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The higher target would be in line with the European Commission's impact assessment of the new 55% target in reducing CO2 emissions, and would require renewable energy's share to roughly double from current levels.
"The most ambitious renewable energy targets remain academic if we don't solve permitting," WindEurope's communications officer Christoph Zipf said.
EU wind energy capacity would need to be 433-452 GW by 2030 to meet a 38%-40% renewable energy target, WindEurope said in a position paper submitted to the EC's consultation process.
Of that, some 361-374 GW would be onshore and 73-79 GW offshore, the wind energy industry association said.