Environmental Licensing of Biomethane Projects in Portugal: What Is Required?
Licensing biomethane units in Portugal requires prior registration with DGEG, an environmental licence via SILiAmb, and coordination with land-use regimes such as RAN and REN — a process now clarified by Joint Order APA/DGEG No. 1/2026.
Biomethane is presented as a critical solution for decarbonising the Portuguese energy sector and reducing dependence on imported natural gas. Decree-Law No. 62/2020 established the liberalisation of renewable gas production and the requirement for prior registration with DGEG, supported by the elements of Annex VI. More recently, Joint Order APA/DGEG No. 1/2026 clarified the procedure: once registration is approved, the developer must obtain the environmental licence via the SILiAmb platform and the urban planning licence from the municipality.
Administrative Simplification and Land-Use Constraints
The Single Environmental Licensing scheme (LUA), created by Decree-Law No. 11/2023, coordinates the different environmental regimes and limits "case-by-case" screening in Environmental Impact Assessment (EIA). Beyond energy and environmental licensing, developers must check land-use constraints such as the National Ecological Reserve (REN, Decree-Law No. 166/2008) and the National Agricultural Reserve (RAN), as well as other sectoral regimes, such as the General Waste Management Regime, the Responsible Industry System (SIR) and the Water Use Title (TUA).
- Main risks: incomplete registration files, underestimating environmental impact, and overlooking applicable sectoral regimes.
- Best practices: prepare a robust feasibility study, consult DGEG, APA and the network operator early, and plan digestate management.
- Access to the gas distribution network requires compliance with technical quality standards and prior negotiation with the operator on the injection point.