APPA Renovables has asked the Government to modify the additionality and time correlation criteria included in the draft royal decree on data centers.
The Association argues that these infrastructures should be supplied entirely with renewable electricity — not just 80%, but 100% — but believes that, during an initial stage, this objective should be demonstrated on an annual basis, in order to take advantage of the abundant renewable generation that is currently wasted in Spain.
According to the Association, excessively demanding conditions will paralyze the development of data centers in our country or force them to generate their electricity with gas outside the electrical grid.
“We are fully in favor of data centers using renewable electricity. In fact, we propose raising the target from 80% to 100%. What we are asking is that renewable consumption be certified through an annual correlation that allows us to take advantage of the clean electricity that the system is already wasting, and, as the sector develops, to consider making the measures more restrictive,” said José María González Moya, CEO of APPA Renovables.
From 80% hourly to 100% renewable annually
The project requires new facilities to cover at least 80% of their hourly energy consumption with new renewable energy installations , linking each megawatt consumed to a renewable energy source installed within the previous 18 months. The Association values the criteria of efficiency, water consumption, and sustainability, and understands the caution given the more than 12 GW of access granted since 2021 and the speculative applications, but believes this design does not reflect the reality of the system.
The requirement does not simply mean installing 0.8 MW of renewable energy for every megawatt demanded. The constant energy consumption of data centers and the variability of wind and solar power necessitate combining technologies, oversizing generation capacity, and utilizing energy storage. A simulation developed by APPA, using hourly profiles for 2025, four-hour battery storage, and 90% efficiency, estimates that for every MW of data center, 3.93 MW of solar, 3.69 MW of wind, and 3.65 MW of battery storage (14.6 MWh) will be required: 11.26 MW in total.
Unattainable figures
These figures are not only inefficient from an energy and economic standpoint, they are also unattainable. To meet Spain's Artificial Intelligence Strategy, which estimates a demand of 4,000 MW by 2030, more than 15,000 MW of new wind power capacity would be needed. This represents an installation rate five times the current one.
APPA Renovables proposes initially requiring 100% renewable energy on an annual basis, temporarily relaxing the additionality requirement, and, in the future, making these criteria more ambitious as networks, storage, manageable renewables, and demand growth advance.
“We are not proposing to lower the target, but to increase it in a viable way. 100% annual renewables is much more ambitious in terms of volume than 80% hourly, it is feasible for developers, and it avoids requiring, from day one, a system up to eleven times larger than demand. This barrier can determine whether the investment is made in Spain or goes to another country,” explained González Moya.
“Additionally, requiring compliance with the requirement individually for each data center is highly inefficient for the system and for the implementation of renewables; this will hinder social acceptance not only for data centers, but also for new renewable developments,” denounced the CEO of APPA Renovables.
New power generation capacity that fails to utilize the electricity already being lost. The additionality requirement also fails to address the main imbalance currently facing the Spanish electricity system. The sum of technical and economic losses means that more than a quarter of the electricity that renewable energy installations could produce is currently being wasted.
In this context, requiring that all new demand be linked exclusively to plants built specifically for it is not only inefficient, it also prevents the use of renewable electricity that is already available, but which cannot be integrated into the system due to a lack of demand, networks, storage or flexibility.
The new additionality criterion also raises a lack of coherence with the framework applied until now.
The regulation linked the request for grid access for new demand to existing generation facilities (up to 50% of the generation capacity) and, in light of these new criteria, these generation facilities cannot be used in cases where the projects have been operating for more than 18 months.
The new regulation should recognize this reality and avoid inconsistencies for projects initiated under the previous framework.
Overly stringent regulations can make gas more attractive. APPA Renovables warns that linking additionality and time-of-use correlation to grid access could push operators to generate their own electricity with gas outside the grid.
It is not a theoretical risk: several multinational technology companies have recently announced new investments in fossil fuel generation facilities and even entry into the gas turbine manufacturing business to meet their demand.
“A regulation designed to boost renewable energy consumption could end up incentivizing off-grid gas plants if it is too demanding. This could lead to less renewable energy integration, more emissions, and an energy system running parallel to electricity planning,” warned the CEO of APPA Renovables.
Renewable hydrogen and biomethane, solutions for the future
Although stricter, the government uses the requirements for renewable hydrogen as a benchmark. But its experience also suggests progressively applying additionality and temporal correlation. In 2020, Spain aimed to install between 300 and 600 MW of electrolyzers in 2024 and 4 GW in 2030, while the EU set a target of 6 GW for 2024.
Delegated Regulation (EU) 2023/1184 introduced additionality and temporal and geographical correlation, but temporarily allowed the use of existing facilities and maintained monthly correlation until 2029, postponing hourly correlation to 2030.
Despite this, in 2024 there was barely more than 200 MW installed in Europe, far from the target of 4,000 MW.
Another renewable gas currently under development that could play a significant role in the future, alongside cogeneration and distributed generation, is biomethane. With a potential of 25-35 TWh per year, biomethane could power high-efficiency cogeneration plants, providing backup and flexibility for data centers.
“Spain can turn its abundant renewable energy into a competitive advantage. But if we confuse ambition with rigidity, we will lose this opportunity. We want 100% renewable data centers, connected to the grid and taking advantage of the competitive price of clean electricity that we currently waste; not isolated centers burning gas,” González Moya concluded.