Comparing Environmental Licensing for Green Hydrogen and Other Energy Sources
How environmental licensing for green hydrogen compares with oil and gas, wind, solar and hydro power in Portugal under the RJAIA regime.
Environmental licensing in Portugal follows the Environmental Impact Assessment Legal Regime (RJAIA), approved by Decree-Law No. 151-B/2013, with specifics depending on the energy sector. For green hydrogen, an Environmental Impact Assessment (AIA) is required above certain production or area thresholds, or in sensitive areas; for oil and gas it is required at practically every stage; for wind above 20 MW or towers over 50 metres; for solar above 100 hectares; and for hydropower it is always mandatory.
Average licensing time by energy source
- Green hydrogen: between one and two years, depending on project complexity.
- Oil and natural gas: between three and five years or more, given the technical complexity and risks involved.
- Wind power: between one and two years, with faster processes for smaller-scale projects.
- Solar power: six months for self-consumption projects, up to a year or more for large parks subject to AIA.
- Hydropower: between five and ten years, due to project scale and significant environmental impacts.
The main entities involved include APA (AIA), DGEG (production licences), ICNF (opinions on fauna and flora) and, in the case of hydrogen and hydrocarbons, ANEPC and the National Maritime Authority. Although still under development, green hydrogen licensing represents a strategic opportunity for Portugal, provided it remains effective, transparent and swift without compromising environmental protection.