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4.10
Enabling ActivityD35.11

Storage of electricity

Construction and operation of facilities that store electricity and return it at a later time in the form of electricity.

Substantial Contribution to Climate Change Mitigation

The activity involves the construction and operation of facilities that store electricity and return it at a later time as electricity. This includes pumped hydropower storage, battery energy storage systems, compressed air energy storage, flywheel energy storage, and other electricity storage technologies. The facility is not dedicated to a fossil fuel power plant.

Electricity storage is classified as an enabling activity under Article 10(1)(i) of Regulation (EU) 2020/852, as it enables greater integration of renewable and low-carbon electricity into the grid by providing flexibility, balancing, and ancillary services. The facility must demonstrate that it is not dedicated to increasing the output or efficiency of fossil fuel generation assets.

DNSH: Climate Change Adaptation

The activity complies with the criteria set out in Appendix A of the Delegated Act. A climate risk and vulnerability assessment proportionate to the scale of the activity has been performed, and adaptation solutions that reduce identified material physical climate risks have been implemented.

DNSH: Water and Marine Resources

The activity does not lead to the deterioration of the good status of bodies of water and complies with Directive 2000/60/EC. For pumped hydro storage, ecological flow requirements are maintained, and water quality impacts from pumping operations are managed.

DNSH: Circular Economy

The activity assesses the availability of and, where feasible, adopts techniques that support reuse, remanufacturing, and recycling at end of life. For battery storage, a battery management system extends useful life and a collection and recycling scheme complies with Directive 2006/66/EC and Regulation (EU) 2023/1542 on batteries.

DNSH: Pollution Prevention

The activity does not involve the use of substances listed in Annex I or II of Regulation (EU) 2019/1021. For battery storage systems, hazardous materials are managed in accordance with REACH Regulation (EC) 1907/2006, and measures prevent leakage of electrolytes or other hazardous substances into the environment.