Permitting requirements / process, including safety distances (external/internal)

This LAP refers to the permitting requirements. In particular it underlines if there are some requirements in terms of environmental assessment, risk assessment, safety requirements. It identifies what is the competent authority responsible for the permitting requirements, what are the different steps of the process, and what are the different kinds of permits needed by the approval authority. Finally, it shows if the process is uniform throughout the country, how much time is needed to obtain the permit, and if there are some exemptions/simplified processes.


A process in which an applicant files forms to a (regulatory) agency/competent authority with required narratives, maps, etc., to ensure in advance that the proposed operation will be in compliance with the applicable standards. Permitting requirements are the legal (regulations and standards) requirements.
An internal safety distance is the minimal separation distance between a potential hazard source (e.g. equipment involving dangerous substances) and an object (human, equipment or environment), which will mitigate the effect of a likely foreseeable incident and prevent a minor incident escalating into a larger incident (also known as domino effect).

Pan-European Assessment:

Subject to significant operational variance (in terms of scope of application and operationalisation of requirements), the storage of hydrogen is, generally, subject to the following requirements:
• Risk Assessments (as operationalised from the general obligations laid down in the SEVESO Directive).
• Health and Safety requirements and conformity assessment procedures, as envisioned by the ATEX Directive.
• Environmental Impact Assessment procedures, as envisioned by the SEA and EIA Directives.

Subjecting hydrogen storage to risk assessments, in accordance with the SEVESO and ATEX Directive is in line with the purpose and intention of these acts, however, the application of the EIA and SEA Directives and other environmental permitting may result in disproportionate administrative burden on project developers and economic operators wishing to bring hydrogen applications such as HRS’s and micro-CHPs to market. In addition, the process itself (involving several permits, provided by different authorities, and requiring much time and effort) imposes high costs on operators and further delays the commercial deployment of these applications.
Finally, and importantly, safety distances are, in some cases, very restrictive and can be seen as a major barrier. This is discussed in more detail in the chapter dedicated to hydrogen refuelling stations

severity of barrier:

No data No barrier Low Medium High