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Energy Storage 4 min read
Licensing Co-located Energy Storage: DGEG/APA Explanatory Note
DGEG's Explanatory Note No. 5/DG/2025 clarifies how licensing applies to batteries installed at the same site as an existing production plant.
On September 29, DGEG published Explanatory Note No. 5/DG/2025, clarifying licensing questions for co-located storage projects — installed at the same site as a production plant, such as a solar or wind farm — following Joint Order No. 2 from APA and DGEG.
Key clarifications
- Licensing vs. addendum: if the storage unit shares the same Environmental Impact Statement (DIA) as the plant, the process can be a faster addendum; if deemed an autonomous unit, it follows independent licensing.
- Injection capacity: co-located storage must generally respect the maximum capacity already allocated to the plant; a capacity increase triggers a new grid connection request.
- Simplified environmental procedures: within the same perimeter and without a significant increase in impact, APA's assessment can be simplified rather than requiring a full new DIA.
The Explanatory Note acts as a bridge between the new storage legislation and the reality of production projects, where co-location is the norm, giving developers a clearer and more predictable path forward.