Permitting process (include former LAP: emission regulation)
This LAP refers to the permitting process. It identifies what is the competent authority responsible for the permitting requirements, highlights 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.
Permitting process (include former LAP: emission regulation)
The 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.
Centralised
(Electrolysis, Steam-Methane reforming, and H2 liquification)
Centralised production of hydrogen is the production of hydrogen at one location, in quantities to cover the needs of hydrogen over a relatively large geographic area for a relatively large number of points of use, implying hydrogen transportation.
The process of obtaining all the necessary permits for the development and operation of a hydrogen production plant is subject to significant national variation throughout the different partner countries covered by this study.
While some countries, such as Austria and the UK, have centralised the competences to steer this process into a single authority, in most other countries the various needed permits (e.g. construction, environmental, operating, Seveso etc.) will have to be obtained from different authorities (e.g. local municipality, regional decentralised authorities, fire brigade, working environment authorities, etc.)
In most cases, a hydrogen production plant is considered as a traditional chemical production facility, without regard to the type of H2 production (PEM, alkaline, reforming…) or the presence (or absence) of hazardous substances involved in the process. This places a disproportionate burden on environmentally friendly production methods, as it subjects them to the same requirements as industrial, emission emitting processes. Furthermore, the absence of simplified processes for small quantity production leads to a restrictive environmental procedure which may discourage investors. This situation discourages development of environmentally friendly production methods and further exacerbates the (lack of) economies of scale issues faced by smaller units.
Irrespective of the production method and scale, the permitting process is long, costly, and its outcome is uncertain. Project developers and administrations themselves lack the sufficient knowledge to navigate the requirements smoothly and without significant efforts. This increases the costs for developers and delays the deployment of hydrogen technology.
This map depicts the severity of this barrier across the HyLaw Partner countries.
The HyLAW project has received funding from the Fuel Cells and Hydrogen 2 Joint Undertaking under grant agreement No 737977.