On 20 March 2026 the Royal Decree Law 7/2026 introduced into Spanish law the Renewable Acceleration Zones (ZAR), the figure that the Directive (EU) 2023/2413 (RED III) had outlined to shorten the authorisation periods for renewable installations. On 15 April, MITECO opened the prior public consultation of the royal decree that is to develop articles 14 to 18 of that text: designation procedure, minimum criteria, and catalogue of mitigation measures. The consultation closed on 15 May and the regulation, as of now, has still not been published.
This is the exact moment when it is important to understand well what changes. Because the quick reading circulating in the sector —«within a ZAR, environmental impact assessment will no longer be required»— is, at the very least, incomplete. And deciding on investments based on an incomplete reading tends to be costly.
The assessment moves upstream
The design of the ZAR does not eliminate environmental assessment: it displaces it in time and scale. Instead of analysing each project in isolation, the analysis is first done on the territory, when the autonomous community delineates the area, with prior strategic environmental assessment and public participation.
Within a designated ZAR, a project that applies the measures from the official catalogue may avoid the ordinary environmental impact assessment procedure of Law 21/2013, but is not exempt from justifying that it fits in.
The practical result is less intuitive than it seems: the technical work does not disappear, it is distributed differently. Part goes to the regional administration in designating the area, and part remains with the developer, turned into a demonstration of fit, not an impact defence.
What will remain inside and what will remain outside
The basic state regime excludes in all cases from the ZAR the spaces of the Natura 2000 Network, the protected natural spaces, the Ramsar wetlands, the critical areas of threatened species and the environments of singular heritage value. Article 6.3 of Directive 92/43/EEC and Article 46 of Law 42/2007 already require a specific assessment of repercussions for any plan or project that may affect a Natura 2000 space.
In the opposite sense, the norm prioritises already transformed soils: industrial estates, degraded soils, closed landfills, quarries. For a developer with a portfolio, this has an immediate consequence: the relative value of their sites has just changed. A mediocre location in resources but situated on degraded land can become quicker —and therefore more valuable— than an excellent location on sensitive agricultural land.
The mitigation catalogue is where everything will be decided
The entire regime hangs on a piece that we do not yet know: the state catalogue of homogeneous mitigation measures. If it is demanding and specific —stops for low wind speed during critical migration periods, detection and stopping systems for avifauna, closures permeable to terrestrial fauna, monitoring with mortality thresholds—, the ZAR will work. If it is generic, it will generate litigation, and the time gained in processing will be lost in the courts.
Therefore, the recommendation we make to our clients is the opposite of what they expect: do not wait for the catalogue to start measuring. A complete annual cycle of monitoring of birds and bats cannot be improvised when the regulation is published. Those who have the data series ready will be able to demonstrate compliance in weeks; those who do not will have to wait a whole year, whether they have ZAR or not.
Three details that often go unnoticed
Beyond the ZAR, the same text includes measures with direct effect on planning:
1. Repowering with increases of up to 25%. The evaluation is limited to the incremental impact and halves the administrative deadlines, with reuse of documentation.
2. Sectoral reports with amendment deadlines. When they are missing, the environmental authority requires the amendment within a three-month period and, once exhausted, continues the processing without those documents. A double-edged sword that rewards those who have their files in order.
3. Shared evacuation by common position. It requires agreements between promoters that, if not negotiated soon, become the real bottleneck.
And a fourth, for projects connected to 132 kV or more: the obligation to transfer benefits to local communities through citizen participation processes. The social licence ceases to be a good practice and becomes a regulatory requirement.
What should be on the table today
For a promoter with projects in the pipeline, reasonable preparation before the regulation is released has five points:
- Classify the portfolio according to the probability that each site ends up within a ZAR
- To have the annual wildlife cycle underway where the decision is relevant
- Review the already drafted impact studies to see which part can be reused
- Open the shared evacuation conversation with the neighbouring promoters
- Prepare the local participation process before the conflict arises
None of this is spectacular. It is advance processing engineering, which is exactly the discipline that separates a project that gets built from one that expires in an administrative drawer.
How we do it at AUMA
We accompany promoters throughout the environmental processing cycle of wind and photovoltaic parks: zoning and selection of alternatives, wildlife studies, environmental impact studies, responses to objections, and environmental monitoring plans.
33 years without a matrix or product to place: if the analysis says that a site will not fit into a ZAR and that the project is not viable, we will say so. It is the cheapest way we know to save money for a client.
If you have a portfolio in processing and want to know which projects will benefit from the ZAR and which will not, write to us. A two-hour working session is usually enough to see it clearly.