On September 24, 2024, Spain’s Council of Ministers approved a Royal Decree updating the Integrated National Energy and Climate Plan (NECP) for 2023–2030. The International Institute of Law and the Environment (IIDMA) has closely followed this plan’s update process, contributing comments during the public consultation process in 2023 and the public participation phase related to its Strategic Environmental Assessment (SEA). Despite its release, IIDMA considers the plan deficient in the following key areas:
Regarding Green Hydrogen Production Targets: The lack of clear information about Spain’s total green hydrogen production goals by 2030 is a major deficiency. Such information is essential to understand how, with a planned 12 GW capacity of electrolyzers, the country will be able to produce enough green hydrogen to decarbonize industry (with 74% of the hydrogen consumed by this sector to be green by 2030) and meet the H2Med project’s infrastructure demand (2 million tons).
Regarding Installed Renewable Power for Green Hydrogen Production: Producing green hydrogen demands significant electricity resources, and while the growth of renewable energy in the electricity sector (81% compared to 74% in the 2021–2030 Plan) is a positive development, the NECP should have included more detailed data on projected renewable capacity specifically for green hydrogen production by 2030. However, the NECP merely states, in general terms, that renewable technology capacities planned for 2030 include capacities for electrolyzers, leaving it unclear whether the planned renewable energy is sufficient to meet projected hydrogen production needs. This also raises uncertainties about the role of renewable energy PPAs (power purchase agreements) for green hydrogen projects.
Regarding the H2Med Project: Despite its early development phase and clear limitations—both in terms of large-scale production and transport viability—the NECP continues to emphasize H2Med. IIDMA argues that the project, which requires substantial financial support to be economically feasible, should not have been included in the NECP, especially given the lack of preliminary studies on green hydrogen demand and the technical, economic, and energy efficiency challenges associated with transporting green hydrogen over long distances.
Regarding Combined Cycle Gas Plants: Regrettably, the NECP continues to rely on combined-cycle gas plants as a non-renewable technology and plans to maintain the entire installed capacity (26.6 GW) through 2030. Given the anticipated increases in renewable electricity generation (74% to 81%), self-consumption capacity (14 to 19 GWh), and energy storage (20 to 22.5 GW), along with anticipated advancements in distributed generation, electrical interconnections, and demand management, IIDMA argues for a gradual reduction of combined cycle capacity from 2023 to 2030. Such reductions would also align with strengthened measures for a just transition. While the gas contribution to the 2030 energy mix has been reduced compared to the previous plan, maintaining the high installed capacity of combined-cycle plants is inconsistent with the goals of the Paris Agreement.
Regarding Capacity Mechanisms: The NECP still includes capacity mechanisms that benefit combined-cycle plants. IIDMA believes these mechanisms should have reconsidered the role of these plants as backup technology. Supporting economically unviable, polluting plants not only squanders financial resources that could promote true decarbonization measures for the power sector but also hampers efforts to ensure electricity supply. Detaching Spain’s energy dependency from fossil gas is essential for achieving an early phase-out.
Finally, during the SEA process, IIDMA criticized the absence of a biennial monitoring report on the environmental effects of the 2021–2030 NECP, which should have been part of the environmental diagnosis for consultation. IIDMA argued that access to this report was crucial to make effective contributions to the updated plan’s environmental assessment. The Ministry’s obligation to produce and publish the report was outlined in the NECP 2021–2030 Strategic Environmental Declaration. However, as of today, this report remains unavailable to the public.
