The conditions for the expansion of renewable energy (RE) on land and at sea have never been better. The costs of setting up renewable energy compared to other energy sources are falling, and solar and wind energy are now cheaper than fossil fuels in terms of lifetime costs. Still, we are not on track with a 100% green electricity supply today. In 2022, 54% of Danish electricity production was based on wind energy and 8% on solar energy. The rest came from biomass, biogas, coal, natural gas, oil and waste. Furthermore, the need for clean renewable energy is expected to increase sharply in the coming years. Partly because the climate crisis makes it necessary to accelerate the phasing out of fossil fuels, and partly because in step with the electrification of society, there is an increasing demand for green electricity. According to the Danish Energy Agency's analysis assumptions for Energinet, Denmark's total electricity consumption is estimated to be over 200 TWh in 2050, which is five times greater than the current electricity consumption (36 TWh). The expansion of renewable energy cannot therefore proceed too quickly.

Even so, the expansion of renewable energy has almost come to a standstill, and virtually no new wind turbines have been set up on land in recent years.

It takes an average of 4-6 years to get new land-based renewable energy projects approved in the EU outside the acceleration areas from the RePowerEU plan, and in Denmark it is difficult in many places to connect new solar cell plants and wind turbines to the electricity grid, which suffers from capacity challenges. But there is also considerable political concern that environmental approvals and consideration for nature and biodiversity are a major barrier to the roll-out of renewable energy projects. This concern must be addressed so that consideration for nature and biodiversity does not have to become a stumbling block for the roll-out of wind and solar. This position paper contains a number of recommendations on how to accelerate the deployment of renewable energy on land without compromising on environmental considerations.

A strong cross pressure

The delays in projects for new solar cells and wind turbines have several explanations. It is often about local citizens' concerns and criticism of the RE projects' local impact on nature and wildlife. The number of complaints based on biodiversity impact from renewable energy projects has been increasing. At the same time, intensive land use and resource extraction are, according to the Biodiversity Council, the most important causes of the deterioration of Danish biodiversity. It is a cross-pressure of various considerations that must be addressed.

Because we are not alone in a climate crisis that calls for an accelerated expansion of solar and wind energy. We also find ourselves in a human-driven biodiversity crisis, which puts the global and Danish flora and fauna under pressure. When species become extinct, not only are vital ecosystems destroyed, which form the basis for us humans and the world economy, but we also lose some of what makes nature beautiful and valuable.

The conflict between climate and biodiversity concerns risks growing in the coming years as the battle for land intensifies. We are therefore in both a climatic and ecological crisis, where we must find new sustainable answers, so that in the future we can live safely within the planetary boundaries instead of planning facilities that worsen the crises. It requires a more holistic approach to problem solving.

At the same time, it is indisputable that it is urgent to find effective answers to the climate crisis, and we cannot solve it without areas being set aside for much more solar and wind energy on land. It is necessary to be realistic in relation to the scale of the challenge we face, because Denmark has to make a profound transformation of our energy system away from dependence on fossil fuels.

Green Transition Denmark estimates that there is a need for a sevenfold increase in renewable energy towards 2030, as it will be a decisive step towards building a 100 per cent renewable energy system in Denmark without fossil fuels. This is more than the quadrupling of onshore solar and wind that a broad majority in the Danish Parliament is betting on. Although the Green Transition Denmark is planning for a more ambitious expansion with renewable energy, it also recommends that all renewable energy projects in the future will be obliged to take into account consideration for nature and the promotion of biodiversity. This must be done at the same time that a much smoother and more agile case processing is introduced.

Political framework agreement points forward

It is not fruitful to set up the climate and biodiversity crises as competitors. One should not regard the two considerations as a zero-sum game where there can only be one winner. Because the crises are connected, and they must be solved together. The biggest threat to both problems is fossil fuels, which are behind the majority of man-made climate change, which puts nature under severe pressure. This calls for a holistic approach in solving the two crises. But how is it done in practice? There was a provisional political proposal for 12 December 2023.

Here, the government and a broad majority of parties in the Danish Parliament entered into an agreement to promote renewable energy expansion on land, so that extra speed can be put into the green transition. The agreement establishes a framework for the establishment of large energy parks, increases the current compensation for neighbors and local communities for renewable energy expansion and will, with a future law, ease the area protection in the setting up of renewable energy.

The agreement provides for minor relaxations of the national rules in the field of nature and the environment and within cultural heritage conservation, etc. This applies, among other things, to conservation in the Nature Protection Act chapter 6, peace forest duty, lake and river protection lines in § 16 of the Nature Protection Act, the forest building line in § 17 of the Nature Protection Act, church building lines in § 19 of the Nature Protection Act and stone and earth dikes in § 29 a of the Museums Act. These relaxations may be necessary to promote a faster approval process about new solar cells and wind turbines.

But you will still be obliged to comply with the EU rules in the nature and environment area, and there will be changes to the current rules for exemptions on §3 areas, which is why overall a good balance has been found. It is open to the possibility that, in certain cases, exemptions from the Nature Protection and Forest Act can be made if there is no viable local alternative, and the Green Transition Denmark finds it sensible to allow such exemptions under the condition that a equivalent natural area elsewhere. The basic principle must be that we as a whole must give at least as much back to nature as is taken.

Green Transition Denmark believes that the agreement is an important step to promote a faster installation of solar and wind energy, but the agreement could well be more ambitious. The Council therefore recommends that the agreement be followed up with further measures.

Legislation must promote respect for nature

If we are to turn the current loss of biodiversity into progress and at the same time ensure the green transition, there is a need for new legislation in the area. In the Biodiversity Council's annual report from 2022, the overall conclusion is that the current biodiversity across species, habitats and natural processes is not sufficient for the maintenance of biodiversity in the long term. In addition, the Biodiversity Council concludes that there is currently no more than 2,3% of the Danish land area which contributes to the objectives of protected areas. It is crucial that the legislation reflects Denmark's obligations in the Kunming-Montreal agreement on biodiversity and the EU regulation on nature restoration. The Montreal Agreement sets 23 targets for 2030 and deals with, among other things, the protection of a minimum of 30% of the total land and sea areas that are important for biodiversity and ecosystems in 2030. The EU regulation requires member states to draw up a national recovery plan, initiate recovery initiatives for land and sea areas in poor condition and improve the habitats of species and birds.

There are currently too many watertight bulkheads in the current regulation between renewable energy, biodiversity and agriculture and forestry. By integrating biodiversity as a parameter in the legislation for RE expansion, you will automatically have to consider considerations early in the process. It can help to create more efficient solutions that affect nature as little as possible, and will simultaneously mean a faster roll-out of RE projects, as delays caused by criticism and complaints are avoided.

Wiser use of Denmark's land

Denmark is a small country geographically. Many people say that there has been increased competition and almost a battle for land use between buildings, energy, agriculture, forests, infrastructure, and all too often nature is put at the lowest level. Denmark is already the country in Europe where nature is the most scarce. It is estimated that between 130%-140% of Denmark's area has already been planned. But you don't have to see land use as a battle where the zero-sum game prevails. An option does not necessarily mean an opt-out. Instead, there is a need to think together and use Denmark's land in the best possible way, where the expansion of renewable energy takes place in balance with other considerations, including nature and biodiversity. In this way, more winners are created. Having said that, today we use far too much of our total land on feed and animal production. There is a need for more space for forest and nature to make room for biodiversity, which simultaneously creates recreational value for citizens.

Considering the climate crisis and the energy needs of the future, the Green Transition Denmark believes that it is a fixed task to make room for that amount of renewable energy on land. In 2021, solar cells and onshore wind turbines made up the equivalent of 0,8% of the agricultural area, and are expected to make up 2,1% of the agricultural area in 2030 based on a fourfold increase in production from land-based renewable energy.

The council has calculated that Denmark needs a sevenfold increase in solar and wind energy in order to be able to lay out a realistic plan that can make Denmark 100 per cent. self-sufficient with renewable energy. It is possible to achieve a sevenfold increase in capacity without confiscating more than 3-3,5 per cent. of Denmark's land area. Wind turbines can coexist with agriculture and take up very little space, and if several of the old turbines are replaced with larger turbines, it is possible to achieve a much greater effect per acres. Solar systems must not just be set up on bare land, but to a much greater extent above car parks, on large roof areas and along motorways, so that a supply of renewable energy close to the city is also achieved.

Space can easily be found for such a significant extension with solar and wind on land. Today, the production of biofuels accounts for as much as 3 per cent. of the agricultural land, and it would be far more energy efficient and better for the climate if this land were used for the production of clean renewable energy. If the politicians want a certain production of energy rapeseed for 2nd generation biofuels, it is also possible to find space on other agricultural areas, including low-yielding marginal lands.

Today, over three quarters of Danish agricultural land is used to produce feed for animals, but the Green Transition Denmark has presented a plan for a major restructuring of Danish agricultural and food production, where meat production and the number of animals are significantly reduced and replaced by more plant-based foods , so that at least a quarter of the agricultural area (680.000 ha) can be set aside for open nature (which is grazed for the benefit of biodiversity) and forest. Some of these areas – including the wet low-lying soils – can e.g. are used for the installation of solar cell systems if they are considered together with regard to biodiversity.

Long-term national spatial planning

There is today a decidedly silo approach in spatial planning, where projects regarding renewable energy, nature and biodiversity are thought of separately. Biodiversity should be considered in connection with climate adaptation and other changes in land use. The sweeping changes needed to turn the loss of biodiversity into progress require a review of existing incentive structures that harm biodiversity and the establishment of new incentive structures that support biodiversity. In addition, renewable energy and nature should take precedence in spatial planning over new motorways or biomass projects. One could e.g. make a planning hierarchy of areas where VE should not be set up. These can be areas that are classified under world natural heritage, untouched forest, Natura 2000 and §3 areas. It is time for new lines to be drawn and new pieces to be shaped in Denmark's area puzzle.

Large wind turbines in production forest

The nature protection legislation must be changed so that wind turbines are also opened up in production forests in the future. The development of wind energy will thus be able to be coordinated to a greater extent with production forests. Since the purpose of production forests is wood production, the forests already have a low degree of biodiversity. The installation of renewable energy will thus have a minimal impact on biodiversity and will at the same time be able to function as a source of income for the forest owner when wood-based bioenergy is phased out. In order for this to succeed, it requires an amendment to the Forestry Act, which today prohibits the forest owner from establishing facilities that are not necessary for forest management. Counterclaims should be made to producers so that they are obliged to ensure increased biodiversity in the same forest, e.g. by creating small biotopes with untouched forest, dead wood or similar in the production forest - or at least expanding the forest. The construction of wind turbines should be considered in the case of new forestry, where recreational conditions have not yet been built up for the new forest area, and one must therefore expect that the resistance will be less.

Bet on common thinking in the countryside

In addition, one should consider setting up solar cell systems on low-lying land. By combining the extraction of low-lying soils and solar cells, a plurality of effects can be achieved. You reduce CO2 emissions from the low-lying soil and produce green energy. This is an effective way of accessing the limited amount of space, as this makes optimal use of the space and meets several considerations. Taking land for use for, among other things Solar cells do not therefore have to mean that you get less nature – quite the contrary. A significant obstacle to this not happening already today is that in the process one goes from agricultural tax to business taxation. The incentives are directed in the wrong direction. Therefore, from a purely tax point of view, the land used for green energy should be equated with agricultural land, when it comes to the low-yielding lands and low-lying lands. Solar cells must not be installed on good agricultural land.

On the other hand, with solar cells on non-wetted areas, clear requirements should be made for the use of the areas for e.g. grazing small biotopes or pollinator mixtures and possibly to the solar cells' environmental impact, such as the release of problematic substances to the earth over time.

More RE production in the cities

It is important that agricultural land is not only used for the development of renewable energy. In the coming years, there should be a much greater focus on the utilization of land in the cities and business areas - especially buildings, as they still represent an unfulfilled potential. In future, the installation of solar cell systems over car parks and on large roof areas should take place on a larger scale than now. House roofs and industrial roofs function as a free and efficient site for renewable energy. In this way, the joint consideration of all land types can contribute to ensuring efficient land use and production of renewable energy with an eye to biodiversity. Access to erecting, operating and owning solar cells on roof areas should be freed up. § 37 and § 38 of the Property Registration Act should be amended so that solar panels on roof surfaces are no longer registered as an integral part of the building, but can be separated as a separate floor with separate property rights. There must also be better opportunities to rent out rooftop areas to solar cell developers and open up for pledging of the roof-based solar cell systems. In the coming years, there is also a need for a massive rollout of solar cells on municipal roofs and large industrial buildings, and this has the advantage that they do not draw so much on the grid capacity in densely populated and suburban areas. Although roof-based solar installations are 2-2,5 times more expensive than field installations (calculated as the cost of producing electricity over the entire lifetime of the installation), the socio-economic costs should be weighed against the fact that rooftop installations cause less visual nuisance and are often close to electricity consumption.

Likewise, solar cell systems should be considered when noise screens are built at motorways in urban areas, and this can help to promote more local energy production in areas with a high demand for green electricity. At the same time, it can help co-finance noise screens, which can reduce noise nuisance for the local residents.

Previous involvement

Citizen resistance is often mentioned as one of the other main challenges in setting up RE, and there have also been a number of cases where local citizens or environmental organizations have been able to stop RE projects citing the protection of nature and the local population of endangered species animal species etc. However, it is not an insoluble contradiction. But the vast majority of Danes are positive towards the expansion of renewable energy. A study from Aalborg University shows, for example, that 74% of Danes support more wind turbines in their municipality. However, there is still a group of citizens who oppose the renewable energy projects.

Common to the challenges is that many of them can be solved by involving citizens, municipalities and other stakeholders earlier in the projects. If you think together and integrate the various considerations right from the start, you can create a common anchoring of the RE expansion and utilize local knowledge. It can help create a momentum for renewable energy projects through strong partnerships and dialogue, where space is also created for nature restoration. Green citizens' councils can be set up in the municipalities with representatives from citizens, organizations and companies to facilitate dialogue, promote citizen involvement and make faster proposals to the municipal council for approval of new projects. Local citizens can be invited into new green projects as shareholders and stakeholders. Alternatively, energy producers can establish beneficial arrangements with local citizens for e.g. cheap charging with green power for electric cars, investment in new nature and biodiversity areas or construction of sports halls or the like, so that the locals feel that the green transition is a plus-sum game and not a zero-sum game. However, it is important to have transparency in the process, so that renewable energy developers play a role with fair, citizen-involving offers in municipal tenders for solar cell systems and the installation of wind turbines.

The local communities play an important role in the deployment of renewable energy. Partly because the citizens are the ones who must be able to see locally the advantages of the installation of solar cells and new wind turbines, where concerns about the environment, noise nuisance, landscape and aesthetic changes must be addressed. And partly because the municipalities are an important authority for environmental assessments and permits. At the same time, it is a problem that until now the municipalities have had too few financial incentives to speed up the processing of cases and to say yes to more renewable energy.

Some of this problem has been sought to be addressed by the parties in the Folketing in the agreement of 12 December 2023, where a significant increase of the compensation schemes in the green pool and VE bonus. These are respectively increased by 150 per cent. and 50 per cent, which is an important advance. In the green pool, the installers of renewable energy plants must pay an amount per installed MW for the municipality where renewable energy facilities are installed. It can also be to the municipality or municipalities that have the right to object to open-door offshore wind turbines. The municipality administers the funds, and the funds can be used widely for municipal initiatives.

But the Green Transition Denmark believes that one should go one step further and abolish the green pool and introduce initiatives that provide the municipality with ongoing income instead of the one-off amount that is currently given via the green pool. Specifically, the municipal earnings from land taxes and business taxation from new solar and wind should be exempt from the municipal equalization scheme, and the extra revenue should be allocated to green investments in the local area. Where the green pool is a one-off payment upon establishment, the Council proposes that the municipalities receive 5 øre per produced kWh during the lifetime of the solar cell or wind turbine. This proceeds must also be exempted from the municipal equalization scheme, but the municipalities must conversely be obliged to reinvest the proceeds in green conversion and nature measures in the local area. The increased cost for the installers to the municipalities must come at the same time as reducing their costs for network expansion, which have increased significantly with the introduction of producer payments and feed-in tariffs per 1 January 2023.

The necessary expansion of the electricity grid should instead be covered to a greater extent via taxes on what we want to get rid of, namely the fossil emissions. For example, it would be obvious to use the proceeds from the diesel tax to lower producer payments to the electricity grid.

A number of projects for solar and wind energy are being delayed unnecessarily. Therefore, the Green Transition Denmark recommends that a much faster approval process be created for RE projects and a streamlining of the appeals process, so that the same case is not raised multiple times. It takes too long from case processing to approval.

The time for case processing, approval and installation of solar cell systems on bare land should be able to be completed in half to a full year, where today it often takes 2-3 years. Green Transition Denmark recommends that a more flexible approval process be made, where citizen involvement takes place very early, and complaints are dealt with in parallel with environmental investigations. At the same time, a more efficient consultation and complaints process should be ensured.

The NEKST working group has recommended here that the consultation period for environmental assessments for reprocessing be reduced from eight weeks to 30 days, which is the EU's minimum requirement. However, a longer hearing of up to eight weeks is opened for complex cases. It is a sensible solution, which the Green Transition Denmark supports. When an environmental assessment is made, it is important to take a broader holistic view, so that it is not just the impact of the local areas that is included. The individual bat in the local area should not be enough to put an end to new renewable energy projects, and you should basically look at the environmental effect for the population as a whole.

Much more offshore wind with clear environmental requirements

Future offshore wind farms in Denmark must not compete down to the lowest possible common denominator. It is important in all tenders and projects that clear demands are made for nature and biodiversity from the start. Competition must not only be based on price, but in all tenders one must also compete on selected environmental parameters in relation to measurable CO2 emissions in the life cycle, a minimum 40-50 year lifespan for the turbines, resource consumption, biodiversity etc., so that the offshore wind turbine products also promote innovation with on nature.

Private developers should also be required to ensure a high recycling rate of wind turbine foundations and components after the end of the concession period, as well as investments in research and development. During feasibility studies and construction, proper consideration must be given to marine mammals in the areas, so as to minimize the negative side effects on the local ecosystem during the construction phase. Solutions to these challenges should be left to consortia. Consortia that will deliver a bid, assessed on how they will solve the challenges.

After construction, the new offshore wind turbine foundations can function as artificial rock reefs. They can contribute to better conditions for the sea's biodiversity if the foundation is designed with nature in mind. Wind energy consortia, fishermen and authorities should cooperate on the exchange of data with the fishing industry, so that energy islands and offshore wind farms also secure new spawning areas for the benefit of the fish population.

One should also promote more collaboration so that new innovative solutions for system integration can be found that optimize use and minimize resource wastage. Including the sharing of costs for transmission lines to land.

Jens Dahlstrom Iversen
Senior advisor – Energy & Climate
Phone : 3318 1932
Mail: jens@rgo.dk

Julie Bangsgaard Abrahams
Senior advisor – Energy & Climate
Phone : 3318 1944
Mail: julie@rgo.dk