy Sources, which has been in force since 2008 (the 2008 RES Framework)¹. 
 
The draft New RES Framework introduces a comprehensive set of siting rules for onshore and offshore wind and solar installations, small hydroelectric projects, facilities for energy generation from biomass, biogas, or biofuels, geothermal energy facilities and energy storage facilities. It introduces significantly stricter siting rules, combining expanded exclusion zones, minimum distance requirements, carrying capacity limits, visual impact rules and other restrictions.

This briefing will highlight the key provisions of the draft New RES Framework for onshore and offshore wind farms and solar (PV) parks, and energy storage installations.

A.   Scope of the New RES Framework
The New RES Framework does not apply to certain projects which are currently at various stages of development. In particular: 

1.   Existing Operation Licenses or Installation Permits: Power stations lawfully operating at the date of entry into force of the New RES Framework are exempt until expiry or renewal of their operation licence. Existing installation permits are executed as issued within their validity period. Any amendment to existing installation permits is made and the related operation licences are issued in accordance with the 2008 RES Framework.

2.   Existing Environmental Licenses (AEPOs or PPDs): Environmental Terms Approvals (AEPOs) and Standard Environmental Commitments decisions (PPDs) issued before entry into force of the New RES Framework remain valid until their expiry. Projects holding an AEPO/PPD may obtain installation permits and operation licences and may be constructed within their validity period. AEPOs/PPDs may also be amended or renewed under the 2008 RES Framework. However, the New RES Framework applies where there is a site relocation or expansion of the installation plot by more than 50% of its surface area.

3.   Environmental Impact Studies with Formal Completeness Approval by 20 May 2026: Environmental Impact Studies submitted to the competent authorities and which have received formal completeness approval by 20 May 2026, continue to be assessed under the 2008 RES Framework.

In addition to the above, certain project categories are exempt from the New RES Framework, including projects for which a Production License, Producer Certificate or Special Projects Certificate is not required. However, this exception does not apply to PV parks.

B.   Wind Farms
Notable provisions for wind farms include:

1.   Wind installations can only be sited within designated Suitability Areas², subject to exclusion zones and further spatial and environmental criteria. The 2008 system of Wind Priority Areas and Wind Suitability Areas is replaced by Suitability Areas’, which include certain Acceleration Areas. 

2.   The installation of new wind turbines is no longer permitted in Attica and the Metropolitan Area of Thessaloniki.

3.   Carrying capacity is now calculated at the level of Municipal Units (Δημοτικές Ενότητες) instead of Municipalities (Δήμοι) and may be increased by regional spatial planning frameworks or urban plans under certain conditions.
 
4.   When siting wind farms on islands, the maximum permitted carrying capacity must be considered and it may not exceed 4% of the total area per Municipal Unit.

5.   A minimum distance requirement of at least 0.5km from certain areas of environmental interest is introduced and includes: zones of absolute protection of nature and nature protection zones, Ramsar wetlands, National Park cores, natural monuments, aesthetic forests and priority natural habitats of Special Areas of Conservation.  

6.   The core exclusion zones of the 2008 RES Framework for wind farms are retained, and several new ones are added, as summarized below:

The above exclusion zones No. 1 to 10, 15 and 16 also apply to ancillary works for wind power facilities. 

C.   PV Parks
Notable provisions for PV parks include:

1.   Priority Areas (which may also include Acceleration Areas) are established for PV parks. These include areas that are barren or non-irrigated, not intended for grazing, preferably out of sight of designated World Heritage sites and other monuments of major significance, designated Archaeological Protection Zone A areas, and areas with a high tourism development index. Areas that have undergone a change in character (abandoned mining sites and lignite fields, polluted and degraded areas etc.) are also included, along with areas with easy grid access. 

2.   A maximum permitted carrying capacity per Regional Unit is introduced for the first time, set at 1.5% of the total area and including solar thermal power stations. 

3.   Additional restrictions (especially for PV parks above 100MW) are set for the first time. These include minimum distance requirements, such as a 0.5km setback from residential areas, specific environmental/cultural heritage zones and high-productivity agricultural land. Visual horizon coverage must not exceed 120° relative to these areas. For installations within 1.5km of settlement boundaries, the limit of visual horizon coverage is 180°. 

4.   A special visual impact study is required for PV parks in areas within 1.5km from significant monuments, archaeological and historic sites, including designated World Heritage sites. The same applies for PV parks in areas within 1km from Archaeological Protection Zone A areas of other archaeological sites, declared cultural monuments, historic sites and traditional settlements. 
 
5.   Environmental licensing may be required for PV installations which will be developed in adjacent plots of land, even if they do not individually fall within an environmental licensing category³.

6.   The core exclusion zones of the 2008 Framework for PV parks are retained, and several new ones are added, as summarized below⁴:

The same exclusion zones apply to ancillary works for PV parks.

7.   Existing provisions, including restrictions and prohibitions, are retained on the installation of agrivoltaics and PV parks in high-productivity agricultural land.
8.   A comprehensive set of minimum distance requirements from adjacent land uses, activities and technical infrastructure networks is established for both PV parks and solar thermal power stations, including a distance of at least 0.5km from areas of environmental/cultural significance (e.g. Natura 2000 Network priority habitats, World Heritage monuments etc.).

D.   Offshore Wind Farms and PV Parks
Specific siting rules for offshore wind farms and PV parks are incorporated into the New RES Framework. Installation of wind farms and PV parks is permitted in offshore areas, provided that these areas are not subject to a specific legal regime explicitly prohibiting such installations and/or do not constitute designated exclusion zones. 

Exclusion zones for both offshore wind farms and PV parks include designated marine and underwater parks, areas with underwater antiquities or protected shipwrecks, Aquaculture Development Areas under the relevant Special Framework (except if consent of the operator is acquired), enclosed bays with a width of less than 1.5km and passenger shipping routes. 

In addition to the above, exclusion zones for offshore wind farms also include diving parks, anchorage areas, firing ranges and military training areas, areas off-limits for reasons of national security, submarine power cables, telecommunications networks and pipelines (natural gas etc.). Exclusion zones for offshore PV parks also include areas in contact with or above Posidonia oceanica seagrass beds.

Minimum distance requirements from adjacent land uses, activities and technical infrastructure networks are established for both offshore wind farms and PV parks. 

E.   Energy Storage Installations (Batteries)
The New RES Framework introduces specific siting rules for electrochemical energy storage installations (i.e. battery energy storage systems, or BESS) for the first time.

A comprehensive list of exclusion zones is established, mirroring those applicable to wind farms, with the exception of the following which do not constitute exclusion zones: 

1.   Special Protection Areas – SPAs;

2.   Areas above 1.2km altitude;

3.   Islands with surface area less than 300sq. km; and 

4.   Municipal Units of high tourism development as defined by the Special Spatial Framework for Tourism or by urban planning frameworks. 

Where BESS is integrated into or co-located with RES facilities, the siting rules and criteria for the relevant RES facilities apply.

Minimum distance requirements from adjacent land uses, activities and technical infrastructure networks are established, including a distance of at least 0.5km from areas of environmental/cultural significance (e.g. Natura 2000 Network priority habitats, World Heritage monuments etc.).

Installation of BESS is subject to the environmental protection provisions of the legal framework regulating protected areas and/or the approved Special Environmental Studies for such areas.

Installation of BESS in forests and forested areas is permitted subject to applicable forestry legislation and the relevant Special Environmental Studies. It is also permitted in high-productivity agricultural land, subject to the applicable legal framework and obligations.

F.   Key Takeaways for Investors and Developers
The New RES Framework represents a substantial tightening of the spatial planning regime for renewable energy in Greece. Meaningful protection is provided for projects already in the pipeline. However, the expanded exclusion zones, new carrying capacity limits and visual impact rules, as well as potential re-examination of early-stage projects, may materially affect site availability and development timelines for onshore and offshore wind and PV parks and BESS. 

Given that the draft New RES Framework is currently under public consultation until 24 June 2026, market participants have a narrow but important window to engage with the process and shape the final text.

Footnotes

^{1  Decision No. 49828/12.11.2008 of the Committee for the Coordination of Governmental Policy in Spatial Planning and Sustainable Development (Government Gazette B' 2464/3.12.2008).
2  Suitability Areas refer to the level of Municipal Units and are defined as areas with significant wind potential above 4mts/sec.
3  As specified in Ministerial Decision YPEN/DIPA/63951/4418/12.6.2024 (Government Gazette B’ 3867).
4  Additional exclusion zones apply to solar thermal power stations.}

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.