The Portuguese Environment Agency (APA) and the Directorate-General for Energy and Geology (DGEG) issued the Joint Order No. 1, dated 30 July 2025, which introduces the second amendment and republishes the Order on the Capacity Reservation Title (TRC) and procedures set forth in the legal framework for Environmental Impact Assessment, of 14 July 2023, in respect of power generation from renewable sources projects and autonomous storage facilities.
This order establishes that the statement of injection capacity into the Public Service Electricity Network (RESP), established for autonomous storage facilities and, previously under the competence of the Director-General of DGEG (by virtue of the amendment of 5 May 2025 to the Order of 14 July 2023), will now be issued directly by the competent network operator.
This amendment results from the need expedite the procedure for obtaining this statement, considering the strategic importance of energy storage facilities for the security and reliability of the network, following the blackout that occurred in April 2025.
The order further clarifies that this statement is not equivalent to the TRC, nor does it confer injection rights to the applicant. It is merely an instrument that allows for a faster and more effective submission of requests for prior assessment or environmental impact assessment relating to autonomous storage projects through the SILiAmb platform (Integrated Environmental Licensing System). In other words, the feasibility of the licensing will always depend on obtaining a TRC in a subsequent phase, in one of the modalities set forth under Decree-Law No. 15/2022, of 14 January.
This order enters into force on the day following its publication on the websites of the APA and the DGEG.