Simplifying and Speeding Up Permitting

A key enabler for the decarbonisation of the cement industry

The CEMBUREAU 2050 Carbon Neutrality Roadmap sets out the decarbonisation levers across the five stages of the cement and concrete value chain (clinker-cement-concrete-constructioncarbonation). Achieving the GHG emission reduction targets requires the development of a variety of technologies and the putting in place of innovative projects. Most of the decarbonisation projects in the cement sector entail an increase in electricity demand and will therefore require a strong and fast availability of renewable energy sources some of which will be developed on-site our industrial plants.

The granting of a permit is an indispensable step in the early stages of each of these decarbonisation projects. However, permitting times strongly vary between Member States and often slow down the lead times for projects.

CEMBUREAU is pleased to see that the need to simplify and fast-track the permitting process, reduce the red tape and address the lack of human resources capacities is addressed by the European Commission both in the Proposed Net Zero Industry Act and in relation to the development of renewable energy projects. Given the specific and limited scope of both initiatives, we strongly plead in favour of extending the permit facilitating principles to each and every project that contributes to the decarbonization agenda.

The below table provides more detailed explanations on each of these topics1. CEMBUREAU urges EU and national policymakers to take into account these requirements in their upcoming initiatives.

1 The items set out in the table are inspired on the EU Commission’s Staff Working Document “Guidance to Member States on good practices to speed up permit-granting procedures for renewable energy projects”, SWD(2022)149final, 18 May 2022 and on the Net Zero Industry Act proposed by the Commission on 16 March 2023, COM(2023)161final.

Simplification of permitting processes
  • Assess simplification potential in EU legislation when it comes to permitting.
  • The permitting procedures of the Net Zero Industry Act should apply to the entire value chain of strategic net zero technology, not only to the manufacturing of these technologies. For instance, CO2 storage, CO2 transport and the installation of carbon capture facilities on industrial sites, as well as the development of renewable energy on industrial sites, should all be covered by the easier timelines.
Cooperation Mechanisms
  • All existing and future cooperation mechanisms with Member States should be reinforced – for instance, the Net Zero Platform created by the Net Zero Industry Act can be an important tool to develop best practices and smoother permitting procedures.
Introducing a permit request
  • Designate a single point of contact within the administration who oordinates the different competent services (“one-stop shop”).
  • Introduce a single application procedure for several permits (e.g. electricity production; approval under nature conservation law; occupational Health & Safety permit; building permit)…
Speeding up permitting process
  • Cap the duration of the different steps in the Environmental Impact Assessment (EIA) procedure, e.g. by reducing the need for expert opinion in areas with no or irrelevant adverse effects.
  • Shorten the period for final approval decision once the developer has submitted the EIA (max 1-2 months).
  • Allow adaptation of technological specifications – by allowing applicants to apply for a range of technological parameters – between permit application and permit granting (to avoid need to start over again when technology evolves).
  • Increase the number of competent staff in relevant authorities.
  • Allow positive administrative silence, whereby no reaction within a given timeframe by one authority to another is considered an approval.
Simplify access to the judicial system
  • Faster processing of litigation cases (e.g. one instance procedures where possible).
  • Apply deadlines in litigation procedures to avoid unnecessary delays.
  • Limit abusive litigation.
Regulatory sandboxes
  • Allow developers to test new technologies and business models that may only partially be compatible with the existing legal and regulatory framework to allow regulators to familiarize themselves with particular innovations so that they can adapt the regulatory environment to accommodate them.
Public acceptance
  • Organize public consultation upfront in the process, including on location of the project.
  • Create a regulatory framework for project developers to voluntarily contribute to increase the social benefits to citizens (kindergarten; health services) or infrastructure (streets, public infrastructure)
  • Continue the work on public acceptance of key technologies – e.g. renewable energy, carbon capture technology – at pace.