EREF says the government also intends to either cut feed-in tariffs or introduce a tax on existing capacity.
If implemented, the tax will cut income for wind-farm operators by at least 15% undermining project-finance contracts, EREF says.
In a letter to EC energy commissioner, Günther Oettinger, EREF urged him to protect regulatory stability and avoid retroactive changes.
Renewables-tariff reform proposals were to be published by end-2011 under the terms of the financial rescue package agreed between Portugal and the troika of international institutions — the IMF, the EC and the ECB — in May. Nothing has yet been forthcoming.
An economy ministry spokesperson said Portugal's largest wind-power consortium ENEOP "does not have a tariff, which is considered too high", but that "it will not be protected by any special regime".
Portuguese renewable-energy association spokesman Antonio Sa da Costa said: "The secretary of state for energy told me that tariffs under €80/MWh would not be affected by retroactive cuts in tariff." This represents between 20-25% of Portugal's total 4.5GW installed capacity.
It would also include the 500MW that remains to be installed by the ENEOP and Ventinveste consortia.