APRIL 11, 2025
By Emma Wilson, ECW Energy & BhA team, Anna Leitner, GLOBAL 2000, & Viktoria Ritter, ÖKOBÜRO
A key assumption associated with the green transition is that fast-tracking can speed up energy transition projects. This includes efforts to reduce the amount of time devoted to public engagement and consultation. In our second Beyond Hot Air webinar on 19 March 2025, we examined the risks of limiting public debate around transition projects, and considered how Strategic Environmental Assessment could enable more meaningful public engagement in government planning processes, before individual projects are approved.
We brought together two experts working on the mining and renewable energy sectors respectively: Anna Leitner – a campaigner for supply chains and resources at the Austrian environmental protection organisation GLOBAL 2000, and Viktoria Ritter – an environmental lawyer working at ÖKOBÜRO, the Alliance of the Austrian Environmental Movement.
The energy transition and ‘strategic projects’
The EU Critical Raw Materials Act (CRMA), was adopted in record breaking time and entered into force in 2024. A key tool of the CRMA is the so-called ‘strategic projects’ label, which allows EU member states to declare mining or recycling projects as being of ‘overriding public interest‘, thereby speeding up permitting processes, and enabling them to secure political and possibly financial support. The (first) list of 47 strategic projects was published on 25 March 2025.
Research by the Austrian Foundation for Development Research (ÖFSE), Friends of the Earth Europe and the European Environmental Bureau (EEB) highlights the lack of transparency and critical public debate on the concept of ‘strategic projects’. There are concerns that the practice of labelling projects ‘strategic’ will undermine stakeholder engagement in the mining sector, especially if it provides no safeguards against poor-performing companies. This will be a problem for social acceptance and will only prolong the permitting process, through protests and legal actions.
The renewable energy sector is a few steps ahead of the mining sector in fast-tracking transition projects. The EU Renewable Energy Directive III (known as RED III) was approved in November 2023. Under RED III, member states must identify regions for the acceleration of renewables, where projects will undergo a simplified fast-track procedure, which in most cases would not require an environmental impact assessment (EIA). The deployment of renewables in such areas is also deemed of ‘overriding public interest’, limiting possible legal objections to new installations.
Strategic Environmental Assessment
With the shift towards fast-tracking energy-transition projects, strategic planning at a higher level is becoming more critical. Strategic Environmental Assessment (SEA) is the high-level evaluation of policies, plans and programmes, carried out before the process of awarding permits to individual projects. As such, it plays a crucial role in balancing stakeholder interests in the early stages of planning. Where conflicts are only addressed during EIAs, as part of individual project permitting, it is often too late, as key decisions, such as site selection, have already been made.
The EU SEA Directive was adopted in 2001 and makes SEA mandatory for plans and programmes related to the environment, e.g., a regional wind-energy zoning plan, a power grid, or a city-wide waste-management plan. These higher-level plans form the basis for subsequent permitting processes. Ideally, SEAs are conducted before any significant decisions are made, so they can inform the planning process itself. They should address needs and capacities: e.g., how much energy, or how much of a particular resource is needed; they can also consider cumulative effects. On that basis, one can then assess how much infrastructure is required and where to build it.
If the public has already been included in an SEA process, this can significantly reduce potential opposition to individual projects because citizens and civil society organisations have already had the opportunity to participate, and are sufficiently well informed about the overall situation and alternative options. As such, SEA can identify and resolve conflicts early on, ensure a more transparent and participatory process, and help to accelerate decision making.
An Austrian case study: the Burgenland wind-power zoning plan
If we want to see how good planning leads to faster decisions, we need look no further than the process of wind-power zoning in the eastern Austrian state of Burgenland [link in German]. Since 2002, the Burgenland government has been conducting strategic wind-power planning. Instead of limiting public participation to written statements at SEA level (which is also a legal option), Burgenland has chosen a highly participatory approach: ‘planning at the round table’.
In Burgenland, representatives from authorities, spatial planning and civil society assessed the need for wind power, evaluated alternative locations, and reached consensus on the best areas for wind energy development. Key issues, such as technology standards and the distance to bird migration corridors, were addressed early on, and their outcomes considered binding for all later approval procedures. More than 30 wind power projects have gone through this process, with only one single objection—and an average approval time of just 6.8 months, four months faster than average for projects going through regular procedures.
The experience of Burgenland is in contrast to the experience of Austrian hydropower projects, such as the expansion of the Kaunertal hydropower plant in Tyrol, western Austria. This was declared a ‘project of common interest’ (PCI) as transnational energy infrastructure under EU law, through a very opaque process of project selection. There has also been a controversial process of splitting the environmental impact assessment in order to push it through. The project is actively being opposed by Austrian environmental groups, who argue among other things that some of the energy storage capacity may not even be needed.
What can the European mining sector learn from the experience of the renewable energy sector?
The European mining sector can take lessons on CRMA implementation from the experience of RED III and transnational energy infrastructure. The lack of transparency and openness in the process of labelling projects as ‘strategic’ sadly appears to have been repeated. However, there are also positive lessons to be learned from the renewable energy sector.
The Burgenland case shows us the value of public debate around the table, which is something much needed on CRMA implementation, as the public is not sufficiently aware of the full picture. The public could be supportive if there was a well-managed and focused public debate to build understanding. The debate needs to be clear that we need both resource-demand reduction and a new openness to (only essential) mining within Europe, with strict safeguards. At a minimum, companies with a bad track record for environmental and human rights violations or corruption should automatically be excluded from taking part in strategic energy-transition projects.
The Burgenland case shows us that early in-depth public consultation – where key concerns are taken seriously and resolved – can speed up permitting processes. We can also learn from Austrian hydropower projects, such as Kaunertal, that trying to avoid or rush public consultation doesn’t pay off. At the national level, real acceleration can be achieved through smart strategic planning by conducting good quality SEAs at the national or regional level and addressing public concerns in these processes. This would help to address concerns about time limits in the subsequent permitting procedures.
Capacity building is essential. High-quality project permit submissions are also critical, because poor-quality submissions take up considerable time in proceedings. We need more resources and expertise within the national and local authorities, which are being asked to implement new rules and accelerate processes under both the CRMA and RED III, but are not being allocated sufficient resources to do this. Public participation needs to be informed and well organized. We also need political will – because without it, even the best strategies will fail.
If we address these challenges, we can accelerate energy transition projects while maintaining transparency and public trust.
Speakers:
Viktoria Ritter is an environmental lawyer working at ÖKOBÜRO, an independent alliance that fights for the rights of the environmental movement. At ÖKOBÜRO she focuses on the energy transition, participation of the public and how it can be achieved in an environmentally friendly way.
Anna Leitner is a campaigner for supply chains and resources at the environmental protection organisation GLOBAL 2000 (a member of Friends of the Earth International). She follows the EU Due Diligence Directive and works on several issues related to post growth, circular economy and mining.
Moderator:
Emma Wilson is an independent researcher and consultant working on issues related to public engagement, decision-making, company policy and human rights in the mining and energy sectors. She is a founder member of the Beyond Hot Air network.
Contact:
Beyond Hot Air: https://miningbeyondhotair.org/ | bha.powi@unvie.ac.at
ÖKOBÜRO: https://www.oekobuero.at/en/about/
GLOBAL2000: https://www.global2000.at/en
This blog post is based on the BhA Webinar #2, the recording of the webinar can be watched here.
