How can an existing power plant in Turkey add solar or wind capacity? A 2026 legal guide for foreign investors covering hybrid power plant licensing, EMRA license amendments, grid capacity, auxiliary sources, land, permits and project acquisitions.

Hybrid power plant projects have become an increasingly important investment model in the Turkish renewable energy market. An existing wind farm may add solar panels, a hydroelectric facility may incorporate solar generation, or another licensed generation facility may seek to use a second energy source within the same project structure.

The commercial logic is attractive. Different renewable sources can generate electricity at different times, allowing existing land, substations, transmission infrastructure and grid connection capacity to be used more efficiently.

However, a foreign investor cannot simply purchase solar panels or wind turbines and install them next to an existing licensed power plant.

Under the Turkish electricity-market framework, converting an existing facility into a multi-source electricity generation facility can require amendment of the existing generation license and compliance with additional regulatory, technical, land, environmental, zoning and construction requirements.

EMRA’s current practice confirms that existing licensed projects can apply to convert into multi-source facilities by adding auxiliary-source units and amending their generation licenses. EMRA also confirmed in its 2026 guidance that projects whose licenses have been amended for multi-source generation remain subject to specific progress-reporting obligations until the licensed capacity has been fully accepted. (EPDK)

For foreign investors, the central question is therefore:

Can the existing project legally accommodate the proposed second generation source without increasing or interfering with the electrical capacity and connection rights allocated to the project?

What Is a Hybrid Power Plant in Turkey?

In electricity-market terminology, these projects generally fall within the regulatory framework governing multi-source electricity generation facilities.

The basic structure involves a principal energy source and one or more auxiliary sources incorporated into the same generation project.

For example:

Wind + Solar

Hydroelectric + Solar

Biomass + Solar

Other combinations may also be possible depending on the regulatory and technical characteristics of the project.

The important point is that the additional source is not automatically treated as an entirely independent power plant.

Instead, it can become part of the existing licensed generation facility through the applicable regulatory structure.

What Is the Main Source?

The main source is the primary energy source underlying the generation facility.

For example, an existing wind farm that subsequently adds solar generation would generally retain wind as its principal source while solar becomes the auxiliary source.

Likewise, an existing hydroelectric plant adding solar units can operate within a hydro-plus-solar multi-source structure.

The distinction is important because the auxiliary source does not simply replace the regulatory identity of the existing project.

What Is an Auxiliary Source?

The auxiliary source is the additional energy source incorporated into the generation facility.

EMRA’s published license-amendment proceedings provide practical examples.

In one case involving an existing hydroelectric facility, the project company sought to convert the plant into a combined renewable generation facility by adding auxiliary-source units and requested amendment of the installed capacity recorded in its generation license. (EPDK)

Similar EMRA proceedings demonstrate that auxiliary-source capacity and the additional land required for those units form part of the license-amendment analysis. (EPDK)

Can Solar Capacity Be Added to an Existing Wind Farm?

Potentially yes.

This is one of the most commercially interesting hybrid structures.

Wind and solar generation profiles can complement one another. Solar generation is strongest during daylight hours, while wind generation may follow a different daily and seasonal profile.

An existing wind project may already possess valuable infrastructure:

Grid Connection → Substation → Transmission Infrastructure → Project Land → Control Systems → Operational Personnel.

Adding solar generation can therefore increase utilization of existing project infrastructure.

However, the investor must first determine whether the proposed auxiliary capacity can legally and technically be incorporated into the licensed project.

Can Wind Capacity Be Added to an Existing Solar Project?

Potentially, subject to the applicable licensing and technical requirements.

However, adding wind turbines can be more complex from a land and permitting perspective.

Wind turbines may require additional:

Coordinates → Turbine Parcels → Access Roads → Crane Areas → Cable Routes → Environmental Review → Zoning → Construction Approvals.

Accordingly, even if the project’s grid structure can accommodate hybrid generation, the physical requirements of the auxiliary wind source must be separately investigated.

Is an EMRA License Amendment Required?

The generation license is central to establishing a hybrid project.

Existing projects seeking conversion into multi-source generation facilities can require a generation license amendment incorporating the auxiliary source and corresponding project characteristics.

EMRA’s published proceedings demonstrate applications by existing generation-license holders requesting conversion into multi-source facilities and amendments to the installed capacity reflected in their licenses. (EPDK)

The investor should therefore establish the licensing position before ordering or constructing auxiliary-source equipment.

The safer sequence is:

Hybrid Feasibility → Grid Analysis → License Amendment → Related Project Approvals → Construction → Acceptance.

MWm and MWe Become Particularly Important

Foreign investors evaluating Turkish hybrid projects should understand the distinction between mechanical installed capacity and electrical capacity.

Hybrid projects can involve an increase in total installed mechanical capacity while maintaining the electrical capacity at the project’s grid-delivery level.

For example, EMRA’s published Birkapılı HES proceeding involved a proposed change from 48.5 MWm / 48.5 MWe to 77.235 MWm / 48.5 MWe following the proposed incorporation of an auxiliary source. (EPDK)

This illustrates one of the core commercial concepts behind hybrid generation.

Additional generation equipment can potentially improve utilization of an existing electrical connection without necessarily increasing the project’s MWe figure in the same proportion.

Hybrid Capacity Does Not Automatically Mean Additional Grid Capacity

This distinction is crucial.

Suppose a wind farm has an electrical capacity of 100 MWe.

The investor wants to add 40 MWm of solar equipment.

The commercial objective may be to increase generation during periods when wind output is below the project’s available electrical capacity.

The investor should not assume that adding 40 MWm of solar creates a right to export an additional 40 MWe to the grid.

The project’s connection rights and electrical capacity remain fundamental constraints.

Grid Connection Requirements

The existing connection arrangement must therefore be reviewed before developing a hybrid project.

The investor should identify:

Connection Point → Connection Capacity → Transformer Capacity → Substation Capacity → Transmission or Distribution Constraints → Existing System-Use Rights.

The project may require technical modifications even if additional grid injection capacity is not requested.

The cost of those modifications should be incorporated into the investment model.

Grid Curtailment Risk

Hybrid generation does not eliminate grid limitations.

If both the main and auxiliary sources generate strongly at the same time, the combined mechanical generation potential may exceed the project’s permitted electrical output.

The project must therefore be technically capable of complying with its applicable grid and licensed electrical limits.

Foreign investors should model this potential curtailment when calculating expected revenues.

An additional 30 MWm of solar equipment does not necessarily produce revenues equivalent to an independent 30 MWe solar project.

Hybrid Solar Added to a Wind Farm

Consider an existing wind farm with substantial unused land.

The investor identifies an opportunity to install solar panels between or around turbine areas.

Before proceeding, the project should be reviewed for:

Generation License

Grid Capacity

Solar Resource

Project Coordinates

Land Rights

Environmental Requirements

Zoning

Construction Permits

Electrical Infrastructure

Acceptance

The fact that the wind project already possesses a generation license does not automatically authorize construction of solar units.

Hybrid Solar Added to a Hydroelectric Plant

Hydroelectric projects can also present attractive solar opportunities.

Existing HES facilities may have available land around reservoirs, substations or other project areas.

EMRA’s published practice contains multiple examples of hydroelectric generation-license holders seeking amendments to become multi-source renewable generation facilities by adding auxiliary-source capacity. (EPDK)

This demonstrates that HES-plus-solar structures are not merely theoretical investment concepts.

However, the suitability of each project depends on its specific licensing, land and grid position.

Can the Auxiliary Source Require Additional Land?

Yes.

The existing generation site may not have enough suitable space for the auxiliary source.

In that case, additional land may need to be incorporated into the project.

EMRA’s published amendment proceedings show projects requesting additional auxiliary-source areas together with amendments to their generation licenses. (EPDK)

This means land expansion and licensing can become interconnected.

Third-Party Objections

Additional project land can also create third-party rights issues.

In certain license-amendment proceedings involving additional auxiliary-source areas, EMRA publishes project-site coordinate information so third parties can submit objections based on alleged violations of personal rights within the applicable period. (EPDK)

Foreign investors should therefore investigate neighboring ownership and existing third-party rights before assuming that project-site expansion will be straightforward.

Land Due Diligence for Hybrid Projects

A foreign investor should verify whether the project company has legally sufficient rights over every parcel required for the auxiliary source.

The analysis should include:

Ownership → Lease → Easement → Public Land Rights → Access → Cable Routes → Substation Rights.

If additional solar capacity is constructed on leased land, the remaining lease period should also correspond with the expected operating life of the new equipment.

Installing solar assets expected to operate for decades on land controlled for only several more years creates obvious investment risk.

Environmental Requirements

Adding an auxiliary generation source can change the physical and environmental characteristics of the existing facility.

The investor should therefore determine whether the existing environmental documentation covers the proposed hybrid configuration or whether additional environmental procedures are required.

The correct comparison is:

Existing Environmental Approval → Existing Physical Project → Proposed Hybrid Project.

Any material difference should be investigated.

An EMRA license amendment should not be assumed to automatically amend environmental approvals.

Zoning Requirements

The auxiliary facility must also be reviewed from a zoning perspective.

Solar fields, wind turbines, battery facilities, substations and additional electrical infrastructure may create new planning requirements.

This becomes particularly important where additional land is incorporated into the project.

Ownership of neighboring land does not automatically mean that renewable generation equipment can legally be constructed on it.

Construction Permits

Additional physical structures can also require construction-related approvals.

Foreign investors should therefore coordinate energy regulatory advice with zoning and construction due diligence.

A project can successfully obtain an energy-license amendment while still encountering problems because its auxiliary-source construction documentation is incomplete.

Hybrid Projects and Existing Land Leases

The project company’s existing land leases should also be examined.

A lease originally negotiated for a wind farm may define the permitted use narrowly.

Adding a solar facility could potentially fall outside the contractual use contemplated by the lease.

The investor should therefore review whether:

Hybrid Generation Is Permitted → Landlord Consent Is Required → Rent Changes → Additional Land Is Needed → Lease Duration Is Sufficient.

This issue is particularly important when acquiring an already developed hybrid project.

Hybrid Projects and Expropriated Land

Where the principal project uses land obtained through expropriation or administrative easements, the investor should not automatically assume that those rights extend to every auxiliary-source installation.

The legal purpose and scope of the existing land right should be reviewed.

Additional land acquisition or regulatory procedures may be necessary.

Progress Reporting Requirements in 2026

Hybrid projects remain subject to continuing compliance obligations after the license amendment.

EMRA confirmed in June 2026 that generation-license holders whose licenses have been amended for multi-source electricity generation facilities must submit progress reports until acceptance of the entire installed capacity incorporated into the license. (EPDK)

Importantly, progress concerning the main and auxiliary source units must be reported separately. (EPDK)

Reports are required during January and July under the applicable framework.

This is therefore an important due diligence item for foreign investors acquiring partially completed hybrid projects.

Acceptance of Auxiliary-Source Units

Obtaining a license amendment does not mean that the auxiliary source immediately becomes fully operational accepted capacity.

The project must proceed through the applicable construction, commissioning and acceptance processes.

Accordingly, acquisition due diligence should distinguish:

Hybrid License Amendment Obtained

from

Auxiliary Units Constructed

from

Auxiliary Units Accepted

from

Auxiliary Units Commercially Operating.

These stages can have very different values.

Acquiring an Existing Hybrid Power Plant

Foreign investors purchasing an existing hybrid project should review both sources separately.

A due diligence report should identify:

Main Source Capacity

Auxiliary Source Capacity

MWm

MWe

Accepted Capacity

Unaccepted Capacity

Connection Capacity

Project Coordinates

Land Rights

Outstanding Construction

Pending Acceptance

Regulatory Reporting

A seller should not simply describe the project as a “150 MW hybrid plant” without explaining what that figure legally represents.

Buying a Project With a Pending Hybrid Application

This is another important transaction scenario.

Suppose a foreign investor is purchasing a 100 MWe wind farm.

The seller has applied to add 50 MWm of solar capacity.

The seller’s valuation includes revenues expected from the future solar units.

The buyer should distinguish between:

Existing Wind Project Value

and

Potential Hybrid Expansion Value.

Until the regulatory and technical requirements are sufficiently secure, the proposed auxiliary source remains development potential rather than fully operational generation capacity.

Hybrid Approval as a Condition Precedent

If the hybrid expansion represents a material part of the acquisition thesis, the buyer may require the relevant license amendment to be completed before closing.

The SPA can therefore provide:

License Amendment → Required Land Rights → Required Grid Position → Closing.

This prevents the buyer from paying for anticipated hybrid capacity that ultimately cannot be developed.

Deferred Consideration

Another transaction structure is deferred purchase consideration.

The buyer may pay for the existing project at closing and additional consideration when the auxiliary capacity reaches defined milestones.

For example:

Existing Wind Farm → Initial Purchase Price

Hybrid License Amendment → Additional Payment

Solar Construction Completed → Additional Payment

Solar Capacity Accepted → Final Payment

This approach can allocate development risk more efficiently.

Seller Warranties

The SPA should accurately describe the project’s hybrid status.

Relevant warranties can address:

License Status → Main Source → Auxiliary Source → Capacity → Grid Rights → Land → Permits → Pending Applications → EMRA Correspondence → Progress Reports → Acceptance Status.

A seller should not represent proposed auxiliary capacity as though it were already legally secured.

Unauthorized Hybrid Capacity

A particularly serious issue arises where a seller has already installed auxiliary-source equipment without completing the necessary regulatory process.

The buyer should determine:

whether the equipment required a license amendment,

whether regularization is possible,

whether grid restrictions have been violated,

whether related permits exist,

and whether administrative exposure remains.

The unauthorized capacity should not automatically be included in the purchase price.

Example: Wind Farm Adding Solar Capacity

A 100 MWe wind farm has substantial unused connection capacity during daylight periods when wind generation is low.

The owner proposes adding 40 MWm of solar equipment.

The project may offer attractive hybrid economics, but the investor must confirm the generation-license amendment, grid configuration, land availability, environmental position, zoning and construction requirements before treating the additional solar generation as secured revenue.

Example: HES Adding Solar Capacity

A foreign investor acquires an operating hydroelectric project.

The seller identifies nearby project land suitable for solar panels and proposes converting the plant into a multi-source renewable facility.

EMRA’s published practice demonstrates comparable HES projects seeking generation-license amendments to add auxiliary-source capacity. (EPDK)

The buyer should nevertheless evaluate the specific project rather than assuming that approval granted or sought for another HES guarantees approval for this one.

Example: Additional Hybrid Land Required

An existing project has sufficient grid potential but insufficient land inside its current site.

The company proposes leasing an adjacent parcel for solar units.

The transaction team must analyze the lease, project coordinates, potential third-party rights, license amendment and all relevant planning and construction requirements.

The land agreement should not be signed on the assumption that EMRA approval is guaranteed.

Example: Hybrid License Approved but Solar Units Not Constructed

A foreign buyer acquires a project whose generation license has already been amended to include an auxiliary solar source.

However, only the main wind facility is operating.

The buyer should identify the remaining construction timetable, required investment, outstanding permits and reporting obligations.

EMRA’s 2026 guidance confirms that reporting continues until the full capacity incorporated into the license has been accepted. (EPDK)

Major Hybrid Project Red Flags

Foreign investors should pay particular attention to auxiliary equipment installed before license amendment, proposed capacity exceeding available grid rights, insufficient project land, missing auxiliary-source land rights, pending third-party objections, environmental approvals covering only the original facility, missing zoning or construction approvals, expired construction timetables, unaccepted auxiliary capacity, missing progress reports and acquisition valuations treating proposed hybrid capacity as already operational.

Any of these issues can materially change the investment case.

Hybrid Power Plant Due Diligence Checklist

Before investing in a Turkish hybrid project, the investor should verify:

Generation License → Main Source → Auxiliary Source → MWm → MWe → Connection Capacity → License Amendment → Project Coordinates → Additional Land → Land Rights → Environmental Status → Zoning → Construction Permits → Substation → Transmission Infrastructure → Construction Schedule → Acceptance → Progress Reports → Commercial Operation.

For acquisition purposes, the legal team should compare these documents with the facility physically existing on site.

The goal is to ensure that the licensed hybrid project and the actual hybrid project are the same facility.

Frequently Asked Questions

1. Can an existing wind farm add solar capacity in Turkey?

Potentially yes, subject to the licensing, grid, technical, land and other regulatory requirements applicable to conversion into a multi-source generation facility.

2. Can a hydroelectric plant add solar generation?

Yes, subject to the applicable requirements. EMRA’s published proceedings contain several examples of HES projects seeking amendments to add auxiliary-source generation. (EPDK)

3. Is an EMRA license amendment required?

Conversion of an existing licensed facility into a multi-source project can require amendment of the generation license to incorporate the auxiliary source and relevant project characteristics.

4. Can hybrid capacity exceed the project’s MWe capacity?

The mechanical installed-capacity structure can differ from electrical capacity. EMRA’s published hybrid amendment proceedings include projects where MWm increases while MWe remains unchanged. (EPDK)

5. Does adding solar automatically increase grid-export rights?

No. Additional installed generation equipment should not be confused with an automatic right to increase electricity delivered to the grid.

6. Can additional land be added for the auxiliary source?

Potentially yes, subject to the applicable regulatory and property requirements. EMRA’s published amendment proceedings demonstrate requests involving additional auxiliary-source areas. (EPDK)

7. Can third parties object to additional project land?

Certain amendment proceedings involving project-site coordinates can be published for objections concerning personal-right violations. (EPDK)

8. Are progress reports required after hybrid approval?

Yes, where the applicable requirements continue. EMRA’s 2026 guidance requires reporting until the total capacity incorporated into the license is accepted, with main and auxiliary sources reported separately for multi-source projects. (EPDK)

9. Should a foreign investor pay for proposed hybrid capacity before approval?

The uncertainty should be reflected in valuation. Approval may be made a closing condition, or part of the consideration can be deferred until defined regulatory and construction milestones are achieved.

10. What is the biggest legal risk in a hybrid project acquisition?

Treating planned auxiliary capacity as guaranteed generation before confirming the license amendment, grid position, land rights, permits, construction status and acceptance required to operate that capacity legally.

Legal Support for Hybrid Power Plant Investments in Turkey

Hybrid projects can significantly improve the efficiency and commercial value of existing renewable-energy assets, but the additional MWm should never be treated as automatically available simply because the project has unused land or existing grid infrastructure.

Firat Fesih Kaya Law Office assists foreign investors, international energy companies and renewable-energy developers with hybrid power plant investments and acquisitions in Turkey. Firat Fesih Kaya can assist with generation-license due diligence, hybrid project structuring, license amendments, grid and land-risk analysis, power plant acquisitions, SPA negotiations and transaction structures involving pending auxiliary-source capacity.

For foreign investors, the key investment test is straightforward: Can the additional solar or wind capacity be licensed, connected, constructed, accepted and operated within the existing project’s legal and technical framework?

Phone: +90 312 434 22 22
Mobile Phone: +90 532 769 22 22
Email: info@firatfesihkaya.av.tr
Address: Mevlana Boulevard No: 221, Yildirim Tower, Balgat, Cankaya / Ankara, Turkey