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4.12
Enabling ActivityD35.21

Storage of hydrogen

Construction and operation of facilities that store hydrogen, including underground hydrogen storage and above-ground hydrogen storage facilities.

Substantial Contribution to Climate Change Mitigation

The activity involves the construction and operation of facilities for hydrogen storage. This includes underground storage in salt caverns, depleted gas fields, and aquifers, as well as above-ground storage in pressurised tanks, liquid hydrogen tanks, and solid-state hydrogen storage using metal hydrides or other carrier materials.

Hydrogen storage is classified as an enabling activity under Article 10(1)(i) of Regulation (EU) 2020/852, as it enables the decarbonisation of energy systems by providing large-scale, long-duration energy storage and facilitating sector coupling between electricity, heat, and transport. The stored hydrogen must meet the criteria for renewable hydrogen or low-carbon hydrogen as defined in Delegated Regulation (EU) 2023/1184.

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 has been carried out, considering the specific risks associated with underground storage (such as geological stability under changing conditions) over the expected lifetime of the facility.

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 underground storage facilities, groundwater monitoring programmes are implemented to detect any contamination from storage operations.

DNSH: Circular Economy

The activity assesses the availability of and, where feasible, adopts techniques that support reuse and recycling of storage vessels, piping, and associated equipment at end of life. Materials selection prioritises recyclable metals and minimises use of composite materials that are difficult to recycle.

DNSH: Pollution Prevention

The activity does not involve the use of substances listed in Annex I or II of Regulation (EU) 2019/1021. Hydrogen leak detection and prevention systems are installed. The facility complies with Directive 2012/18/EU (Seveso III) on control of major-accident hazards where applicable.