This is an extract from a recent paper “Supporting Denmark’s island communities in the green transition. Creating a proportionate framework for Natura 2000 in small-scale renewable projects” published by Clean energy for EU islands.
Denmark is recognised as one of the European leaders in the green transition, with a long-standing political and societal consensus on the need for climate action. The country has committed to reducing its greenhouse gas emissions by 70% by 2030 compared to 1990 levels and aims to become climate-neutral by 2050. The 2022 government advanced climate neutrality to 2045, aiming for 110% GHG reductions by 2050. These overall targets are grounded in the Danish Climate Act (Klimaloven), adopted in 2020. The Act, in general, balances green transition with maintaining welfare. Under the Climate Act, Denmark set up the Danish Council on Climate Change, an independent expert body, to assess the government’s climate efforts.
In addition, the Act also establishes a system of annual progress reporting. One of the main pillars of Denmark’s green transition is the expansion of renewable energy production. In 2017, Denmark achieved a wind energy world record: 43,4 % of the Danish power was produced solely by wind energy. In 2022, more than 60% of Denmark’s electricity came from wind and solar energy, with ambitions to further increase both offshore and onshore capacity. The government’s Energy Agreement and Climate Action Plans support this trajectory, emphasising not only technological deployment but also decentralisation, public participation, and community ownership of energy systems.
Within this national context, the Danish islands play an important role. Their geographic isolation and reliance on local infrastructure make them ideal sites for showing self-sufficiency in energy production. Moreover, island communities have shown leadership in adopting renewable technologies, often ahead of the national curve. The most well-known example is Samsø, which became Denmark’s first “renewable energy island” by transitioning to 100% renewable electricity and heating within a decade, largely through locally owned wind turbines and biomass plants. Besides Samsø, other islands such as Fejø, Ærø, Bornholm, and Venø are also pursuing ambitious sustainability agendas. These include community wind and solar projects, district heating systems based on biomass or electric heat pumps, and energy storage pilots.
In addition, many islands are active participants in EU and national initiatives, such as the Clean Energy for EU Islands Secretariat or the DK2020 climate planning framework, which provide technical support to local governments developing climate-neutral action plans. The experience of Denmark’s islands shows the viability and scalability of decentralised energy transitions. These communities serve as examples of citizen engagement and cross-sector collaboration. Their efforts contribute to achieving Denmark’s national climate goals but also enhance energy security, economic resilience, and local empowerment. To pursue the success of the islands’ initiatives, it is necessary to ensure coherent policy support, streamlined permitting procedures, as well as investment in infrastructure and capacity building.
Natura 2000
Natura 2000 is the cornerstone of the European Union’s biodiversity policy. It is an EU-wide ecological network of protected areas established under the Birds Directive (2009/147/EC) and the Habitats Directive (92/43/EEC). The primary aim of this framework is to ensure the long-term survival of Europe’s most valuable and threatened species and habitats, both on land and at sea. In Denmark, Natura 2000 sites comprise habitat areas (habitatområder), bird protection areas (fuglebeskyttelsesområder), and Ramsar-designated wetlands.
Projects or plans that could significantly affect a Natura 2000 site either directly or indirectly must undergo an appropriate assessment under Article 6(3) of the Habitats Directive. This is a preventive tool based on the precautionary principle: the project proponent must prove that the activity will not have adverse effects on the site’s integrity. If such effects cannot be ruled out, the project can only proceed under strict conditions set out in Article 6(4), including proof of overriding public interest and provision of compensatory measures.
As clarified in the Danish national guidance issued by the Ministry of the Interior and Housing, new wind turbine installations or major expansions are generally prohibited within Natura 2000 sites unless an exemption (dispensation) is granted under exceptional circumstances. The guidance underlines that while societal interests such as the deployment of renewable energy are recognised, they do not automatically outweigh nature conservation objectives. Any proposed development must clearly demonstrate that it will not adversely affect protected habitats or species, or it must include adequate compensatory or mitigation measures.
Nevertheless, the guidance allows for context-sensitive planning. For instance, if a wind turbine is proposed on farmland with no significant presence of protected species or habitats, and where cumulative impacts are minimal, authorities may assess the potential for derogation on a case-by-case basis. Under Section 2(5) of the Planning Habitats Executive Order, the Minister of the Interior and Housing may, in special cases, grant a derogation from the prohibition on planning in a Natura 2000 area. Furthermore, Section 2(3) clarifies that the planning prohibition does not apply to line transfers of overhead power lines through areas designated solely as habitat sites.
Consequently, Natura 2000 rules do not automatically ban new projects. Instead, Natura 2000 follows the precautionary principle, meaning project developers must show that their plans will not harm protected nature or take steps to reduce any harm. This makes sense in sensitive areas, but applying the same strict rules everywhere, even in low-risk places, can create unnecessary obstacles for small community projects. This issue has become particularly important on Denmark’s islands, where small-scale wind turbine projects are often delayed or blocked despite being located on previously developed or agriculturally used land.
Case Studies
Fejø – Skalø Windmill Proposal
Fejø is a small island in Lolland Municipality that shows both the strong local ambition and the challenges Danish islands face when trying to develop renewable energy initiatives. The Fejø Island Transition Team wishes to install two modern wind turbines to replace older ones and help the island produce its own clean energy. But strict rules related to land use, the environment, and planning make this difficult. Parts of Fejø are covered by Natura 2000, and the island is also affected by Danish laws protecting the coast and environment. The Fejø Transition Team has looked at up to nine possible turbine layouts, with total capacities between 2 and 3 MW. These include one or two large turbines (like the Vestas V80 or Enercon E82) or several smaller ones (like the Vestas V52), with possible locations on the nearby island of Skalø, Østerby or Vesterby.
Since the proposed sites are close to Natura 2000 areas, salt marshes, and bird migration paths, a full Environmental Impact Assessment is required. Skalø, for example, is entirely within a Natura 2000 site and falls under the coastal protection line, which generally prohibits new construction within 300 metres of the coastline unless a dispensation is granted under the Nature Protection Act. This means that replacing an existing turbine here would require multiple exemptions from both Natura 2000 and coastal protection rules, adding complexity to the permitting process. The Østerby sites are close to the coastline and residential areas, so they must meet strict rules like staying at least 300 metres from the shore and at least four times the turbine’s height away from homes.
To move the project forward, the Fejø community has looked for suitable sites on farmland with little environmental risk. They have also started early discussions with the local authorities. Bird studies suggest that the project would have very little impact on migratory species, which could allow for a case-specific exemption under the Natura 2000 rules. The community has also proposed removing the old turbines as part of the project to improve the island’s landscape and reduce the overall environmental impact. The project is supported by the Clean Energy for EU Islands Secretariat, which selected Fejø for technical assistance. The Secretariat confirmed that the project is technically possible, provided that planning and nature protection requirements are met. To address legal and social aspects and barriers, several measures are considered, such as habitat replacement, benefit-sharing schemes under the Danish Renewable Energy Act, as well as community engagement activities to strengthen local support.
Venø – local planning barriers and opportunities for renewable energy
Venø is a small island in Struer Municipality, located in the Limfjord, with fewer than 200 residents. Despite its size, Venø has a strong local ambition to become carbon-neutral, supported by the island’s Transition Team and its Clean Energy Transition Agenda (CETA) developed in 2022. A key part of this plan is to install a new, community-owned wind turbine. Until around 1985, Venø had three small wind turbines in joint ownership among the island’s residents. Struer Municipality has included Venø’s interest in wind turbine installation in its development plan, pending changes in national policy regarding planning legislation. However, the island faces several barriers.
One of the main challenges is that Struer Municipality has, for the time being, not designated Venø as a wind energy development area in its current spatial plan. If the municipality decides to allow a wind turbine on Venø, the planning conditions require the installation of not just one, but three turbines. Two possible areas for wind development have been identified. One of the potential locations, situated at the southern end of the island, requires habitat exemptions, while the other option only requires a standard planning process and exemptions that may become possible through anticipated legislation in 2026.
One turbine could cover the island’s self-sufficiency needs. Yet this would require a change to the municipal plan or a formal dispensation, as any new wind turbine project requires a full permitting process, including an Environmental Impact Assessment and a new municipal planning procedure. Most of the island is restricted due to coastal protection zones, Natura 2000 designations, dwelling setback requirements, and water protection areas. The most promising area is in the south of the island, where there are fewer conflicts. However, environmental screening and further assessments would still be needed especially because of nearby salt marshes and bird migration routes. National regulations require that turbines are placed at least 300 metres from the coast and at least four times the turbine’s height from any nearby dwellings. These rules limit what’s possible on a small island like Venø.
However, a recent national agreement on rural development (October 2024) may offer new opportunities: small islands like Venø may now apply for exemptions from some planning restrictions, such as those related to coastal zone protection, if the project is part of an approved island development plan. The benefits of the turbine would stay local, and residents are more likely to support the initiative. The Venø Transition Team is also open to including compensatory or nature-friendly measures in the project design, to reduce any environmental impact and help with approval under Natura 2000 and Environmental Impact Assessment rules. A political parliamentary agreement from autumn 2024 opens up possibilities for dispensation for smaller islands. The agreement is expected to be implemented into law in 2026. However, the possibility of granting dispensation for the installation of wind turbines on islands remains uncertain.
The problem: a systemic misalignment
Although it is understood that the goals of Natura 2000 are environmentally necessary, the way the rules are currently applied shows a mismatch between nature protection laws and climate policy, especially for small island communities in Denmark. Small, citizen-led wind projects, even when placed on farmland with little or no environmental value, are subject to the same level of regulation as large commercial wind farms. This creates procedures that are far too demanding for the scale and impact of these projects. At present, such small projects often have to go through long and expensive Environmental Impact Assessments and face unclear, case-by-case rules. This can delay or even alter their development. This approach goes against both the EU’s Better Regulation principles, which call for simpler and fairer processes, and the European Commission’s REPowerEU plan, which supports faster approval for renewable projects in low-risk areas like farmland or developed land.
Local and national planning rules are also not designed with small islands in mind. Many existing turbines on islands like Venø, Fejø, and Anholt were built decades ago, but cannot be easily replaced under current regulations because the sites are not included in official wind energy zones, and Denmark’s planning system requires a complete municipal plan change and Environmental Impact Assessment even for repowering existing turbines. This blocks upgrades and goes against Denmark’s national climate goals, as outlined in the Klimaloven, which aims to establish legally binding targets of reducing GHG emissions by 2030 and achieving climate neutrality by 2050. The problem is also practical. Natura 2000 rules are often applied uniformly to areas with high biodiversity and to places like intensively farmed land or developed land with low ecological sensitivity. In many cases, local landowners and communities have useful knowledge that could help shape a smarter, more focused impact assessment, but this input rarely fits into the current national system.
As a result, island municipalities are left without clear guidance or flexibility to move forward with sustainable energy projects. This creates a real contradiction as Denmark’s islands, which have led the way in community-owned renewable energy, are now limited in how they can support national climate goals. Instead of being supported, they face rules that do not fully reflect their potential and may overlook their consistent efforts toward sustainability. This problem is not caused by the original intent of Natura 2000 but by the way the rules are currently applied. The European Commission’s own guidance explains that protecting a site does not automatically mean refusing new projects; it means making a well-reasoned judgement based on actual risk. Unfortunately, as is the case now, the current system does not put that flexibility into practice, especially not for small, local renewable projects on islands.
Why a proportionate approach is needed
The experiences of Fejø and Venø demonstrate why a more proportionate and flexible approach is urgently needed for small-scale renewable energy projects in Denmark’s island communities. On Fejø, the local community plans to install two modern wind turbines to replace older ones, with the preferred location being Skalø. The site is farmland, not forest or wetland, and no bat colonies or other protected species of concern have been identified. Although Skalø lies within a Natura 2000 area, the actual ecological risk is low. The community has also proposed to remove outdated turbines as part of the project, helping reduce visual and environmental impact across the island. The project is small in scale (2–3 MW) and designed to support local energy needs, yet it still faces a full Environmental Impact Assessment and a complex dispensation process discouraging progress despite strong local support. Similarly, on Venø, a single community-owned turbine is planned to support local energy needs. Most of the island is covered by planning and environmental constraints, including Natura 2000, beach protection zones, and strict dwelling setbacks. The only viable site, located in the island’s south, still borders protected habitats, requiring extensive assessments.
Like Fejø, Venø’s project is modest in scale and impact but must navigate the full weight of national permitting procedures. Adding to this, Venø is not designated as a wind energy area in the municipal plan, blocking even the replacement of older infrastructure without a new planning process. These examples reflect a one-size-fits-all interpretation of Natura 2000 rules, which is not required under EU law and is not environmentally justified in low-risk settings. The European Commission’s own Article 6 guidance clarifies that development is not automatically forbidden within Natura 2000 areas but must be assessed based on actual impacts on conservation goals, not just proximity. Moreover, both Fejø and Venø have shown a strong commitment to sustainability. They propose clear mitigation measures such as turbine replacement and early local engagement. However, these good practices receive no procedural benefit under current frameworks. Without changes, the risk is that such community-led projects will be delayed or abandoned, not due to environmental risk, but due to disproportionate administrative barriers. A proportionate approach would allow authorities to distinguish between high-impact commercial projects on one side and low-risk, high-benefit community initiatives on the other side.
Conclusion
The Natura 2000 framework plays an important role in protecting Europe’s biodiversity, and its goal of safeguarding vulnerable habitats and species is widely supported. However, it has been noticed that it sometimes applies too rigidly. The experiences of Fejø, Venø, and other small Danish islands show a growing tension between two national priorities: protecting nature on one side and advancing the green transition on the other side. Danish islands are not just passive recipients of national policy; they are practical examples of innovation, self-sufficiency, and community-driven climate action. However, under the current approval system, their plans to replace outdated wind turbines and contribute to national climate goals are often slowed or blocked by complex procedures, even when the projects pose minimal environmental risk.
A more predictable and proportionate framework is needed to ensure that these low-risk initiatives can move forward without unnecessary administrative barriers. A more proportionate approach is necessary and fully allowed under the existing EU rules. A small, citizen-led project on farmland with no sensitive species should not face the same requirements as a large commercial wind development. If this distinction is not made, the system risks becoming stuck and ineffective. With the right reforms, Denmark can continue to protect nature while giving its island communities the tools they need to support the green transition.
Access the paper here