An Evaluation of Significant Legislative Amendments Concerning Renewable Energy Investments

Significant Amendments in Energy and Land Legislation: What Do They Mean for Investors and Property Owners?

On July 24, 2025, the Law No. 7554 on Amendments to Certain Laws was published in the Official Gazette (Issue No. 32965). This law introduces notable amendments to several key pieces of legislation, most prominently the Pasture Law (Law No. 4342), the Renewable Energy Law (Law No. 5346), and the Electricity Market Law. While these amendments aim to accelerate renewable energy investments, streamline bureaucratic processes, and facilitate land acquisition, they also raise potential legal disputes that merit careful consideration. This article explores the legal implications of these changes for the energy sector.

Expanded Expropriation Powers for Renewable Energy Projects

Article 14 of Law No. 7554 adds paragraph (k) to Article 14 of the Pasture Law. This new provision allows the allocation of pasturelands, highlands, and wintering grounds for renewable energy source areas designated under the Renewable Energy Law. According to the amendment:

"Upon the request of the relevant directorate, and with the approval of the commission and the treasury office, the governor may change the allocation purpose of lands required for renewable energy resource areas designated under Law No. 5346. Such lands shall be registered in the name of the Treasury, while foundation-owned pastures shall be registered in the name of the foundation."

This amendment effectively expands the State’s expropriation authority, enabling the use of pasture and similar lands for renewable energy projects. While this represents a crucial step toward promoting clean energy production and reducing foreign dependency, it also significantly broadens the government’s "eminent domain" powers. For large-scale wind and solar projects, this change will ease land acquisition processes, but it is likely to lead to disputes over property rights and an increase in expropriation-related lawsuits.

Accelerated Permitting for Renewable Energy in Forest Areas

Article 15 of Law No. 7554 amends Article 8 of the Renewable Energy Law, introducing new procedures for establishing wind and solar power plants on forest-designated lands. Key points include:

• Permit durations: Permissions can now be granted for the duration of the pre-license, with automatic extension through the production license period.

• Measurement and drilling activities: These activities may be carried out without requiring a pre-license or production license.

• Application deadlines: Authorities must conclude permit applications within a maximum of 60 days.

• Ornithological studies: For projects located on primary bird migration routes or bottlenecks, ornithological observations are mandatory.

  
  

These changes aim to reduce uncertainty in project planning and impose a "reasonable time" obligation on the administration to prevent undue delays. At the same time, the mandatory ornithological observation for certain areas reflects an attempt to balance renewable energy development with environmental protection.

Centralization of Zoning and Licensing Processes

Article 16 of Law No. 7554 adds an Additional Article 1 to the Renewable Energy Law, granting the Ministry the authority to directly approve zoning plans, parceling plans, and construction permits for licensed wind and solar energy projects. Additionally:

• Plans approved by the Ministry come into force upon approval and are published online for 15 days.

• The Ministry may also issue occupancy permits, building usage permits, and workplace opening licenses for such projects.

• Urgent expropriation court orders can be used as documentation in licensing applications.

  
  

While these changes aim to eliminate delays caused by local governments, they significantly limit municipal planning powers. This raises potential constitutional debates under Article 127 of the Turkish Constitution and Article 3/b of the Municipal Law No. 5393 regarding administrative autonomy of municipalities.

Conclusion

These amendments represent an important step toward expediting renewable energy investments. However, they also expand State authority in ways that may trigger new legal disputes, especially in areas such as expropriation, municipal autonomy, and environmental protection. Stakeholders in the energy sector should closely monitor how these provisions will be implemented in practice and seek legal counsel to navigate potential risks.

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