Guidelines and good practices for obtaining permitting (D4.3)

D4.3 Guidelines and good practices for obtaining permitting Ref. Ares(2025)8120968 - 26/09/2025 D4.3 Guidelines and good practices for obtaining permitting DELIVERABLE TYPE Report MONTH AND DATE OF DELIVERABLE M28, 30/09/2025 WORK PACKAGE WP 4 LEADER CNH2 DISSEMINATION LEVEL Public AUTHORS Maria José Sánchez (CNH2) Maria Panadero (CNH2) PROGRAMME HORIZON EUROPE GRANT AGREEMENT 101111933 START June 2023 DURATION 28 Months 3 Contributors NAME ORGANISATION María José Sánchez, María Panadero CNH2 Mattia Miglietta ENVI Simon Habran CLUSTER TWEED Miroslava Tzekova, Vasimir Radulov BH2C Justyna Błaszak-Gondek RIGP Peer Reviews NAME ORGANISATION Mattia Miglietta, Ilaria Schiavi ENVI Simon Habran CLUSTER TWEED Dr Fanie van Rooyen IMI Revision History The information and views set out in this report are those of the author(s) and do not necessarily reflect the official opinion of the European Union, neither the European Union Institutions and Bodies nor any person acting on their behalf. VERSION DATE REVIEWER MODIFICATIONS 1 21/08/2025 Simon Habran First version for consortium’s review 2 02/09/2025 Mattia Miglietta First version for consortium’s review 3 05/09/2025 Dr Fanie van Rooyen First version for consortium’s review 4 05/09/2025 Miroslava Tzekova First version for consortium’s review 5 11/09/2025 Ilaria Schiavi Final draft for translation 6 17/09/2025 Translation company Grammar and vocabulary revision of the English version 4 Index of Contents 1 About the HYPOP project .........................................................................................................................10 2 HYPOP guideline documents ....................................................................................................................10 3 Methodology and data collection approach ..........................................................................................11 3.1 Technical workshop: Spain ................................................................................................................11 3.2 Technical workshop: Italy ..................................................................................................................16 3.3 Technical workshop: Belgium ...........................................................................................................19 3.4 Technical workshop: Bulgaria ...........................................................................................................21 3.5 Technical workshop: Poland .............................................................................................................22 4 Overview of the European regulatory landscape .................................................................................24 4.1 Industrial sector ...................................................................................................................................25 4.1.1 HYPOP countries ....................................................................................................................................... 26 4.1.1.1 Belgium .................................................................................................................................26 4.1.1.2 Italy ........................................................................................................................................26 4.1.1.3 Spain ......................................................................................................................................26 4.1.2 EU 13 countries .......................................................................................................................................... 27 4.1.2.1 Bulgaria (also a HYPOP country) .....................................................................................27 4.1.2.2 Poland (also a HYPOP country) .......................................................................................27 4.1.2.3 Croatia ..................................................................................................................................27 4.1.2.4 Cyprus ...................................................................................................................................28 4.1.2.5 Czech Republic ....................................................................................................................30 4.1.2.6 Estonia ..................................................................................................................................32 4.1.2.7 Hungary ................................................................................................................................32 4.1.2.8 Latvia .....................................................................................................................................32 4.1.2.9 Lithuania ...............................................................................................................................32 4.1.2.10 Malta .....................................................................................................................................33 4.1.2.11 Romania ................................................................................................................................33 4.1.2.12 Slovakia .................................................................................................................................33 4.1.2.13 Slovenia ................................................................................................................................34 4.1.3 Frontrunner countries ............................................................................................................................... 34 4.1.3.1 France ...................................................................................................................................34 4.1.3.2 Germany ...............................................................................................................................34 5 4.1.3.3 Switzerland ..........................................................................................................................36 4.1.3.4 The Netherlands .................................................................................................................39 4.2 Mobility sector .....................................................................................................................................39 4.2.1 HYPOP countries ....................................................................................................................................... 40 4.2.1.1 Belgium .................................................................................................................................40 4.2.1.2 Italy ........................................................................................................................................41 4.2.1.3 Spain ......................................................................................................................................42 4.2.2 EU 13 countries .......................................................................................................................................... 42 4.2.2.1 Bulgaria (also a HYPOP country) .....................................................................................42 4.2.2.2 Poland (also a HYPOP country) .......................................................................................42 4.2.2.3 Croatia ..................................................................................................................................44 4.2.2.4 Cyprus ...................................................................................................................................44 4.2.2.5 Czech Republic ....................................................................................................................44 4.2.2.6 Estonia ..................................................................................................................................46 4.2.2.7 Hungary ................................................................................................................................46 4.2.2.8 Latvia .....................................................................................................................................46 4.2.2.9 Lithuania ...............................................................................................................................47 4.2.2.10 Malta .....................................................................................................................................48 4.2.2.11 Romania ................................................................................................................................48 4.2.2.12 Slovakia .................................................................................................................................48 4.2.2.13 Slovenia ................................................................................................................................48 4.2.3 Frontrunner countries ............................................................................................................................... 48 4.2.3.1 France ...................................................................................................................................48 4.2.3.2 Germany ...............................................................................................................................49 4.2.3.3 Switzerland ..........................................................................................................................50 4.2.3.4 The Netherlands .................................................................................................................50 4.3 Residential sector ................................................................................................................................51 5 Key elements to foster the hydrogen economy at the regional level ...............................................52 5.1 Examples in industry that have been considered useful .............................................................52 5.2 Examples in mobility that have been considered useful .............................................................54 6 HYPOP recommendations to deal with hydrogen project permits in the EU .................................57 7 Conclusion ....................................................................................................................................................61 8 References ....................................................................................................................................................62 6 9 Appendix A. Additional information on applied regulations ...............................................................64 a. CROATIA ...................................................................................................................................................64 b. POLAND ...................................................................................................................................................65 c. LITHUANIA ...............................................................................................................................................66 d. SWITZERLAND........................................................................................................................................67 e. THE NETHERLANDS ..............................................................................................................................73 Index of Tables Table 1. Overview of the questions asked in the Spanish workshops ......................................................12 Table 2. Summary of the results obtained in question 1 of the Spanish workshops. ............................13 Table 3. Strategy followed by SNAM for a hydrogen valley project .........................................................17 Table 4. Strategy followed by Techfem for a hydrogen production plant ...............................................18 Table 5. Overview of the questions asked in the Belgian workshop ........................................................19 Table 6. Current outlook of the specific regulatory framework for H2. Columns in purple – based on European Hydrogen Observatory [2]. Column in blue – based on the information collected during the HYPOP project from different resources. ...............................................................................................25 Table 7. Current outlook of the specific regulatory framework for H2. Column in purple – based on European Hydrogen Observatory [2]. Column in blue – based on the information collected during the HYPOP project for different resources. ...................................................................................................39 Table 8. International and European standards considered for the implementation of HRS in Belgium [1] ............................................................................................................................................................40 Table 9. European directives on safety for HRS in Belgium [1] .................................................................41 Table 10. Requirements and barriers from the industrial field, local urban planning and safety regulations affecting HRS in Italy [1] ...............................................................................................................41 Table 11. Customised mobile HRS registration protocol for H2 rail vehicles (FCH2RAIL) [1] .............42 Table 12. Overall contact authorities found in Swiss guidelines [8] .........................................................52 Table 13. Required documents when implementation planning has been initiated in the German guidelines. Collected from [13] .........................................................................................................................55 Table 14. Main requirements collected during Deliverable D4.3. .............................................................57 Table 15. Description of applicable procedures. Collected from [8] .........................................................71 Table 16 Expert opinions for plant approvals. Collected from [8] .............................................................72 Table 17 Relevant legislation in The Netherlands. Collected from [15] ...................................................74 Index of Figures Figure 1. Spanish workshop 1 at the CNH2 premises. Photograph by CNH2 ........................................11 Figure 2. Spanish workshop 2 at the National Green Hydrogen Congress in Huelva. Photograph by CNH2......................................................................................................................................................................12 Figure 3. Answers according to question 2 - Spanish workshop 1 ............................................................14 Figure 4. Answers according to question 2 - Spanish workshop 2 ............................................................14 Figure 5. Questions answered about permitting in the Italian workshop ................................................19 7 Figure 6. Main types of laws considered in the Sibinj Energy Park Study (Croatia). Collected from [] .................................................................................................................................................................................27 Figure 7. Aspects taken into account for the development of the plant in Croatia. Adapted from [3] .................................................................................................................................................................................28 Figure 8. Permitting process carried out in the GreenH2CY Project (Summary of the information collected with the support of the stakeholders). ...........................................................................................30 Figure 9. Hydrogen Networks Regulations in Germany [1] ........................................................................34 Figure 10. Main parts of the procedure for hydrogen pipelines in Germany. Adapted from [6] ........36 Figure 11. Overview of applicable procedures in the official guideline for Switzerland. Adapted from the guidelines8. .....................................................................................................................................................37 Figure 12 Expert opinions on the approval of the plan for the official guideline in Switzerland. Adapted from the guidelines8 ............................................................................................................................38 Figure 13. Summary of requirements for HRS in Poland. Collected from [1] .........................................44 Figure 14. Stages in HRS development. Adapted from [] ............................................................................47 Figure 15. German guidelines as support for stakeholders. Layout of the stakeholder procedure (HRS <3 ton)1 ........................................................................................................................................................50 Figure 16. HRS procedure in the Netherlands. Adapted from Hydrogen Delivery Installations PGS 35:201515 ..............................................................................................................................................................51 Figure 17. Diagram for the Gösgen project in the Canton of Solothurn. Collected from [8] ...............53 Figure 18 Overview of the procedure in Switzerland based on [8] .........................................................54 Figure 19. Overview of the procedure in Germany based on [13] ............................................................55 Figure 20. Key aspects of hydrogen permitting. Collected and adapted from [] ....................................58 Figure 21. Key aspects of hydrogen production licenses. Adapted from [16] ........................................59 Figure 22. Key aspects of hydrogen distribution and storage licenses. Adapted from [16].................59 Figure 23. Key aspects of administration. Adapted from [6,16] ................................................................60 Figure 24. Main regulations applied in Croatia to install an Energy Park. Adapted from [3] ...............64 Figure 25. Main regulation for HRS in Poland. Adapted from [1] ..............................................................65 Figure 26 Process for obtaining permits applied in Lithuania based on [11,] ........................................66 Figure 27 Kubel project in the canton of St. Gallen [8] ..............................................................................67 Figure 28 Schiffenen project in the canton of Fribourg [8] .......................................................................68 Figure 29 Birsfelden project in the canton of Basel-Landschaft [8] .........................................................69 Figure 30 Wildegg-Brugg project in the canton of Aargau [8] ..................................................................70 Figure 31. Main regulations applied in the Netherlands to install HRS. Adapted from [15] ................73 8 Partners short names ENVI Parco Scientifico Tecnologico Per L’ambiente Environment Park Torino Spa IMI Institute For Methods Innovation IME Fundacion IMDEA Energia APRE Agenzia per la Promozione della Ricerca Europea CNH2 Centro Nacional Del Hidrogeno RIGP Regionalna Izba Gospodarcza Pomorza CLUSTER TWEED Cluster Tweed BH2C Balkanski Vodoroden Klaster Abbreviations TECNIBERIA Spanish Association of Engineering, Consultancy and Technology Services Companies SNAM Società Nazionale Metanodotti H2IT Italian Hydrogen Fuel Cell Association PAS Simplified Authorisation Procedure HRS Hydrogen Refuelling Station IED Industrial Emissions Directive QRA Quantified Risk Assessment DVGW German Technical and Scientific Association for Gas and Water EIA Environmental Impact Assessment CNG Compressed Natural Gas LPG Liquefied Petroleum Gas PCI Project of Common Interest CERA Cyprus Energy Regulatory Authority PSG Publicatiereeks Gevaarlijke Stoffen WABO Wet Algemene Bepalingen Omgevingsrecht NMG Ministry of National Economy AUA Single Environmental Authorisation AIA Autorizzazione Integrata Ambientale / Integrated Environmental Authorisation ENAV Air Navigation Services AfU Amt für Umwelt / Environment Office 9 Executive Summary The HYPOP project (Hydrogen Public Opinion and Acceptance) is co-funded by the Clean Hydrogen Partnership under the European Horizon Europe programme (GA nr.101111933) and aims to raise public awareness and trust in hydrogen technologies and their systemic benefits. The aim of WP4 is to provide guidelines on permits, certification and safety, for the purpose of addressing information gaps in some countries. Following the structure of WP2, HYPOP countries, EU-13 countries and Frontrunner countries have been studied on the basis of three main pillars: the industrial, mobility and residential sectors. (Note that all the countries considered in this report are mentioned in the corresponding sections and this can be checked in the table of contents). This document aims to offer guidelines on obtaining permits and to this end, a compilation of information has been prepared through workshops in the project countries (Spain, Italy, Belgium, Bulgaria and Poland) to analyse the main barriers and gaps everyone identified during the installation of hydrogen facilities. Meetings with stakeholders were also organised, where possible, and bibliographic searches have been conducted to collect as much information as possible. Based on the information obtained from the aforementioned sources, the report concludes that in general there is no specific legal framework for the deployment of hydrogen projects and/or wellestablished procedures. After presenting the legislative landscape of the countries, those with greater development or clear procedures are used as examples. Specific actions that might be considered in the creation of a process, or suitable rules, are also recommended, and can be seen in section 6, where steps suggested for the deployment of hydrogen projects are shown. The discussion with the stakeholders and further research highlights that it is crucial to educate experts for the advancement of these technologies, also to create permitting procedures that facilitate safe and timely rollout. To this end, establishing cross-sector working groups—bringing together local and national authorities with industry actors in the chemical and renewable-energy sectors—will help address issues incrementally and translate solutions into clear, actionable permitting rules. It is also important to designate a lead competent authority to act as a single point of contact, coordinating dossier circulation to other bodies or directing applicants to the appropriate contacts after an initial project screening. Because requirements may vary by region and site, authorities there should be a well-defined, standardized process map that sets out responsibilities, documentation, and decision points to support consistent, efficient project approvals. 16 - CertifHy, that is an initiative started in 2014 and funded by the Clean Hydrogen Partnership with the aim of taking Europe-wide green and low-carbon hydrogen certification to the next level: from concept to implementation. - ISO standard 14687-2:2012 “Hydrogen fuel – Product specification”. - SAE J2719 standard “Hydrogen fuel quality for fuel cell vehicles”. - ISO standard 19880-1:2020 “Gaseous hydrogen – Fuelling stations”. 6) What barrier/s have you encountered during the installation of H2 technologies? In workshop 1, 12 people responded, while in workshop 2, 22 people responded, specifying the barriers. The answers have been grouped into four categories: - Economic viability: these included funding, competitivity without a grant, the supplydemand balance and cost rationalisation. - Knowledge: lack of information and awareness (generally from the administrations), availability of previous infrastructures and lack of precedents were also shown to be an issue. - Safety: ignorance about safety, safety itself and the difficulty in detecting hydrogen leakages were other topic addressed. - Permitting and certification: the lack of regulation, regulation ambiguity and the discrepancies or differences in the criteria between different entities of the same government, the fear of risk, the lack of a certification process and the execution deadlines were emphasised by the participants. When finishing workshop 2, one of the attendees highlighted the importance of disseminating the H2 properties and the safety measures applied in H2 usage, such as detection. Another expressed his concerns about hydrogen implementation, because there are many projects on paper but only a few were being implemented, and this participant also added that the green hydrogen price (€/kg) is not well defined. 3.2 Technical workshop: Italy The Italian workshop was held on the 23rd of May 2025 and took place at Hydrogen Expo Piacenza. It was organized by ENVIPARK, which was represented by Mattia Miglietta, in collaboration with H2IT. The workshop was attended by private companies and public authorities. A roundtable on authorised procedures for hydrogen was conducted to discuss the main barriers and future perspectives with the participation of Francesco Bonadeo (SNAM), Francesca De Falco (REGIONE CAMPANIA) and Francesco Vitali (TECHFEM). It was shown that, in terms of permitting, it is essential that the project is presented in advance to authorities and administrations in order to gather comments and then develop a design for “fit for purpose” permits. Permits drew considerable interest from the audience, sparking a lively debate on several features of the current regulatory framework. SNAM shared the example of a hydrogen valley project that successfully made it through the authorisation process. The project centres on a 2.5 MW electrolyser powered by a 6 MW photovoltaic plant and includes four loading bays for tube trailer filling. The steps and scopes are shown in Table 3. 17 Table 3. Strategy followed by SNAM for a hydrogen valley project Step Legal reference Competent authority Permit scope Exemption from Environmental Impact Assessment (EIA) and from EIA Screening Italian Env. Code, Leg. Decree 152/2006 – Art. 6-bis, Annex II, Part II; Art. 8 (l), Annex IV, Part II – Environmental Derogation from Integrated Environmental Authorisation (AIA) Leg. Decree 152/2006 – Art. 4.2.a, Annex VIII, Part II Emilia-Romagna Regional Authority Environmental Single Authorisation (Autorizzazione Unica) under Art. 12 DPR 380/2003, issued pursuant to Leg. Decree 199/2021 – ARPAE SAC Modena (Regional environment Agency) Urban planning/building Project assessment under FireSafety Regulations DPR 151/2011 – Art. 3 (activities 1.1.C, 2.2.C, 3.3.C, 49.1.A) Provincial Fire Brigade Command, Modena Safety/fire Single Environmental Authorisation (AUA) – – Discharges, emissions, etc. Permit to discharge water into a watercourse and sewer – – Environmental No objection from the Superintendency of Archaeology, Fine Arts and Landscape – – Cultural, heritage and landscape Declaration of no interference with ENAV (air navigation services) – – Aviation One of the main points added is the low experience and the perception of public authorities towards hydrogen: although pursuant to Legislative Decree 199/2021, the size of the electrolysis unit would have allowed for free construction or at least the PAS procedure, but as a precautionary measure the Municipality of Modena requested the possibility of voluntarily proceeding with a Single Authorisation, resulting in a longer procedure. 18 The new national environmental rules have cleared up previous doubts over interpretation: green hydrogen production projects are now explicitly exempt from an Environmental Impact Assessment when they involve refuelling stations or when the hydrogen is produced for downstream end uses. In addition, an exemption from EU legislation is expected that would remove this type of plant from the list of facilities required to obtain an Integrated Environmental Authorisation. Similarly, Techfem outlined its own permit strategy for a hydrogen production plant. The company filed a single digital application through the ZES Calabria One-Stop Shop on the 30th of November 2023, bundling the procedures shown in Table 4. Table 4. Strategy followed by Techfem for a hydrogen production plant Procedure Description Autorizzazione Integrata Ambientale (AIA) Regionale Regional Integrated Environmental Authorisation Autorizzazione Paesaggistica Ordinaria (interventions in areas subject to landscape restrictions, Art. 146, Leg. Decree 42/2004) Ordinary Landscape Authorisation Screening Valutazione d’Incidenza (VIncA) Screening for Appropriate Assessment (Habitats Directive) Valutazione Preventiva dell’Interesse Archeologico (VPIA) Preliminary Archaeological Interest Assessment Valutazione Previsionale di Impatto Acustico (Art. 8, Law 447/1995) Forecasted Noise Impact Assessment Dichiarazione Inizio Lavori Asseverata (DILA/CILA) for the photovoltaic plant Self-Certified Start-of-Works Declaration for the PV array Verifica di Compatibilità Idraulica – AdB Distretto Appennino Meridionale Hydraulic compatibility check by the Southern Apennines River Basin Authority Istanza di Valutazione Progetto to the Catanzaro Fire Brigade (DPR 151/2011) Project Evaluation Request to the Catanzaro Fire Brigade Command (fire safety authorisation) Valutazione Ostacoli ENAC/ENAV Obstacle clearance assessment by the Italian Civil Aviation Authority (ENAC)/AirNavigation Service Provider (ENAV) It can be seen how both the strategies in Table 3 and Table 4 have similar procedures. After that, the workshop was concluded with a Slido Q&A session, which some participants answered. Some questions related to permitting are shown in Figure 5. 19 Figure 5. Questions answered about permitting in the Italian workshop The two main takeaways regarding permits in the Italian workshop relate, first, to the uncertainty in framing regulatory requirements with respect to the characteristics of hydrogen, its technologies and the project in general, and second, to the fact that the main gaps in permitting procedures concern safety permits. 3.3 Technical workshop: Belgium A total of 18 people attended the Belgian workshop, which was held online on the 24th of January 2025. There were two sessions. The first one was a presentation on the current state of permitting in Europe. During this session, Mattia Miglietta from ENVIPARK presented the HYPOP project, after which Simon Habran, from CLUSTED TWEED led a presentation focusing on the current situation in Belgium and neighbouring countries. The second session was a roundtable discussion on the topic of “finding the right guidelines for new hydrogen facilities in Wallonia”, in which stakeholders shared their experiences. The roundtable comprised Sertius (represented by Xavier Musschoot), a company involved in environmental and safety services; Colruyt Group (represented by Catherine Goormaghtigh), a food store chain which has developed HRS (6 in Belgium); RESA (represented by Sébastien Dubois), a public company dedicated to the gas and electricity distribution network; and the Free University of Brussels (represented by Patrick Hendrick). After both sessions had finished, there was a brief Q&A session, the results of which are shown below: Table 5. Overview of the questions asked in the Belgian workshop Questions asked in the Belgian workshop 1 What are the main challenges you have encountered in obtaining or granting permits for hydrogen-related projects? 20 2 How does the environmental permit process for hydrogen projects compare to that of other energy technologies? What improvements do you suggest? 3 Have you experienced significant differences in permit processes between regions or municipalities? If so, how do these disparities affect project implementation? Additionally, what improvements would you propose to harmonise or streamline these processes? 4 What are the main challenges in demonstrating the safety of hydrogen plants? 5 What improvements would you propose to overcome regulatory barriers in your country? 1) What are the main challenges you have encountered in obtaining or granting permits for hydrogen-related projects? The administrative requirements in Wallonia are unclear. Public services generally fear this new technology. This is due to a lack of experience, as they are generally unfamiliar with hydrogen. In an effort to raise awareness regarding this technology, Colruyt invited the Walloon authorities to their first HRS in Flanders as part of the permit process in Wallonia, in order to raise awareness regarding this technology. Training and raising awareness among authorities is essential, and the industry can primarily join in the process. After obtaining a permit, you need to insure your project. This is also a delicate step, as the insurance company must have confidence in the project to avoid charging exorbitant prices or requiring additional safety measures. We are therefore faced with the same problem: we need to raise awareness among stakeholders. There is a need for change in the classifications for permit procedures in Wallonia. For example, the Industrial Emissions Directive (IED) should not apply to hydrogen facilities, as is the case in Flanders. This directive is indeed very restrictive. 2) How does the environmental permit process for hydrogen projects compare to that of other energy technologies? What improvements do you suggest? The same problem arose during the development of compressed natural gas stations. The Colruyt Group had to meet with the relevant authorities and firefighters in each municipality to convince them that the installation would be safe and would not pose excessive risk. Therefore, the problem is not the technology itself, but rather public and stakeholder awareness and perception of new technologies. We can develop and implement multiple safety measures and technologies that eliminate risks, but people’s perception of this new technology remains the major problem. 3) Have you experienced significant differences in permit processes between regions or municipalities? If so, how do these disparities affect project implementation? Additionally, what improvements would you propose to harmonise or streamline these processes? Subjectivity is a problem in administrative monitoring in Wallonia. While the administration does consult competent people, such as firefighters, there is no clear framework to follow. The 21 framework in Flanders is better defined, making it more objective. Flanders has a well-defined permit process, whereas Wallonia does not. As the administration lacks expertise in hydrogen, it often refers to SEVESO regulations, even for small projects. As there are no specific acceptance criteria, they follow the SEVESO criteria, which are very restrictive for HRS. 4) What are the main challenges in demonstrating the safety of hydrogen plants? As stated before, the primary issue is not the technical aspect, but rather stakeholder acceptance upon demonstrating the safety of the product. 5) What improvements would you propose to overcome regulatory barriers in your country? A regulatory framework that does not differ between the various member states. On this note, attendees wondered why there was not a regulatory framework. Participants proposed the actions listed below to improve the development of hydrogen projects: - The first action was to include insurance companies among the stakeholders. They are often overlooked, even though they are essential for the project’s successful development. If an insurance company does not consider a project to be secure, it will not insure it. - The next issue is the need for specific files and the best available technologies for hydrogen production. - Following this, the permitting process in Wallonia is more subjective and lacks concrete practices, whereas Flanders takes a more objective and scientific approach. Stakeholders need a well-defined permitting process for hydrogen projects in the Walloon region. - The need for change in the classifications for permit procedures in Wallonia. For example, the Industrial Emissions Directive (IED) should not apply to hydrogen facilities, as is the case in Flanders. So, Wallonia applies the IED but Flanders does not. - Improve the experience and involvement of the Industrial Risk Departments (a department of the Walloon administration). This could result in shorter processing times and better project evaluations. - Permit delays in Wallonia need to be reduced. Currently, the process can take up to a year or more. - Develop a unified EU-level guideline for hydrogen technology permitting. - Finally, improve social acceptance and trust in the safety of hydrogen projects. Additional safety measures are even more important than this. Due to the lack of concrete permit processes in the Wallonia region, stakeholders need more concrete processes to implement hydrogen projects, as in the case of the Flanders region. 3.4 Technical workshop: Bulgaria On the 27th of January 2025, the Bulgarian workshop was held at the Bulgarian Academy of Sciences in Sofia. Vasimir Radulov, the BH2C representative, presented the HYPOP project to the participants. Attendees included representatives of the following organisations: the State Agency for Meteorology and Technical Supervision, the Bulgarian Academy of Sciences, various universities, municipalities, and the National Fire and Civil Safety Services. 22 The State Meteorological Agency representative provided a comprehensive overview of the measures adopted in Bulgaria and the most legislatively advanced countries regarding hydrogen. The participants then expressed their opinion that the state authorities should take a proactive approach and introduce legislative norms more quickly in order to enable businesses to adopt hydrogen on a large scale. The National Fire Safety and Civil Protection Service informed participants of all the legal and regulatory requirements and practical examples related to the production, storage and use of hydrogen. Finally, the BH2C and representatives of municipalities and universities presented all the perspectives and opportunities for using green hydrogen. The possibilities of creating hydrogen energy communities on a local basis for the benefit of municipalities and businesses were discussed. In relation to safety related to hydrogen projects, representatives of the Meteorological Agency, the Fire Department and local authorities —the municipalities on whose territory such projects are being or will be deployed— discussed the matter. In Bulgaria, hydrogen-related projects are carried out in accordance with the Spatial Planning Act and the Regulation on the Storage and Transport of Pressurised Gases. These documents set out the technical requirements for hydrogen facilities, as well as for the transport and storage of hydrogen. Each project is implemented in this way. One specific hydrogen project that has been implemented in Bulgaria in accordance with the aforementioned legislation is the modular refuelling station of the Bulgarian Academy of Sciences. The topic of issuing permits for hydrogen projects and the use of hydrogen was also discussed by all participants. Currently, permits for the production and use of hydrogen are issued in Bulgaria by the State Meteorological Agency. A working expert group is to be established within the Agency specifically for hydrogen project permits. Stoyan Sabev, the Chief Chemical Engineer of the BH2C, will lead this expert group, as he is one of the few experts with nearly 40 years’ experience in hydrogen-related projects, having designed, built and exported various projects relating to hydrogen production, use, storage and transport. Participants expressed their hope that this group will provide positive momentum for hydrogen projects and their permits. 3.5 Technical workshop: Poland The Polish workshop took place in Pomeronian Voivedato, Gdańsk on the 15th of May 2025, and was also attended by 18 regional entities. The meeting began with a display of the goals and framework of the HYPOP project. The geographical scope of the project and the team, which includes hydrogen clusters, research bodies and public communication groups, were explained. Special attention was given to the Social Life Cycle Assessment method, which helps pinpoint social issues in hydrogen initiatives. RIGP also shared effective methods for certification and safety that have been created at the EU level and talked about tools for implementation. 23 Participants that took part in the meeting were from sectors such as transport and logistics infrastructure, gas systems, providers of energy and technology solutions, hydrogen sector companies, environmental consultancies and the regional government authority. In the discussion, attendees talked about their experiences, requirements and difficulties when implementing hydrogen projects. Main issues were identified and are shown below: - Complicated and unclear administrative procedures, - Absence of consistent local standards, - Limited skills among officials in the technical and legal areas regarding hydrogen systems, - Lack of effective public communication tools and ways to involve citizens, - Untapped opportunities to collaborate with EU-funded initiatives, - The necessity for common guidelines for the Pomeranian area. The conversation showed both systemic and structural obstacles, but also highlighted areas where immediate action could be taken. Based on the discussion, the RIGP colleagues concluded with the following aspects: 1) The need to update the regional strategy, where it was considered to include a social component that reflected citizens’ attitudes, knowledge and readiness to accept hydrogen technologies. 2) The improvement in local government capacity, as there are gaps in public administration knowledge, specifically in the interpretation of technical procedures, such as technical standards, the environmental impact assessment, and the regulations and certification procedures. 3) It was suggested that education and public communications be strengthened. 4) The involvement in national and EU projects, allowing every region to actively join in the developing of hydrogen technologies, enabling the transfer of knowledge and mutual learning about the challenges and steps given for the project to progress. 5) Developing participatory regional roadmaps and implementation scenarios, which involve local authorities, sector professionals and investors that foster technological progress. 24 4 Overview of the European regulatory landscape During the development of the final HYPOP permitting guidelines, activities carried out in Work Package 4 were accompanied by the research of additional information on the regulatory landscape. The objective was to find out more about the regulatory framework or installation procedures for hydrogen plants in countries not identified in Work Package 2. This was achieved by searching for relevant legislation and by contacting companies in the renewable energy or hydrogen sector, as well as public authorities that might be responsible for regulation. This section has three sub-sections: industry, mobility and residential sectors. A brief review of the countries analysed in deliverable 2.2 1 was also conducted to compare the regulatory framework of all the countries involved in this project. In sections 4.1 Industrial sector and 4.2 Mobility sector it was deemed appropriate to add tables (Table 6 and Table 7) as a preliminary overview of the situation in each country. The perspective was based on consultations with the European Hydrogen Observatory and, in general, also on searches and consultations carried out during the project, which are marked in the same table where they can be seen in more detail within this deliverable or in other deliverables of this project. It should be noted that not all the supplementary information is specifically related to hydrogen; in many cases, steps have been identified that are being taken even though there is no specific legislation for hydrogen, and these have been considered relevant to the document. During the HYPOP project, information was sought in the countries concerned on the existence of specific legislation for hydrogen in the industrial, mobility and residential sectors. Unfortunately, in the latter case, it has not been possible to find much information beyond that discussed in D2.2. However, in the case of industry and mobility, this section summarises the information discussed in D2.2 and seeks new information for those countries not covered. Thus, all the information has been consolidated in this section, divided into sectors and the information found for each country is discussed. 1 https://www.hypop-project.eu/wp-content/uploads/2024/07/D2.2.pdf 25 4.1 Industrial sector As can be seen in Table 6, based both in the European Hydrogen Observatory 2 and in the results of the HYPOP project, most countries do not have a specific framework for hydrogen. However, in some cases, which will be detailed in the subsections, the requirements that would be taken into account or that have been taken into account for the projects that have been developed have been revealed to the extent possible. Table 6. Current outlook of the specific regulatory framework for H2. Columns in purple – based on European Hydrogen Observatory [2]. Column in blue – based on the information collected during the HYPOP project from different resources. Official permit process for H2 production projects Legal framework for the operation of H2 storage facilities within national energy law Additional information about legal framework found during HYPOP research – regardless of [2] HYPOP countries Belgium No No - Italy No* No* More detail in D2.2 or section 3.2 Spain Yes* Yes* More detail in D2.2 EU 13 countries Bulgaria No No - Poland No No - Croatia No No More detail in section 4.1.2.3 Cyprus No No More detail in section 4.1.2.4 Czech Republic No No More detail in section 4.1.2.5 Estonia No No - Hungary No No More detail in section 4.1.2.7 Latvia No No More detail in D2.2 or section 4.1.2.8 Lithuania No No - Malta No No More detail in D2.2 or section 4.1.2.10 Romania No Yes - Slovakia No No More detail in section 4.1.2.12 Slovenia Yes No - Frontrunner countries France Yes Yes More detail in D2.2 or section 4.1.3.1 Germany Yes Yes More detail in section 4.1.3.2 Switzerland Yes No More detail in section 4.1.3.3 and 6.d 2 https://observatory.clean-hydrogen.europa.eu/hydrogen-landscape/policies-and-standards/national-policy [viewed in July 2025] 32 refuelling stations— are currently not permitted because they are not explicitly provided for in existing regulations. These solutions may be approved if implemented in private settings, but in public areas, new regulatory provisions are required, which do not currently exist. Similar to the challenges encountered with municipal authorities, there are also significant issues related to public acceptance, with many citizens expressing concerns or resistance. From a perception standpoint, National Hydrogen platform (HYTEP) reports a high level of openness and willingness from national-level public authorities, but possible barriers and limited awareness or acceptance at the regional level, depending on the specific administrations involved. 4.1.2.6 Estonia Estonia neither produces nor consumes green hydrogen, so there is no specific permitting guideline for hydrogen2. 4.1.2.7 Hungary In Hungary, the creation of two hydrogen valleys was planned for 2030, known as the "Transdanubia Hydrogen Ecosystem" and the "Northwest Hydrogen Valley". Both areas are dedicated to the chemical and petrochemical industry, with significant hydrogen use. The process of obtaining permits varied for each project, as it depended on its duration. Moreover, some of the parameters that determined the actual timelines were the determination of the number of authorities that would be involved in the permitting process, the duration and what information would be required from the investor to apply for different permits. Some of the legislation that guided the process related to: - Rules for the administration of construction procedures in certain industrial facilities - Various decrees on environmental impact assessment, protection against serious accidents, certification of equipment and protection systems for use in explosive areas, or the supervision of pressure equipment. - Fire regulations. More specific information on the legislation is detailed in deliverable 2.2. 4.1.2.8 Latvia A hydrogen project in Latvia is considered as a set of facilities, with each technology following individual procedures with their own durations. The overall permit requirements are building (planning), operation and environmental, dealt with by municipal and local authorities and the State Environmental Services, as discussed in deliverable 2.2. Moreover, the main reference legislation is the Construction Law which regulates the building and operation permits. Before that, the project owner has to assess whether an Environmental Impact Assessment procedure is required. Although there are no specific limits for a hydrogen production plant to be built, it must only be located in an area destinated to be industrial since it is considered a chemical production1. 4.1.2.9 Lithuania Lithuania states that there are currently no official rules or legal structures for running hydrogen facilities in the industrial sector. However, there is a plan for the advancement of hydrogen in the country set for 2024 to 2050. Also, the limit for H2 in the gas grid is up to 2%2. 33 4.1.2.10 Malta The MelitaTransGasProject was in development, which required following a procedure for obtaining permits as outlined in the Manual for the Permit Granting Process for Projects of Common Interest (PCI) 4 . The Planning Authority serves as the Competent Authority in this scenario. The laws applicable to the PCI include general regulations, such as those focused on health and safety or transportation; additional laws relate to the environment, including those governing industrial emissions and environmental conservation; further regulations pertain to construction laws that address development plans; finally, there are laws concerning the management of energy and water services, along with regulations specific to the gas market. All these laws are detailed in the aforementioned manual. 4.1.2.11 Romania To date, Romania lacks a specific national plan for the hydrogen industry, although it appears that one is under development. However, ANRE (National Energy Regulatory Authority) approved the order on the “Hydrogen Code”, ANRE Order no. 63/20232. 4.1.2.12 Slovakia The EASTGateH2 Valley was started in April 2025, which aims to install a total of 4 MW of electrolytic hydrogen production within a hydrogen refuelling station (HRS) 5 . Although it is not a legal framework for the operation of hydrogen storage2, the main parts of the procedure (that have been under consultation which stakeholders from this country) will require, at least, one year in duration, are shown below: • Detailed technical report, which includes the plant design, operation and technology interfaces. The project developer will have to prepare a comprehensive engineering report, where the technical aspects (including the characteristics of the electrolyser, compressor, etc. and the process flows or the control mechanism, for example) should be explained. The competent authority is the Technical Inspection Authority and the City Council. • Grind-connection permit. A file about the electrolyser must be presented independently to the regional distribution-system operator to secure and establish protection parameters. The contract must be in hand before the construction can start. The competent authority is the grid operator or the energy authority. • Environmental permits. The electrolyser requires a full EIA, which includes a feasibility study that focuses on water demand, wastewater, noise and the site’s proximity to Natura 2000 habitats. It must be taken into account when locations fall beside protected zones. The competent authority is the District Environmental Office. • Urban planning consent. This is not considered critical. In this case, the electrolyser may be built outside traditional industrial zones. The municipality is the competent authority in this case. 4 https://www.pa.org.mt/en/projects-of-common-interest 5 https://cordis.europa.eu/project/id/101192335/es 34 • Building permit. This requires the consent of the landowner. Once all procedures have been approved, and the landowner has given his or her consent, the authority issues a building permit, provided there are no objections. The responsible body is the Building Authority or the District Council. 4.1.2.13 Slovenia Slovenia has no official legally binding limit, but the share of the limit is mentioned in the Gas Supply Act. According to Article 7 of this law, “the decision falls strictly on the distribution network operators, but in practice, no more than 10% of hydrogen should be introduced in the gas network”2. 4.1.3 Frontrunner countries 4.1.3.1 France The French national strategy has been updated in April 2025, updating the objectives set out in 2020. The official permitting guidelines for hydrogen projects are called “Installations Classées pour la Protection de l’Envionnement (ICPE)”. The classification obtained by the facility depends on the potential impact it may have on the environment2. The legal framework, that is the “Régime legal des stockages souterrains”, takes into account hydrogen storage facilities within the fields of energy, mining, environment, ICPE safety standards and compliance with EU directives2. 4.1.3.2 Germany When it comes to industry, hydrogen networks were regulated by laws like the Energy Industry Act, the Combined Heat and Power Act, the German Technical and Scientific Association for Gas and Water Regulation (the DVGW Regulation is its acronym in German) and the Renewable Energy Act. You can find a summary of what each one deals with in Figure 9. Hydrogen Networks Regulations Energy Industry Act This Act is all about how the electrolyser is connected to the grid. The Combined Heat and Power Act This Act says that there will be surcharge payments for the cogeneration of electricity. DVGW Regulation This sets out the general requirements for gases in public supply networks, allowing up to 10% vol. of hydrogen and the general rules affecting the technical requirements for hydrogen injection into the gas supply network. Renewable Energy Law This law contains a collection of articles about hydrogen, relating to the certification of origin and Power to Gas plants and CHP systems. You can see more articles about this in deliverable 2.2. Figure 9. Hydrogen Networks Regulations in Germany [1] The document known as the “Cambridge handbook of hydrogen and the law” shows the permit regime for the construction of pure hydrogen pipelines and is divided into regional planning, plan approval, environmental law, pipeline rights and land use agreements. 35 Under regional planning, it has been making efforts to enhance cohesion between regional planning and approval processes. Getting started with the plan approval, as large infrastructure projects often lead to conflicts of interest, the plan approval involves extensive participation by the authorities and, in most cases, the public 6 . Germany has two types of procedures, simplified or formal. If the procedure is formal, a public consultation, known as a plan approval decision, is required. However, when is simplified, this is not required and it is known as plan authorisation. The main difference between the two procedures is the exclusion of mandatory public participation during the plan authorisation procedure, with the aim of accelerating the procedure. The same happens with EIAs, which will be needed depending on the characteristics of the hydrogen pipeline, with public participation being mandatory6. Note that “in the case of a facultative plan approval, the advantage over plan authorisation would be that the specific acceleration regulations under energy law would apply, until 31 December 2025”, stated in part 15 – Accelerating Permission 7 . Because the competent authority must first be aware of the proposed energy installation, the administrative opening control (which is what this procedure is called) requires that the developer submit an application for permission to inform the authority before constructing and operating an energy plant. An EIA may or may not be mandatory depending on the specifications of the hydrogen grids. When not mandatory, it can be determined through an official assessment and checked relatively quickly. Moreover, plan authorisation offers advantages over plan approval, because both have the same legal effect, but the first has a less time-consuming requirements. In regards to the environmental aspects, a preliminary assessment can be made to quickly check if an EIA is needed because these procedures are generally quite time-consuming, taking an average of 16.8 months7. This is challenging for the fast development of a hydrogen infrastructure and will need to be studied in-depth. Lastly, land use should be taken into account, drafting agreements with landowners for the construction and operation of the pipelines (even though it is not specifically for hydrogen)6. The requirement of an EIA also affects whether a plan approval or a plan authorisation is granted7 and it depends on the characteristics and scope of the hydrogen pipeline. In the document mentioned above, it is reported that there is no legislative framework for underground hydrogen storage, more specifically in salt caverns, but according to the draft, the same requirements as for natural gas will apply. However, the construction of a hydrogen storage facility will require an EIA under the mining law, thus requiring planning approval. 6 https://www.cambridge.org/core/books/cambridge-handbook-of-hydrogen-and-the-law/regulatinghydrogen-transport/5B1C65218B931C98A5D05528B03610EA (Part IV Regulating Hydrogen Transport) 7 https://www.cambridge.org/core/books/cambridge-handbook-of-hydrogen-and-the-law/acceleratingpermission/647CDCAB1A8708EAE1D0C58590894DF1 (15 - Accelerating Permission) 36 Figure 10. Main parts of the procedure for hydrogen pipelines in Germany. Adapted from [6] 4.1.3.3 Switzerland In this case, it is worth mentioning that, even though there is no specific legislation for hydrogen technologies, there is cooperation between public authorities that issue different types of permits. Following the guidelines 8 , there is also a main authority (the cantonal or municipality authority) that acts as a point of entry and provides support to stakeholders in the hydrogen value chain. Usually, the whole permit process is overseen by one authority, which serves as a central point of contact for stakeholders. In this country, the principle of procedural coordination applies, which means that the main authority is responsible for reviewing all the documents, coordinating with the rest of the competent authorities and issuing all permits in a single decision. If this is not possible, the competent authorities can, at least, ensure the coordinated public disclosure of their decisions, provided that the designer ensures that all permits are submitted to the competent authorities in a timely manner and refers to the parallel application in both applications. The main documentation you need to submit depends on the type of permit. So, we will need to do an environmental analysis (and get an EIA if that is needed). Then there are building permits and urban planning or regulations to think about. And, of course, there are safety requirements to consider too. This is because there is an official guideline for Switzerland8, the steps of which are summarised in Figure 11 and in more detail in Appendix A. Additional information on applied regulations. 8 https://www.google.com/url?sa=t&source=web&rct=j&opi=89978449&url=https://pubdb.bfe.admin.ch/de/p ublication/download/11554 Simplified procedures - public participation is not required - Approval plan Formal procedures - public participation is required - Authorisation plan Regional planning EIA may or may not be required A preliminary assessment can be made to determine whether an EIA is needed Environmental aspects Land agreements with landowners Land use 37 Figure 11. Overview of applicable procedures in the official guideline for Switzerland. Adapted from the guidelines8. The general process is followed by risks assessments, noise, fire and explosion protection, protocols for serious accidents and assessments related to standards and environment. In the last of these, it depends on the conditions of the facility, as shown in Figure 12. ▪Building permit ▪Planning permission ▪Planning permit for electrical installations ▪Operating license Permits for the construction of the plant: ▪Electrical components ▪Prove system compliance ▪Commissioning of pressure equipment The buildings must then be approved by the competent authorities: ▪Request for a proof of conformity from the manufacturer of the H2 production equipment ▪Application for an operating permit (before starting production) When the works are complete, the competent authorities are informed: 38 Figure 12 Expert opinions on the approval of the plan for the official guideline in Switzerland. Adapted from the guidelines8 Expert opinions for the approval of the plant Standard assessment Environmental assessment Necessary if: Gas storage > 50,000 m³ Liquid storage >5,000 m³; Plant operating area > 5,000 m² Chemical synthesis >1,000 tonnes/year Serious accident preparedness Risk assessment Noise protection Fire protection Explosion protection 39 4.1.3.4 The Netherlands The permitting framework in the Netherlands includes various requirements for obtaining permits, such as environmental permits, which involves QRA to evaluate safety risks, building permits and water act permits2. There is a subsidy that can be applied to projects in which the hydrogen production installation is put into operation within four years of the subsidy being granted. So, this is the main condition to grant permits such as WABO2. 4.2 Mobility sector Table 7 shows an outlook of the regulatory framework for purely hydrogen-based projects in the European Hydrogen Observatory, following the answers of the question “Are there official guidelines in place that cover permitting of HRS?” for every country covered in the project. Note that in some cases this could differ from the information found during the HYPOP project. In cases where it has been seen, this will be discussed in the corresponding subsection and marked with an asterisk in the table. Table 7. Current outlook of the specific regulatory framework for H2. Column in purple – based on European Hydrogen Observatory [2]. Column in blue – based on the information collected during the HYPOP project for different resources. Official guidelines in place that cover permitting of HRS Additional information about the legal framework found during HYPOP research – Regardless of [2] HYPOP COUNTRIES Belgium Yes More details in D2.2 or 4.2.1.1 Italy Yes More details in D2.2 or 4.2.1.2 Spain No* More details in D2.2 or 4.2.1.3 EU 13 countries Bulgaria Yes More details in D2.2 or 4.2.2.1 Poland No* More details in section 4.2.2.2 or 6.b Croatia No - Cyprus No - Czech Republic Yes More details in section 4.2.2.5 Estonia No - Hungary Yes More details in section 4.2.2.7 Latvia No More details in section 4.2.2.8 Lithuania Yes More details in section 4.2.2.9 Malta No - Romania No - Slovakia No More details in D2.2 or section 4.2.2.12 Slovenia Yes - Frontrunner countries France Yes More details in D2.2 or 4.2.3.1 Germany Yes More details in section 4.2.3.2 Switzerland Yes - 40 The Netherlands Yes More details in section 4.2.3.4 and 6.e 4.2.1 HYPOP countries 4.2.1.1 Belgium As can be seen in D2.2, a regulation study was performed by HINICIO so as to consider the installation of a hydrogen refuelling station in the Francorchamps Campus of Technifutur. The list of directives and rules provided is shown in Table 8. Also, European Directives on safety are presented in Table 9. In this country, hydrogen does not have sectoral conditions yet and is therefore subject to specific conditions within the framework of the environmental permit, so it was concluded that the general approach for the permitting of a HRS would need a combination of specific risk assessed study and the application of the existing technical standards for both environmental and safety aspects. In Flanders, the technical standards are specified in the Vlarem II (section 5.16.9) and in Wallonia in the Walloon government decree: “les conditions sectorielles relatives aux installations de distribution d'hydrogène sous forme gazeuse destiné aux véhicules à moteur”. Table 8. International and European standards considered for the implementation of HRS in Belgium [1] Type of regulation Scope Reference Subject Description Directive Europe 2014/94/EU Alternative fuel infrastructure directive (AFID) Common directive to deploy alternative fuel infrastructure Standards International ISO/TS 19880-1 General requirements for refuelling station Technical specifications for public and private refuelling stations Europe EN 17127 General requirements for refuelling station European transposition of ISO/TS 19880-1 International ISO 14687-2 + ISO 19880-8 Quality conformity and hydrogen purity Quality specification for hydrogen use for mobility Europe EN 17268 Hydrogen purity European transposition of ISO 14687-2+ and ISO 19880-8 International ISO 17268 Recharging connectors Standards for the design, the security and the operations of refuelling connectors Sector standards International SAE J2601-1 SAE J2601-2 SAE J2601-3 SAE J2601-4 Refuelling protocols for: Light Duty vehicles High Duty vehicles Forklifts Slow refuelling Security and performance limits for refuelling stations (350 bar and 700 bar) 41 International SAE J2799 Communication between the vehicle and the refuelling station Description of infrared communication between the vehicle and the refuelling station (350 bar and 700 bar). This communication system must also correspond to the SAE J2601 standard. Table 9. European directives on safety for HRS in Belgium [1] Reference Subject Description 2012/18/UE SEVESO CE conformity which is guaranteed by the builder of the refuelling station IED-2010/75/EU Industrial emissions ATEX95-94/9/EC Explosive atmospheres The system is not subject to the ATEX directive since it will not work under explosive atmospheres ATEX137-99/92/EC MD-2006/42/EC Machines CE conformity which is guaranteed by the builder of the refuelling station PED-97/23/EC, TPED-1999/36/EC Pressurised equipment LVD-2006/95/EC Low voltages EMC-2004/108/EC Electromagnetic compatibilities 4.2.1.2 Italy To date, developing an HRS in Italy is subject to certain barriers and requirements summarised in Table 10. Table 10. Requirements and barriers from the industrial field, local urban planning and safety regulations affecting HRS in Italy [1] Hydrogen production for HRS The connection with hydrogen production and distribution can lead HRS to be considered as industrial facilities where inorganic chemical products are generated (barrier) Urban planning involving local authorities • land use planning and environmental protection of natural habitat (requirement and barrier); • connection to the electrical grid (requirement) • local noise emissions and acoustic regulations (barrier) Application of the prescriptive regulation for hydrogen production from electrolysis and for hydrogen refuelling stations (see Deliverable 2.1) When the two facilities are connected and installed on contiguous areas, strict safety prescriptions for industrial equipment, such as electrolysers, apply and safety distances can be difficult to satisfy (requirement/barrier) 48 4.2.2.10 Malta Malta does not have any official guidelines in place for the permit procedure for HRS nor a legal framework for the development of this technology2. 4.2.2.11 Romania Although law no. 237/2023 on the integration of hydrogen from renewable sources and with low carbon emissions in the industry and transport sectors, aims to establish measures for fuel suppliers and industrial hydrogen consumers, there are no official guidelines in place that cover the HRS permit procedure2. 4.2.2.12 Slovakia Reviewing the European Hydrogen Observatory, there are no official guidelines that cover HRS permit procedures. However, according to the same project mentioned in point 4.1.2.12, for the installation of HRS, the following would be required: • HRS environmental position on which the Ministry of Environment, which is the authority in charge, has already issued two positive statements; neither an environmental impact assessment for the HRS nor Natura 2000 impacts are required, but this will be reconfirmed as legislation evolves. • Urban-planning consent. As noted earlier, the same applies here as with electrolysers; HRS do not need to be built in industrial areas; they can also be developed elsewhere. 4.2.2.13 Slovenia There is an “Act on infrastructure for alternative fuels and the promotion of the transition to alternative fuels in transport” by way of an official guideline for HRS2. As mentioned in D2.21, the permitting procedures followed by the pilot projects related mainly to natural gas, rather than hydrogen. 4.2.3 Frontrunner countries 4.2.3.1 France For HRS, the legal approval process can be a bit of a mix between the approval process for a hydrogen production unit and a hydrogen storage unit. This depends on the technical characteristics of the HRS (whether it is onsite production or only with delivered hydrogen). The permit process depends on that. If hydrogen is delivered and stored at the HRS, the process can be made easier. If we make the hydrogen ourselves on site, that depends on what the administration decides. France has a specific regulation for hydrogen refuelling stations: the order of 22 October 2018. This made it possible to regulate HRS by means of general rules, so that this technology could be properly developed. This order also explained the specific safety distances depending on the flow rate of the HRS, which we talked about in Deliverable 2.1 12 . There is also the order of 8 December 2017, which is about the regulation of hydrogen as an energy source for road transport. This sets out the requirements for hydrogen as an alternative fuel. On top 12 https://www.hypop-project.eu/wp-content/uploads/2024/07/D2.1.pdf 49 of that, a guideline known as "Guide pour l’évaluation de la conformité et la certification des systèmes a hydrogène" had France Hydrogen and INERIS's input. As mentioned in section 4.1.3.1, the permitting framework is governed by ICPE, which regulates facilities based on their potential environmental and safety risks. So, for both the industrial and mobility sectors, the permit process is based on the potential danger that the project causes to the environment2. 4.2.3.2 Germany The pieces of legislation followed in Germany are shown below: • Building Code and Federal Land Use Ordinance. Both relate to land use planning for hydrogen production, storage and refuelling stations. • Protection from the Harmful Effects of Air Pollution, Noise, Vibration and Similar Processes on the Environment Act (Federal Emissions Control Act). • Ordinance on Permitting Facilities. This relates to the authorisation process for hydrogen production, storage and refuelling stations, as well as road planning. • Environmental Impact Assessment Act. This affects authorisation and safety requirements. • Dangerous Incidents Ordinance. This affects the production process and safety, as well as HRS. As mentioned in deliverable 2.2, the official guidelines 13 provide a flow chart that summarises the process, specifying the stakeholders involved: WHO (in grey), WHAT THEY DO (in blue) and WHAT IS NEEDED (in light blue). The main steps to follow1 are shown below and summarised in Figure 15: 1. Identify the authority responsible for issuing the permit (may vary depending on the municipality and the type of procedure), 2. Preliminary phase, where certain documents are provided to the identified authority, which contain the definition of the layout of the site planned for the installation, the preparation of draft construction documentation and the consultations with the building authority, 3. Authorities responsible for the various permits provide feedback, 4. Evaluation of the compiled documentation (this procedure can be either concentrated or nonconcentrated), 5. If the procedure is concentrated, the documentation is sent to a specific authority that evaluates it and the applicant only receives confirmation of the positive outcome of the authorisation procedure. If it is non-concentrated, the procedure is longer and validated in parallel by two authorities: a building authority and a supervisory authority. Then, the two authorities involved can issue the permits. 6. Once the permits have been approved, construction activities begin, which may involve inspection. 13 https://rcs.now-gmbh.de/wp-content/uploads/2023/11/Approval-guide-for-hydrogen-for-Germany.pdf 50 Figure 15. German guidelines as support for stakeholders. Layout of the stakeholder procedure (HRS <3 ton)1 Apart from that, hydrogen vehicles are also affected by the German Traffic Ordinance, which considers hydrogen in its section on. The hydrogen refuelling stations are affected by a standard known as “CMS 70 Regulation (Version 1/2020). Generation of green hydrogen 14 ”, which defines the requirements of green hydrogen production. 4.2.3.3 Switzerland Based on the findings from the construction of the first HRS in Switzerland, a guideline for the construction of HRS was produced and is known as “Guide to setting up hydrogen refuelling stations”, but it is no longer up to date2. 4.2.3.4 The Netherlands In the Netherlands, the responsible authority varies depending on the plant location. The permit procedure is followed according to the WABO (Wet Algemene Bepalingen Omgevingsrecht), which is the General Provisions for Environmental Law Act. The specific procedure for delivering hydrogen to vehicles and tools is the PGS 35, which is the guideline for the occupationally safe, environmentally safe and fire safety application of installations for delivering hydrogen in the Netherlands. The document includes testing periods and a practical maintenance schedule that can be seen in the guideline’s annex 15 . A diagram of the procedure for installing an HRS in the Netherlands is shown in Figure 16. More specific laws can be seen in more detail in Appendix A. Additional information on applied regulations. 14 https://www.tuvsud.com/it-it/-/media/global/pdf-files/brochures-and-infosheets/tuvsud-cms70standard-greenhydrogen-certification.pdf 15 https://content.publicatiereeksgevaarlijkestoffen.nl/documents/PGS35/PGS%2035%20voor%20website%20 ondertekend.pdf 51 Figure 16. HRS procedure in the Netherlands. Adapted from Hydrogen Delivery Installations PGS 35:201515 Following the guidelines15 for this country, the government bodies involved are: • For the Environmental Licensing Act (Wabo), the competent authority is the municipality. For companies which could cause more severe environmental pollution because their size, it is the provinces. In some cases, the Dutch Ministry of Infrastructure (for defence sites) and Environment or the Ministry of Economic Affairs (for mining activities and for oil gas extraction) may be the competent authority. • In terms of safety, the municipal and regional fire brigades will be integrated as part of the fire service. • The working conditions are supervised by the Dutch Ministry of Social Affairs and Employment. • Regarding the transport of hazardous substances, the Human Environment and Transport Inspectorate is in charge. 4.3 Residential sector Unfortunately, when searching for information on legislation in the residential sector, it was not possible to find any new information that was not already covered in Deliverable 2.21. The only update that can be offered relates to the Czech Republic, which states: as previously mentioned, there are no specific national or regional safety regulations for hydrogen projects in this country. However, following an amendment to the Czech Energy Act, hydrogen is now subject to the same legislative framework as natural gas12 for distribution through the pipeline network to customers. This update should facilitate the implementation of hydrogen, particularly with regard to mobility and residential applications, from a permitting point of view. Delivery station Shall comply with European regulations Transposed into Commodities Acts (warenwetbesluiten) When completed/com missioned Provided the CE marking By the manufacturer Indicates that all the relevant and applicable regulations are complied with Assembled a technical file To obtain a conformity assessment Manufacturer's signature Some parts of legislation require a test by a Notified Body Requirements or regulations laid down for the use of hazardous substances Established in European legislation or derived from it The PGS provides a description of how to meet legal and regulatory requirements Local legislation is also relevant Including the various permits required to construct the facility 52 5 Key elements to foster the hydrogen economy at the regional level In this section, we will start by discussing the steps set out in the guidelines developed by leading countries such as Switzerland (see section 5.1) and Germany (see section 5.2). Even if other permitting guidelines have been identified (for example for France and Netherlands), the Swiss and German cases have been taken as a reference due to their good structure and replicability in other countries. For the former, we will examine the projects that subsequently helped to develop Swiss guidelines. Regarding the latter, we will examine the steps set out in these guidelines for implementing a refuelling station in Germany. 5.1 Examples in industry that have been considered useful The guidelines developed in Switzerland, which were mentioned above, presented five projects implemented in that country. Although they have some legislative differences depending on the area in which they were implemented, the common contact authorities are those presented in Table 12. Table 12. Overall contact authorities found in Swiss guidelines [8] Depending on the municipality where they are located, some of the offices may have different names or be grouped under different names. Furthermore, depending on the location of the plant, the relevant authorities may be part of the canton or municipality. Each canton, however, will have its own building insurance. Finally, it should be clarified that some authorities will only be involved in certain locations. One of the H2 projects developed in Switzerland is the Gösgen project in the canton of Solothurn. In this case, responsibility for processing the various permits required for construction is divided Contact authorities •Environment Office (City/Canton) •Building Insurance (Canton) •Civil Engineering Office (City/Canton) •Water Office (Canton) •Fisheries Office (Canton) •Waste Management Office (City) •Forestry Office (Canton) •Labour Inspection (Canton) •Monument Conservation (Canton) •Office of Construction and Land Use Planning (City/Canton) •Mobility Office (Canton) •Office of Agriculture, Rural Development Sector and Soil Protection (Canton) •Energy Office (Canton) •City Hall •Building Manager (City) •Consumer Protection Office (Canton) •Fire Department (City) or other specific safety authorities (Canton) 53 between the Department of Construction and Justice. The latter is divided into an environmental office that, depending on the application, will refer it to one department or another. The Department of Economic Affairs is divided into the Office of Economic and Labour Affairs, which is responsible for approving plans and building insurance. A diagram of the permitting procedure for this project can be seen in Figure 17. Figure 17. Diagram for the Gösgen project in the Canton of Solothurn. Collected from [8] Anyway, a comparison of the projects described in these guides8 revealed that the steps they had in common are shown in the corresponding Figure 18. The process begins with the building permit procedure and the submission of a feasibility study, which clarifies the location of the project and any potential conflicts of interest relating to environmental conservation, distance or transport for users, among others. Following submission of the building application, the result of the study is obtained from the relevant public authorities. If the results are positive, the designated competent authority will proceed to issue the permit, concluding with the implementation or planning of the project. Point of Contact for the Authorities Department of Construction and Justice Environment Office (AfU) Coordination Department AfU Coordination Department of Water and Operational Water Protection Application for discharge from the Aare Canal, water protection permit Department of Hydraulic Engineering Granting of Regulation of Own Consumption Air/Noise Department Noise report Department of Economic Affairs Office of Economic and Labour Affairs, Working Conditions Division: Plan Approval Building insurance 54 Figure 18 Overview of the procedure in Switzerland based on [8] A diagram of the rest of the projects mentioned in these guidelines is shown in Appendix A. Additional information on applied regulations. 5.2 Examples in mobility that have been considered useful The same applies to Germany13, where the process begins by sending the applicant a site plan by email so that the approval process can begin. At this stage, it is important for the applicant to identify the authority responsible for beginning the approval process so that the documents can be prepared as a sample building application. Next, an initial consultation is held with the building authority and the labour inspectorate so that the applicant can present their pre-defined plan. After this consultation, the competent authorities inform the applicant of the documents with which the procedure should be continued. Opinions are now commissioned, requiring the following documents: • Opinion of the fire and explosion protection expert, including all relevant documents and expert opinions, • Construction drawing and other items from the architect, • An official site plan from the surveyor, • Written consent from the property owner, • The structural engineer’s calculations. Then, the inspection by ZÜS is carried out on the basis of the above. Moreover, if it is a “non-concentrated procedure” the document is checked by the building authority and the trade inspectorate and the processing time is three months from the date of receipt by both organisations. A statement from the specialist authorities may be requested by the trade inspectorate, which includes: Procedure for construction permit Preliminary clarification/Feasibility analysis Declaration of the principal authority Request for building Review and publication of the resolution Issuance of the permit •Canton/Municipality /Specific Authorities Implementation 55 • A fire brigade plan, • An independent fire and explosion protection expert opinion, • A fire brigade’s expert statement on the expert’s fire brigade plan. Based on these, a decision can then be made on the granting of the operating permit and building permit. If the document is approved, the building authority can issue the building permit (with site specification conditions) and the trade inspectorate can issue the operating permit independently of one another. However, if the procedure is “concentrated” all the documents have to be presented to the trade inspectorate, which forwards the documents to all relevant departments (including the building authority). Then, the applicant only receives a confirmation of receipt from the trade office. If the procedure is approved by the competent authorities, the implementation planning is initiated by the architect, who instructs the applicant to commission further site-specific expert opinions for the implementation planning. The expert opinions that are required are described Table 13. Table 13. Required documents when implementation planning has been initiated in the German guidelines. Collected from [13] Required document Expert in charge A subsoil report Building authority An assessment of the supporting structure The architect A test structural analysis report Structural engineer Then, the applicant prepares a building notification for initiating construction and a building inspection is carried out by the building authority, concluding the building permit phase. The applicant forwards the documents to the ZÜS (which is the approved monitoring body) for the installation certificate for inspection before the HRS is put into operation. The last step of the approval process is the submission of the test report (previously forwarded to the applicant by ZÜS) and the construction notification to the trade inspectorate. To conclude, the commissioning of the HRS can take place after these steps. Figure 19. Overview of the procedure in Germany based on [13] A sample construction application is submitted Submisison of a predefined plan Requirement for specific documentation Issuing permits •Building authority and trade inspectorate or •Only the trade inspectorate Approval and implementation of the HRS 56 Although it has been possible to see how many countries work in terms of developing hydrogen facilities (even when there was no specific framework for hydrogen), these projects need to be supported during their deployment. For the frontrunner countries, as is the case of Germany and Switzerland, we know, for example, how they develop procedures to install these facilities, and an overview of this is shown in Figure 18 and Figure 19. 57 6 HYPOP recommendations to deal with hydrogen project permits in the EU The purpose of this section is to provide recommendations supporting the overcoming of typical barriers identified in the HYPOP project. The main barrier is the lack of a hydrogen-specific legal framework in many of the countries covered by this deliverable. To tackle this, procedures can be drawn on lessons from past or completed projects. When no hydrogen norm exists, companies may follow general laws, supplemented by government-defined hydrogen requirements. Over time, general permitting procedures should be adapted and codified into a dedicated framework for hydrogen, with clear thresholds that distinguish permit routes by applications. A regulatory framework and an official permit pathway enabling project deployment can then be created. To facilitate the development of a hydrogen project, even when a country or region has no H2 specific regulatory framework, the common steps for obtaining permits observed across various countries currently rely on land use and spatial planning rules, building codes and environmental legislation. The following documents are the most relevant when installing a hydrogen facility (see Table 14). Table 14. Main requirements collected during Deliverable D4.3. Documents or aspects that could be required Building Environmental Land use • Pre-defined plan • Related to fire safety (fire and explosion protection) • Construction drawing • Official site plan • Structural engineer’s calculations • Environmental impact assessments (depending on the facility’s characteristics) • Laws related to water, nature, habitat protection, etc. • Written consent from the property owner • Accessibility • Availability of basic services (water, electricity, etc.) Others • Risks assessments • Noise protection The Figure 20 shows a diagram of the administrative framework proposed for hydrogen in “Good legislative practices for the green hydrogen industry” where an administrative framework is proposed which requires licenses to be obtained from the government to produce and distribute hydrogen16. 64 9 Appendix A. Additional information on applied regulations a. CROATIA Figure 24. Main regulations applied in Croatia to install an Energy Park. Adapted from [3] •Noise Protection Law (Official Gazette 30/09,55/13,153/13,41/16,114/18) and 14/21) •Air Protection Act (OG 127/19 and 57/22) •Regulation on levels of pollutants in the air (Official Gazette 117/12,84/17,77/20) •Environmental Protection Law (Official Gazette 80/13, Art. 202) •Act on Climate Change and Ozone Layer Protection (OG 127/19) •Regulation on the assessment of the impact of interventions on the environment (Official State Gazette 61/14 and 03/17) •Waste Management Ordinance (Official Gazette 106/22) •Climate Change Adaptation Strategy in the Republic of Croatia for the Period up to 2040 with a View to 2070 (NN 46/20) •Low-Carbon Development Strategy of the Republic of Croatia until 2030 with a View to 2050 (Official Gazette 63/21) •Seventh National Report and Third Biennial Report of the Republic of Croatia under the United Nations Framework Convention on Climate Change (UNFCCC) Environment •Construction Law (Official Gazette 153/13, Official Gazette 78/15,12/18, and 118/18). •Spatial Plan of Brod-Posavina County ("Official Gazette of Brod-Posavina County") No. 4/01, 6/05,11/08,14/08 - consolidated text, 5/10, 9/12,39/20,45/20 - consolidated text, 33/23. and 1/24 - consolidated text) •Territorial Development Plan of the Municipality of Sibinj ("Official Gazette of BrodPosavina County" No. 8/03, 7/04 - correction, 2/07 - credible interpretation, 17/07, 27/14 - harmonization with By Law, 27/16 and 2/17 - consolidated text) •Urban Development Plan of the Slobodnica Small Business Zone, Phase II ("Official Gazette of Brod-Posavina County" No.29/07) Building •Agricultural Land Law (Official Gazette 20/18,115/18,98/19, and 57/22) Land use 65 b. POLAND Figure 25. Main regulation for HRS in Poland. Adapted from [1] Regulation for the construction and design of hydrogen refuelling stations The Act of July 7, 1994. - Construction Law The Act of October 3, 2008 on providing information about the environment and its protection, public participation in environmental protection and environmental impact assessments The Law of March 27, 2003 on spatial planning and development The Law of December 21, 2000 on technical supervision The Law of August 19, 2011 on the transportation of dangerous goods The Regulation of the Minister of Infrastructure of April 12, 2002 on the technical conditions to be met by buildings and their location The Regulation of the Minister of Transport and Maritime Economy of March 2, 1999 on the technical conditions to be met by public roads and their location The Regulation of the Minister of Infrastructure of January 16, 2002 on technical and construction regulations for toll highways Regulation of the Minister of Economy, Labor and Social Policy of July 9, 2003 on the technical conditions of technical supervision in the operation of certain pressure equipment The Regulation of the Minister of Development dated July 11, 2016 on requirements for pressure equipment and pressure equipment assemblies The Ordinance of the Council of Ministers of December 7, 2012 on the types of technical equipment subject to technical supervision 66 c. LITHUANIA Figure 26 Process for obtaining permits applied in Lithuania based on [11, 17 ] 17 https://data.kurklt.lt/wp-content/uploads/2023/04/6-gaire.-Rekomendacijos.pdf •Law on Alternative Fuels of the Republic of Lithuania •Rules for the Installation and Operation of Gas Stations of the Republic of Lithuania, Order of the Ministry of Energy of the Republic of Lithuania on the Approval of the Rules for the Installation and Operation of Gas Stations •Resolution of the Ministry of Energy of the Republic of Lithuania No 1-81 of 26 April 2024 "On Approval of Guidelines for Hydrogen Development in Lithuania 2024-2050" •Resolution of the Ministry of Transport and Communications of the Republic of Lithuania No 3-105 of 10 March 2023 "On the Approval of the Guidelines for the Development of the Hydrogen Refueling Infrastructure and the Promotion of the Use of HydrogenPowered Road Vehicles in Lithuania" •Law of the Republic of Lithuania on Special Land Use Conditions •Law of the Republic of Lithuania on Natural Gas •Law of the Republic of Lithuania on Construction •Order of the Ministry of the Environment of the Republic of Lithuania on the approval of the environmental (except air) protection requirements for the design, construction and operation of liquid fuel filling stations (LAND 1-2003) •Order of the Ministry of the Environment of the Republic of Lithuania on the technical regulation on construction, art. 1.01.03:2017 “Classification of Constructions” •Law on Roads of the Republic of Lithuania About HRS •Law on Special Conditions of Land Use of the Republic of Lithuania Land •Order of the Minister of Environment of the Republic of Lithuania No D1-878 of 12 December 2016 Construction •Law on Environmental Impact Assessment of Planned Economic Activities of the Republic of Lithuania •Order of the Ministry of Health of the Republic of Lithuania No V-362 of 10 May 2007 •Order of the Ministry of Health of the Republic of Lithuania No V-604 of 13 June 2011 •Order of the Ministry of the Environment of the Republic of Lithuania No D1-528 of 15 July 2013 Environment •Order No 4-791 of the Ministry of Economy of the Republic of Lithuania of 11 December 2015 •Order of the Head of the Lithuanian Metrology Inspectorate No 11V-24 of 31 March 2016 •Order of the Ministry of Economy of the Republic of Lithuania No 4-523 of 1 August 2014 •Order of the Ministry of the Environment of the Republic of Lithuania No D1-546 of 16 September 2009 •Law on Energy of the Republic of Lithuania •Law on Metrology of the Republic of Lithuania Others 67 d. SWITZERLAND Figure 27 Kubel project in the canton of St. Gallen [8] Points of contact for the authorities Department of Land Use Planning, Environment and Construction AREG (Territorial Development and Geoinformation Office, Canton) Civil Engineering Office (City) Environment Office (City and Canton) Office for Water and Energy (Canton) Fisheries Office (Canton) Building Permit Office (City) Waste Management Office (City) Directorate of Institutions, Agriculture and Forestry Forestry Office Department of Economic Affairs and Vocational Training Labour Inspection Conservation of Monuments Department of Security, Justice and Sports Cantonal Building Insurance TÜV Süd (Fire Protection, Safety, etc.) 68 Figure 28 Schiffenen project in the canton of Fribourg [8] Point of contact for the authorities Preliminary application and construction permit application, Cantonal section of the municipality Analysis and recommendation for the attention of the Cantonal Office - Office of Construction and Land Use Planning (BRPA) - The following cantonal authorities participated: Directorate of Land Use Planning, Environmen t and Constructio n (RUBD) Office of Construction and Land Use Planning Civil Engineering Office Mobility Office Office of the Environment Acoustic Protection Section Water Section Directorate of Institutions, Agriculture and Forestry (ILFD) Office of Forests and Nature, Natural Hazards Commission Forest District, Wildlife and Hunting, Aquatic Fauna and Fishing, Nature and Landscape Office of Agriculture, Rural Development Sector, Soil Protection Directorate of Economic Affairs and Vocational Training (VWBD) Energy Office Office for the Labor Market (Security Concept) Directorate of Security, Justice and Sports (SJSD) KGV, Cantonal Building Insurance, Fire Protection, Risk Assessment AMA, Office for the Labour Market 69 Figure 29 Birsfelden project in the canton of Basel-Landschaft [8] Contact authorities / Specialised departments Cantonal authorities Construction Inspection (BIT) Civil Engineering Office Office for Environment and Energy Labour Inspection Landmarks Preservation Office Municipality Mayor Building Manager TISG (Support for the integration projects of the St. Gallen Association) Preliminary review 70 Figure 30 Wildegg-Brugg project in the canton of Aargau [8] Special agreements are required for the construction of the H2 plant according to construction legislation The project is subject to the Major Accident Ordinance An incident report was prepared Approval procedure Multiple building permit applications are required Construction permit application procedure Applications to the Federal Inspection of High Voltage Installations Feasibility analysis/preliminary clarification Preliminary study Preliminary project/construction project/publication project/presentation project 71 Table 15. Description of applicable procedures. Collected from [8] Permits for the construction of the plant Building Permit Cantonal legislation It is presented in the municipality where the project is located Planning Permission Federal Labour Law Authority: Cantonal Control Body (Cantonal Labour Inspectorate) Planning Permit for Electrical Installations Federal Electricity Law Operating license Federal Labour Law Authority: Cantonal Authority Building approval Electrical Components Notify to: Federal Inspection of Heavy Current Facilities (ESTI) Prove system compliance Product Safety Act (PrSG) Certifies: Cantonal Control Bodies Commissioning of pressure equipment Ordinance on the Use of Pressure Equipment (DGVV) Swiss Occupational Health and Safety Insurance (SUVA) Equipment inspection Boiler Inspection, a specialised department of the Swiss Association of Technical Inspections (SVTI) When the works are completed Notify the competent authorities to accept the different components of the building and facilities for which permission has been requested Equipment compliance testing Apply to: Manufacturer Application for operating permit before starting production Issued by the cantonal authority Copy of conformity of the notification of the pressure equipment and the operating permit ETSI CE certification of the entire system Applicable regulations DGV SR 930.114 National regulations Cantonal regulations DGV SR 930.11 Ordinance on Low Voltage Electrical Products NEV SR 734.26 Ordinance on electromagnetic compatibility VEMV SR 734.5 MaschV Machinery Safety Ordinance SR 819.14 Regulations on Protective Equipment and Systems for Use in Potentially Explosive Atmospheres VGSEB SR 734.6 Areas Compliance Body CE approved body 72 Table 16 Expert opinions for plant approvals. Collected from [8] Standard assessment The buildings must correspond to the intended use of the area and be on urbanised land Environmental assessment Competent authorities Federal Office for the Environment (FOEN) Applicable regulations Environmental Protection Act Rules relating to: Nature and heritage conservation; Landscape protection; Water protection; Forest conservation; Hunting; Fishing; Genetic engineering If not subject to an EIA Simple Environmental Statement Procedure regulated by Chapter 3 of the Environmental Protection Act and the Environmental Impact Assessment Ordinance Serious accident preparedness Applicable regulations Major Accident Regulations (StFV) Serious Accidents Ordinance Implementing authority - Swiss Federal Office of Energy (SFOE) Supervisory Authority for Implementation - FOEN Risk assessment Applicable regulations Labour Law Accident Prevention Ordinance Ordinance on the Protection of the Safety and Health of Employees When Using Pressure Equipment Be part of Building and Facility Use Protection Act (PGV-ArG) Noise protection Applicable regulations Noise Protection Ordinance (LSV) Fire protection Applicable regulations VKF Fire Protection Regulations Authority: Association of Cantonal Fire Insurers Explosion protection Be part of PGV-ArG Applicable regulations VUV (German Ordinance on the Use of Buildings and Facilities) Refers to the ATEX Works Directive 1999/92/EC Legal procedures specification tool Suva Brochure 2153-d, "Explosion Protection: Principles, Minimum Requirements and Zones" 73 e. THE NETHERLANDS Figure 31. Main regulations applied in the Netherlands to install HRS. Adapted from [15] •Environmental Licensing (General Provisions) Act (Wet algemene bepalingen omgevingsrecht –Wabo) •Best Available Technology (BAT) •Activities Decree (Activiteitenbesluit) General •Pressure Equipment (Commodities Act) Decree (Warenwetbesluit drukapparatuur –WBDA) •Legislation on explosive atmospheres (ATEX 95) Requirements for technical integrity •Legislation on explosive atmospheres (ATEX 137) •Pressure Equipment (Commodities Act) Decree •Risk inventory and evaluation (Risico inventarisatie en evaluatie –RI&E) •Working Conditions Act (Arbeidsomstandighedenwet) •In-house fire service (Bedrijfsbrandweer) •National and international standards for operation Operation •Building Decree (Bouwbesluit) •External Safety (Establishments) Decree (Besluit externe veiligheid inrichtingen –Bevi) Requirements for spatial context •Transport of hazardous substances act (Wet vervoer gevaarlijke stoffen) •Ships Act (Schepenwet) •Regulation on transport of hazardous substances by land (Regeling vervoer over land van gevaarlijke stoffen –VLG) Transport