Wind turbines: REPowerEU directive. EPAW junio 2022

Wind turbines: REPowerEU directive. CALL TO ALL !!!

Consultation before the adoption of the REPowerEU directive. 


The European Commission, under the pretext to free Europe from Russian gas, has launched a consultation under the name of "REPowerEU" to impose a renewable energy directive based on the invasion of European countries by hundreds of thousands of new wind turbines.

This program "REPowerEU" is supported by the lobby of wind developers (RES SIMPLIFY Report) and carried by the green environmentalist parties that hold power in Europe.

To achieve its goals, the commission simply wants to flout democratic principles and suppress fundamental laws, particularly environmental laws, which allow citizens to fight against this plague

"REPowerEU" is just the program of the ruling coalition in Germany.  It is potentially, the shattering all environmental protections and may be the end of our capacity to resist.
( Jean-Louis Butré - Patrick Kawala  pdt FAEV)

 Your participation is required if you do not want to ruin the future of our union.

Consultation prior to the adoption of the REPowerEU Directive.
(Michel de Broissia,  Michel Faure FED administrators)

The war in Ukraine has brutally revealed the fragility of the European energy transition based on renewable energies and gas. Far from questioning its strategic choices, Europe has chosen to rush ahead and is preparing a directive to double down on this path, which many consider to be a dead end. Without any prior impact study, this new rule will apply to all countries, regardless of their own greenhouse gas emissions (GHG).

Directive Project main issues (18/05/2022):

Commission Recommendation (18/05/2022) :

The directive currently being adopted is subject to a public consultation from 20 May to 27 July 2022. Its content opens the way to all kinds of abuses and we will have to mobilize as never before..

To participate (Associations or individuals),

click on the following link:

Beware, the web page is confusing. By scrolling down the page, a first call for contributions appears followed by 728 opinions. This is a first consultation that is now closed and that took place from January 18 to April 12, 2022, including the two summary documents. 
The current public consultation appears just after scrolling down the web page. It is easy to recognize with its orange highlight.

Scroll down the web page to see the following content (highlighted in orange):

All you have to do is click on "Give feedback".

All that remains is for you to give your opinion on behalf of yourself or your association by creating an account if you have not already done so. If your association is declared in the transparency register, you can indicate your identification at the top of your contribution.

To build your argument, it is best to read the draft directive and/or the summary given below. It is always better to give your point of view with your own expression. It will not be or appear to be the comment of an organization.

Some issues seem particularly worrying:

·  The precipitation of procedures will exacerbate conflicts instead of mitigating them,

·  The absence of impact assessments on the scale of projects in favorable areas (“go-to areas”), combined with the very short deadlines, opens the door to all kinds of abuse.

·  The shortened deadlines are incompatible with the observation of nature

·  The lack of information and public participation at the level of each project is a negation of the Aarhus Convention.

·  The easy re-equipment of old plants, as well as the will to concentrate all the RES in go-to areas, designates some territories as abandoned areas in contradiction with the principle of equality of territories.

·  The principle of subsidiarity is flouted by imposing without saying it a partial abandonment of the nuclear power produced in Europe without any GHG emissions.

·  The draft directive flouts certain European treaties (Euratom) and runs counter to the restoration of biodiversity, which was previously designated as a priority.

·  The prior public consultation integrated in the process of elaboration of the present draft directive, which took place from January 18 to April 12, 2022, did not take into account any observations in opposition to the object of the inquiry. This is a practice far removed from the spirit of a consultation.

·  Accelerating the procedure process will increase rather than mitigate conflicts.

Key points of the draft directive

The following paragraphs provide an overview of the most critical points that will become binding on member states if they are adopted without an impact assessment. They reflect the considerations formulated in the draft directive. ;

The opinions given in the form of a note are those of the authors of this key note.


1.       The massification of renewable energies (RES):

The directive (EU) 2018/2001 set a binding target of 32% RES deployment by 2030. The war in Ukraine is the pretext for fixing this RES deployment to 45% by 2030 [1].

2.       In order to accelerate the implementation of renewable energy projects, it is first necessary to simplify and shorten the procedures for granting permits.

1.       The development and operation of RES must be considered to be in the “overriding public interest [2] and serving public health and safety”. As such, they should be given the most favorable procedure among other planning and permitting procedures.

2.       Member States should immediately map and assess suitable onshore and offshore areas for renewable energy projects, known as "renewables go-to areas", and ensure their availability.

3.       Member States will have to quickly define a zoning of their territories

1.       The renewable go-to areas for which projects will be subject to accelerated procedures.

1.       Only a global environmental assessment [3] of go-to areas will be carried out, valid for an indefinite period.

2.       If necessary, member states will adjust unforeseen impacts through corrective actions [4].

3.       The designation of go-to areas shall meet the needs defined by the commission in terms of produced energy [5].

4.       The preliminary environmental assessment, which is therefore at the zoning plan level, makes it unnecessary to carry out impact studies for each project. In the event of unforeseen impacts that are duly justified within a short period of time, an impact study at the project level may be required, but its duration is limited to 6 months

2.       The other areas (outside go-to areas)

The fact that a RES project is located in a non go-to area should not prevent its realization. In this case, an environmental assessment must be carried out [6].

4.       Taking biodiversity into account will become less restrictive.

The killing of protected species [7] is allowed provided that mitigation measures are in place and monitoring is carried out. Member States may authorize experimental mitigation measures for a limited period of time and under strict control.

There will no longer be any need to request exemptions for the destruction or disturbance of protected species.

5.       Repowering of renewable energy plants at end of life will be simplified [8]:

The directive includes very simplified procedures for the repowering of old wind farms. The reasons are given: the first projects were set up on the most promising sites, the local residents will have a better acceptability, the power connections are available and the effect on the environment is known

1.       Environmental studies will only address changes for plants located outside go-to areas (plants in go-to areas will be exempted),

2.       Permit granting procedures are shortened.

6.       Member States should consider renewable plants and their associated infrastructure to be in the overriding public interest and to serve public health and safety

Unless there is clear evidence that some projects have major adverse environmental impacts that cannot be mitigated or compensated for.

As these renewable plants are projected in the overriding public interest and serving the public health and safety, these projects must receive a shortened assessment.

7.       Some directives need to be amended to allow for the required simplifications:

1.       About environmental studies: directive (EU) 2018/2001 should be amended.

2.       About housing ; directive 2010/31/UE 2001 should be amended.

3.       The energy saving factor, which is expected to be 32.5% in 2030 compared to 2007, should be increased to 41.5% by the same date. Directive 2012/27/EU should be amended accordingly.

8.       Authorization procedures are time-limited and are subject to a very tightly controlled process

1.       application request: the administration must respond to the promoter within;

1.       14 days in a go-to area. If the application is incomplete, the developer must respond within 14 days. He will have the possibility to re-file a new application if he passes the deadline for the formal admissibility examination.

2.       1 month in a non go-to area

The start date of the granting procedure starts on the date when the project is defined as complete by the administration..

1.       The administration states a single contact for the entire procedure.

This contact has a guide that he gives to the promoter..

1.       For the resolution of disputes, the member states provides the quickest legal framework available.

2.       In go-to areas, the granting process should not exceed one year (with a maximum extension of 3 months in exceptional cases).

3.       Outside go-to areas, the period is 2 years, extendable by 3 months.

4.       For repowering, the authorization procedure should not exceed 6 months (this period can be extended in “extraordinary” circumstances).

5.       Permit-granting

6.       Inside go-to areas, there is no need for impact studies [9]. The administration has 30 days to exceptionally require an environmental study [10]. In the absence of a response within the deadline, the project is considered to be accepted as is.

7.       Outside go-to areas, the granting procedure requires an impact assessment. In total, the entire procedure should not exceed 2 years (which can be extended by 3 months in exceptional cases).


[1] In practice, to comply with this new directive, some countries will have to shut down or mothball some of its nuclear power plants.

[2] Note the definition of an "overriding" category intended to be placed above the "general" interest.

[3] Thus clearly insufficient because at this stage, the characteristics of the projects are unknown.

[4] The current drifts based on this kind of precaution are well-known.

[5] This requirement in terms of energy produced mignt become extremely restrictive without even taking into account the energy potential of a country.

[6] But, the State services will define the content and it will become intangible!

[7] This is a considerable regression. The European Commission places the deployment of renewable energies above the protection of biodiversity including protected species.

[8] Bad luck to the territories that have accepted or suffered the deployment of wind farms.

[9] A project can therefore be authorized without any assessment of the biodiversity, without an acoustic study, without a landscape or cultural study,…

[10] The 30 days deadline is very short as the State services will have to prove that the project is highly likely to have unforeseen significant negative impacts on the environment to require an environmental assessment! It is obviously an impossible mission in such a short time.

More informations please contact
Michel de Broissia :
Michel Faure :

Jean-Louis Butré
European Platform Against Wind Farms 
Fédération Environnement Durable
tel 06 80 99 38 08

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