Storage has become a key pillar of the energy transition, but its development involves a regulatory framework that combines access and connection, energy, environmental and urban-planning requirements. The main milestones are set out below.
Grid access and connection
The access and connection procedure is governed by Royal Decree 1183/2020, of 29 December, on access to and connection with the transmission and distribution grids. A storage facility able to inject energy into the grid is treated as a generation installation; when it draws energy from the grid to charge, it is also treated as a demand installation. Storage therefore needs two access and connection permits — one for generation and one for demand — each backed by economic guarantees.
For hybridised storage added to generation that already holds permits, the same connection point and access capacity can be reused where the requirements of article 27.3 of RD 1183/2020 are met: the holder asks the grid operator to update the existing permits and replace the guarantees so they cover the new storage power; if the storage charges from the grid, a demand permit must also be requested. Guarantees for new storage modules in hybridisation cases are reduced by 50% compared with the ordinary amount.
Administrative milestones under RDL 23/2020
Because storage counts as generation for access purposes, it is also subject to the administrative milestones set by Royal Decree-law 23/2020, of 23 June. For stand-alone storage, the milestone deadlines start once the generation access and connection permits are obtained. For hybridisation of installations that already hold permits, both technologies must meet the milestones: if the original technology fails, the whole permit lapses; if the technology added by hybridisation fails, the permit reverts to its original state and covers only the original technology. Deadlines run, for the original technology, from the grant date of the access permit (or from the entry into force of RDL 23/2020 if it was granted earlier) and, for the hybridised technology, from the date the permit was updated.
Administrative authorisations
Storage is subject to the same authorisation regime as electricity generation. Under article 115.4 of Royal Decree 1955/2000, of 1 December — which regulates transmission, distribution, marketing, supply and the authorisation procedures for electricity installations — a stand-alone or hybridised storage project must obtain three authorisations: the Prior Administrative Authorisation (AAP), the Administrative Construction Authorisation (AAC) and the Administrative Operation Authorisation (AAE).
Jurisdiction over project processing
The General State Administration is competent when the installed capacity of the storage system — stand-alone or hybridised — exceeds 50 MW. At 50 MW or below, the autonomous community where the installation is located is competent. Some autonomous communities have their own authorisation rules while others refer directly to state legislation, and even where regional rules exist they may defer to national rules on storage. For projects of 50 MW or less, the applicable regional regulation should be reviewed before starting the procedure.
Environmental authorisation
Under Law 21/2013, of 9 December, on environmental assessment, stand-alone electrochemical battery storage — and storage of any technology hybridised with electricity installations — is subject to simplified environmental assessment. Stand-alone storage using any non-electrochemical technology must undergo ordinary environmental assessment.
Urban planning
Legislative competence over urban planning rests with the autonomous communities, and storage currently lacks a homogeneous urban-planning framework, with only a few isolated exceptions. Projects therefore require analysis of both the regional urban-planning law and the municipal planning for the site. Urban-planning authorisations are independent of the energy permits and are not strictly necessary until the execution phase, but a preliminary study of the project’s compatibility with current planning is strongly recommended.
Conclusions
Storage is a key pillar of Spain’s energy transition, providing flexibility and supporting the integration of clean energy. It is viable today and the regulatory framework is being simplified and strengthened, but the procedure remains complex because it combines access and connection, energy, environmental and urban-planning requirements, with competencies split among several administrations. A detailed knowledge of the applicable rules is essential.
