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European Association for Storage of Energy

EASE

The European Association for Storage of Energy promotes energy storage technologies to improve flexibility and support Europe's transition to clean energy.

Lobbying Activity

Meeting with Valdis Dombrovskis (Commissioner) and

4 Dec 2025 · Industrial Accelerator Act

Meeting with Jens Geier (Member of the European Parliament)

25 Nov 2025 · Exchange on Energy Storage

Meeting with Michael Bloss (Member of the European Parliament) and E-MOBILITY EUROPE and

14 Oct 2025 · Clean Industrial Deal Implementation

EASE urges energy storage focus in EU electrification plan

9 Oct 2025
Topic — The EU Electrification Action Plan aims to shift energy demand from fossil fuels to electricity.
Message — EASE requests removing double taxation and tailoring grid fees for storage projects. They advocate for setting storage deployment targets and unlocking revenue from flexibility services.123
Why — Storage would lower industrial operational costs and create new revenue from grid flexibility services.45
Impact — Fossil fuel suppliers lose market share as industry switches to storage-supported electrified heating.67
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European energy storage association urges prioritising thermal storage technologies

9 Oct 2025
Topic — A strategy to accelerate the decarbonisation of heating and cooling across the EU.
Message — Strengthen the role of thermal storage by removing double taxation and permitting barriers. Integrate storage goals into national plans and improve investment frameworks for smaller companies.123
Why — This would increase demand for storage technologies and improve member profitability.45
Impact — Natural gas suppliers lose market share as industries transition to stored renewables.67
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Energy storage group demands central role in EU grid plan

5 Aug 2025
Topic — The European Commission is proposing measures to modernize and expand EU energy infrastructure.
Message — Transmission operators should be encouraged to fully consider the multi-service capabilities of storage systems. EASE calls for clearer guidance and obligations on flexibility assessments in planning processes.12
Why — Storage providers would benefit from being treated as a standard resource for grid services.34
Impact — Conventional asset owners may lose out as flexibility solutions replace traditional grid reinforcements.5
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Meeting with Kurt Vandenberghe (Director-General Climate Action) and Transport and Environment (European Federation for Transport and Environment) and

13 May 2025 · Clean Industrial Deal to deliver a Joint Decarbonisation and Competitiveness Roadmap

Meeting with Stefan Leiner (Head of Unit Environment)

15 Apr 2025 · Presentation of the Battery Energy Storage System (BESS) Safety Best Practices Guideline developed by EASE

Meeting with Angelika Winzig (Member of the European Parliament)

13 Mar 2025 · Meeting with representatives of the European Association for Storage of Energy (EASE)

Meeting with Anna Stürgkh (Member of the European Parliament, Rapporteur) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V.

5 Mar 2025 · INI Report on Grids

Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

The European Association for Storage of Energy (EASE) welcomes the opportunity to provide feedback on the draft Implementing Act for non-price criteria in renewable energy auctions. Please consult the attached position paper to access EASE's feedback in full.
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Meeting with Peteris Ustubs (Director Directorate-General for International Partnerships)

17 Feb 2025 · Meeting with the European Association for Storage of Energy - EASE a.i.s.b.l.

Meeting with Lukasz Kolinski (Director Energy)

14 Feb 2025 · Energy Storage for Green Transition & System Integration

Meeting with Anne Katherina Weidenbach (Cabinet of Commissioner Dan Jørgensen), Anne-Maud Orlinski (Cabinet of Commissioner Dan Jørgensen)

3 Feb 2025 · Role of storage on energy prices and competitiveness. Clean Industrial Deal and Affordable Energy Action Plan.

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

22 Jan 2025 · Discussion on the potential and challenges of the energy storage value chain.

EASE urges EU energy storage Action Plan

26 Nov 2024
Topic — An evaluation of the performance of the EU's energy security architecture.
Message — EASE requests a Commission Action Plan on energy storage with clear targets. They advocate for placing storage at the centre of electricity risk-preparedness. Harmonised policies and market designs are also sought to encourage infrastructure investment.123
Why — This would create strong investment signals and accelerate deployment of storage technologies.4
Impact — Polluting gas power plants and fossil fuel providers lose their market position.56
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Meeting with Bruno Tobback (Member of the European Parliament)

19 Nov 2024 · The role of energy storage in the European energy landscape and Green Deal

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

30 Oct 2024 · Batteries, Energy grid, energy congestion

Meeting with Benedetta Scuderi (Member of the European Parliament) and ENEL SpA and Energy Storage Coalition

3 Oct 2024 · Energy

Meeting with Barry Andrews (Member of the European Parliament)

3 Oct 2024 · Energy Storage

Meeting with Bart Groothuis (Member of the European Parliament)

26 Sept 2024 · Energy storage

Meeting with Giorgio Gori (Member of the European Parliament) and Euroheat and Power and

18 Sept 2024 · Presentation of priorities

Meeting with Michael Bloss (Member of the European Parliament) and European Heat Pump Association

18 Sept 2024 · Austausch Industriepolitik

Meeting with Ditte Juul-Joergensen (Director-General Energy) and BUSINESSEUROPE and

22 Feb 2024 · Energy market

Energy storage association backs ambitious 90% climate reduction target

23 Jun 2023
Topic — The European Commission is seeking feedback on setting an EU-wide 2040 climate target.
Message — EASE supports the highest-ambition climate targets for 2040, exceeding a 90% emissions reduction. They emphasize that these targets must be rooted in scientific evidence and thorough impact assessments.12
Why — Ambitious targets would attract necessary investments for the deployment of energy storage solutions.3
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Meeting with Ditte Juul-Joergensen (Director-General Energy) and Bureau Européen des Unions de Consommateurs and

20 Jan 2023 · U.S.-EU Task Force: Best practices in Energy Savings and Flexibility Other participants: Cleantech-Cluster Energy, ELVIA, EU DSO Entity, California Energy Commission, ASE, AEE, ComEd, Octopus Energy, OPower, Uplight

Meeting with Claudia Gamon (Member of the European Parliament)

30 Jun 2022 · Speaker at panel discussion on energy storage

Meeting with Aleksandra Tomczak (Cabinet of Executive Vice-President Frans Timmermans), Sarah Nelen (Cabinet of Executive Vice-President Frans Timmermans) and

28 Apr 2022 · EU’s security of energy supply

Response to Revision of EU rules on Gas

13 Apr 2022

EASE – The European Association for Storage of Energy welcomes the proposal for the Hydrogen and Decarbonised Gas Regulation. This Regulation is fundamental for the clean energy transition. Yet, the role of renewable and low-carbon gas in energy storage solutions and technologies is not sufficiently acknowledged, which may hinder the security of supply efforts and lead to legal uncertainty. First, EASE would like to stress that the current definitions, especially in the context of energy storage, are missing or not precise enough. Power-to-Gas, renewable hydrogen, and flexibility are not defined. Concerning certification, EASE believes that the methodology for the low carbon hydrogen threshold should be defined as soon as possible. The details are mentioned in the feedback on the Directive. The Regulation sees renewable and low-carbon gases as key to achieving security of supply. Therefore, the complementarity of Regulation’s Articles 60 and 67 is deemed to be functional. However, EASE believes more could be done for the security of supply in the Package. The Regulation should further recognise energy storage as a key flexibility source and enable lower energy prices. EASE suggests a further discussion on the topics such as energy shifting, flexibility, and energy storage from the security of supply perspective. Furthermore, to prevent future gas price spikes, it is necessary to develop energy storage solutions to achieve long-term, seasonal, and strategic flexibility while reducing our reliance on fossil fuels. EASE welcomes incentivising renewable and low-carbon gases through tariff reduction, as proposed by Articles 15 and 16 of the Regulation. In particular, 75% tariff reduction on entry/exit points of storage facilities in Article 16 (1) point b is positive. However, some doubts about its impact and practices remain present and should be addressed. Grid tariffs should recognise the benefits of energy storage to the grid, and transparency should be ensured. Furthermore, the avoidance of cross-subsidies, discussed in Articles 12 and 15, appears positive. Regarding ENNOH, creating an entity specifically focused on hydrogen might be optimistic considering the distinctive tasks of gas and hydrogen network operators. At the moment, it is unclear how its work will unfold. Meanwhile, EASE would suggest enhancing ACER’s role in overseeing the network planning process, not merely offering its opinion. Similarly, in Articles 24 and 46, a provision ensuring that ENNOH will integrate the ACER recommendations on the draft Union-wide network development plan submitted by ENNOH should present. EASE believes that blending cannot be the ultimate solution. At the same time, it creates technical constraints and additional costs at injection, exchange of existing valves and sensors across the transport pipes, and end-use. However, EASE acknowledges that the blending may bring opportunities to the market in the short term by contributing to the deployment of hydrogen. Therefore, EASE is not against the requirement for transmission system operators to accept the gas flow with a hydrogen content of up to 5% by volume, as described in Article 20. However, the industry should keep in mind that blending should phase out in the market not far future. Meanwhile, extending pure hydrogen deployment for the essential industry should prevail in the discussion to contribute to reaching the target. To conclude, EASE believes that ensuring flexibility in the energy market by transparently and efficiently introducing renewable and low-carbon gases is the key to the energy transition. Many of the provisions go in the right direction; several Articles need further details; and the Regulation needs to stress the role of energy storage and power-to-gas throughout the text.
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Response to Revision of EU rules on Gas

12 Apr 2022

EASE – The European Association for Storage of Energy welcomes the proposal for the Hydrogen and Decarbonised Gas package. The Directive is fundamental for the clean energy transition. Yet, renewable and low-carbon gases’ role in energy storage solutions and technologies is not sufficiently acknowledged. Similar to the Regulation, EASE would like to stress that the definitions, especially in terms of energy storage, are missing or not precise enough in the Directive. For example, Power-to-Gas, renewable hydrogen, and flexibility are not defined. EASE would suggest Article 2 include their definitions. Concerning certification, both the default value and exact calculation method for the low-carbon hydrogen threshold (-70% GHG emission) are absent. Furthermore, EASE is concerned with the uncertainty derived from the proposal defining the 70% reduction via delegated act, especially with its deadline, set at the end of 2024. Hence, EASE suggests the methodology be defined as soon as possible. Besides, as mass balance imposes physical tracking of molecules from injection to withdrawal from the gas grid, linking the certification of renewable and low-carbon gases with the mass balancing system appears impractical. The Directive sees renewable and low-carbon gases as key to achieving security of supply. This is positive, but it should be better recognised that energy storage is a key flexibility source, enabling lower energy prices. EASE suggests a further discussion on the topics such as energy shifting, flexibility, and energy storage from the security of supply perspective. On vertical unbundling, EASE welcomes that hydrogen production and supply activities are seen as market-based, and the unbundling is enshrined in the Directive’s Articles 54 and 62. However, the ITO model should not be phased out for hydrogen by 2030: this would preclude TSOs to be involved in long-term perspective infrastructure development (e.g. refurbishing their existing methane pipelines), creating inefficiencies. Regarding cross-subsidies, EASE welcomes the position that they should be avoided. Furthermore, preventing financial transfers among different RAB (Regulated Asset Base) should remain a key pillar of EU legislation. Any exception to these principles should be limited in scope and adequately monitored by regulators. EASE welcomes the introduction of sector integration-related provisions between gas and electricity within the package. But Power-to-Gas is a key not only for integration with the electricity system but also, e.g., for the heat one. Therefore, addressing flexibility in Article 51 would be an ideal example. Additionally, EASE supports the proposal for a joint scenario framework to be considered when drafting national ten-year network development plans. EASE believes it is vital to plan infrastructures whilst considering system efficiency and energy optimisation regarding the repurposing and new infrastructure for hydrogen. However, the proposal might not sufficiently ensure economic efficiency. For instance, ‘repurposing’ of infrastructure can be further elaborated in Article 52 to prioritise using existing facilities instead of building new infrastructure and avoid stranded assets. EASE supports the package in strengthening active customers and citizen energy communities in the renewable and low-carbon gases market, which may increase customers. To conclude, EASE believes ensuring flexibility and energy shifting in the energy market by introducing renewable and low-carbon energy is vital to the energy transition. Many provisions go in the right direction, but many need further details. The package, in general, needs to emphasise the role of energy storage and power-to-gas as the provider of energy flexibility throughout the text.
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Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

12 Apr 2022

EASE - The European Association for Storage of Energy believes that removing barriers to the permitting and PPAs issues is absolutely essential for decarbonisation, clean energy transition, and energy security. To achieve more efficient permitting procedures, EASE recommends the following. Firstly, EASE recognises the need for suitable permitting procedures for flexibility and options for flexible connection agreements for energy storage. Additionally, prioritisation of interconnection for batteries should be considered. EASE also acknowledges that many EU Member States’ authorities do not have nationally harmonised permitting processes for energy storage. Therefore, EU-wide minimum standards, e.g., safety and first safety to prevent the fire risk of batteries, should be established. Secondly, in terms of legislation, EASE found that several Member States do not have a specific categorisation and permitting regime for either standalone or co-located storage exists. Therefore, sharing the harmonised categorisation for energy storage among the Member States is essential. Thirdly, an accurate and accessible guideline for permitting is necessary. Based on the proper definition and categorisation, the local authority should provide a permitting guide. EASE suggests cooperation between European and national governments to set up a guideline with details to stimulate incoming newcomers in the industry. It is because that unclarity on procedures/contact point often causes difficulties, e.g., shared permitting responsibility between regional/national authorities. In addition, a specific guideline and priority for co-located renewable+storage assets could improve their system supporting capability. Hence EASE recommends a streamlined process for permitting and connecting storage to a renewable plant, which already has received permitting in the past, to speed up the hybridisation process. In practice, better training for government staff is crucial. The key barriers are the delay derived from the understaffed local authorities and national/regional government staff without sufficient knowledge on permitting new storage technologies. Therefore, national government should avoid overlapping competencies between government bodies. Moreover, all of the procedures should be shortened and digitalised. Current required documents and fees for the permitting are burdensome. A simplified permitting procedure could apply to Europe-bases/sourced BESS projects to support the growth of the European storage industry and its supply chain. Besides, permitting should not be blocked while new legislation is elaborated. As new legislation on energy storage is under discussion, some legal uncertainty/permitting processes are fully blocked until a new law is launched, e.g., Greek law 4819/2021. Such decisions discriminate against storage technologies by placing a competitive disadvantage impacting investors' confidence in the markets. Regarding PPAs, EASE strongly advocates for the recognition of hybrid (RES + storage) PPAs in the EU legislation to allow the Member States to set up enabling regulatory, administrative, and fiscal frameworks (including a proper framework for state guarantees) for: 1) PPAs for co-located storage facilities (that allow providing renewable energy for an extended period of time), 2) corporate PPAs providing 24/7 RES energy, and 3) private wire PPAs with storage. Long-term contracts (10+ years) should be encouraged. Lastly, EASE believes all the mentioned changes shall be based on the solid and steady political willingness for active renewable deployment, especially on energy storage, at the European and the national level. Moreover, EASE suggests an initiative under the REPowerEU package focusing on flexibility assets, including an emphasis on renewable co-located assets to ensure grid-friendly integration of those additional renewable assets and prevent renewable energy curtailment.
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Response to Revision of the Energy Performance of Buildings Directive 2010/31/EU

31 Mar 2022

Energy storage solutions are paramount for achieving the goals set by the European Commission in the revised directive, as key enablers of energy efficiency and grid flexibility. Furthermore, the ambitious targets for the deployment of private charging infrastructure will increasingly require the deployment of energy storage solutions. EASE welcomes the increased ambition for improving the energy performance of the European Union's building stock. However, despite the benefits they provide, the focus on energy storage technologies remains limited. For full feedback, see attached file.
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Meeting with Mikuláš Peksa (Member of the European Parliament)

11 Mar 2022 · Renewable Energy Directive proposal

Response to Delegated Act on cross-border projects in the field of renewable energy

15 Nov 2021

Regulation (EU) 2021/1153, the recast of the Connecting Europe Facility regulation, sets out ambitious plans to support the roll-out of cross-border projects in the field of renewable energy and promote cooperation between Member States. The regulation correctly argues that renewable energy sources can be better integrated with the use of energy storage facilities with the aim to contribute to the Union’s long-term decarbonisation strategy. As more variable renewable energy is connected to the grid as a whole, a wide range of storage technologies, differing in scale, will need to be deployed in order to best maintain a steady and reliable trans-European network. Cross-border projects are defined as enabling the cost-effective deployment of renewable energy in the Union and as contributing to the strategic uptake of innovative technologies concerning renewable energy – criteria that energy storage technologies meet on their own terms. A non-exhaustive list covers a range of renewable energy generation technologies, their connection to the grid, storage, and conversion facilities, as being eligible. Beyond this, the action is not limited to electricity, as other energy carriers are covered along with sector coupling through the means of storage. With this in mind, it is unclear why the draft delegated act now explicitly forbids stand-alone storage technologies and only permits the use of storage as part of a hybrid project, coupled with renewable energy generation. Storage facilities are now only eligible if they are “ancillary to a renewables generation facility”, where “projects should always include a renewables generation facility as an integral part of the project”. The reason stated in Recital 14 is that this is required to contribute to the EU 2030 renewable energy target. Not only is the 32% target out of date, with a likely 40% soon to be official, but it neglects the role storage will play, decoupled from direct RES generation, to help integrate these higher levels of renewable energy sources. When aggregated, large and small-scale variable renewables, in a Member State, can have significant cross-border effects on energy flow. Germany’s Energiewende, driven by small-scale renewables, proves this, as the Czech Republic and Poland install phase-shift transformers at the border to manage new energy overflows. If the aims of the delegated act are to be taken as the starting point, then large-scale stand-alone storage technologies need to be permitted in order to contribute to the EU 2030 renewables target, by aiding the further integration of renewables in Member States and managing cross-border energy flows.
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Response to Modernising the EU’s batteries legislation

28 Feb 2021

EASE welcomes the proposal for the Batteries Regulation: although several criticalities are present, it is a step forward to tackle several of the barriers that currently hinder the battery market. First, EASE would like to underline that the current classifications and definitions, especially in the context of stationary storage, may need further clarification. For example, there is a weight limit of 5 kg to differentiate portable from industrial batteries. EASE would like further details as several industrial batteries can be well below 5 kg. The carbon footprint calculation is a complex topic that needs appropriate discussion between policymakers and industry. It is hard to assess to what extent the Carbon Footprint calculation provisions will have a positive effect: without a proper methodology, it may be ineffective at delivering a correct picture of batteries' environmental sustainability. On the topic of performance and durability, EASE does not see the need to tackle the issue through a Regulation. The introduction of specific provisions through a regulation may hamper innovation and fragment knowledge. Specific customers have specific requests for specific battery solutions. Another provision that may lead to negative consequences is mandatory minimum shares of recovered material. Such provision would not improve the efficient use of raw and recycled materials. Not only there would be considerable difficulties related to determining the percentages of materials coming from batteries vis-a-vis the share of newly produced materials; it would also make the recycling process more burdensome. EASE welcomes the introduction of ambitious recycling efficiency and collection targets. Still, it may be important to underline some challenges for manufacturers: if materials are cheap, abundant and environmentally friendly, recycled batteries have no value and therefore recycling is a pure cost. This hinders competition and innovation. Policymakers should support the development of full recycling supply chains for different battery technologies. EASE also welcomes provisions related to repurposing of batteries /second life – but would like to suggest that additional relevant data to realise a prognosis on its second-life purpose, e.g. the chronic of first life utilisation is compulsory, may be needed. Regarding provisions on critical raw materials, such as due diligence, they are key to ensure environmental and social sustainability across the battery value chain. The legislation would also require batteries to rely on a battery management system; but this is not needed for all battery technologies. The current proposal would lead to an unnecessary expenditure of materials and resources, leading to waste. Regarding labelling, the Regulation proposal requires a significant amount of information, while also relying on different systems (QR Code, battery passport, printings). This appears to lead to overlapping. On the battery passport, the administrative burden required for batteries information seems to be excessive. Unfortunately, EASE believes that the norms on hazardous substances in the proposed Batteries Regulation may overlap with the existing norms of the REACH Regulation. Hazardous substances should be regulated only in the latter piece of legislation. Finally, for standards, it is paramount that standardisation organisations play a key role in their development. Importantly, EASE would like to highlight the persistence of a mismatch between the proposed regulation and the related Request for Standardisation. To conclude, creating a level-playing field for batteries is key. Some Proposal provisions go in this sense - e.g., the recognition that different types of batteries are needed. In other articles, vice versa, the focus seemed to lie on specific battery solutions, e.g. the ones currently leading the market, therefore not adopting a technology-neutral approach, with the risk of hampering innovation and com
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Response to Revision of the guidelines for trans-European Energy infrastructure

5 Feb 2021

EASE welcomes the new proposal for the new TEN-E Regulation: it is a step forward, a piece of legislation more in line with the European Union’s climate objectives, although criticalities are still present. Firstly, EASE is glad to see that the role of flexibility as a tool to improve infrastructure planning for energy system integration is considered, and that the idea of involving users “in the management of their energy usage” as criteria for smart electricity grid projects is present. Still, additional focus on flexibility solutions – in particular energy storage – is needed. The reorganisation of the priority corridors excluding natural gas from the available corridors’ categories is positive; and regarding Projects of Common Interest, EASE welcomes the fact that sustainability criteria are now present for mutual interest projects. But it must be underlined the risk that fossil fuels projects may still de facto be selected. This should be avoided: it should be clarified that pipelines are supported only in the case they transport renewable and low-carbon gases. In addition, EASE believes the lack of introduction of specific PCI categories for market-based tools (i.e. non-network related PCI flexibility and storage) is a missed opportunity. On the other hand, the focus on small(er) scale project is key recognition of the importance of different solutions for the energy system. It is surprising the absence of a synergy plan with the TEN-T: this may be a missed opportunity, especially in the context of Alternative Fuels Infrastructure. Regarding governance matters, the decision to further empower ACER is positive. EASE approves ACER being given additional tasks, such as developing framework guidelines for Scenario Development. However, there also may be a further need of a joint planning approach for gas and electricity: this is key in the context of system integration. Looking at the CBA methodology developed by the ENTSOs, the additional power given to ACER is a positive change: still, ACER should be able to approve the methodology and issue appropriate, binding guidelines. Similarly, EASE also believes further details on how to appropriately empower stakeholders and achieve accountability may be needed. On the extensive consultation that ENTSO-E and ENTSO-G should conduct, it is unclear the reason behind only hydrogen stakeholders being mentioned. Moreover, in general, stakeholders should be more comprehensively consulted, being appropriately requested to provide inputs on ENTSO’s CBA Methodology. In general, some elements may need clarification. EASE positively assesses the inclusion of smart grids in the priority thematic areas. However, the practical consequences of these changes are unclear. Similarly, it is also unclear why specific objectives for hydrogen and offshore renewable energy are present, e.g. in the context of performance indicators on page 59 of the Proposal, – while being absent for other solutions.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

EASE welcomes the development of a classification system for sustainable economic activities to incentivise investments in clean energy technology. Energy storage has an important role to play in the energy transition by integrating higher vRES shares & supporting efficient system operation & security of supply. It is positive that the technical screening criteria listed in the annex to the draft delegated regulation recognise ‘storage of electricity’, ‘storage of thermal energy’, & ‘storage of hydrogen’ as contributing substantially to climate change adaptation. EASE is concerned about the assessment of pumped hydro storage (PHS). PHS has long played a key role in providing flexibility services, makes up over 90% of the EU’s installed storage capacity & its importance will only increase as higher vRES shares require more balancing, system & ancillary services. PHS also has proven benefits for supporting the energy transition in small isolated systems. The draft technical screening criteria unfairly assess PHS & hydropower. The current draft is not based on existing legislation (e.g. Water Framework Directive) & is not aligned with the proposals of the technical expert group (TEG), which took a fact-based approach. The “Do no significant harm” criteria for hydro, especially those for “Sustainable use and protection of water and marine resources” do not reflect the current water acquis but add additional barriers to the development of hydro projects. Criteria should be set in accordance with existing EU law. We propose to return to the TEG proposal. The criteria for “Operation of existing hydropower plants, including refurbishment activities to enhance renewable energy or energy storage potential” are unclear & are not based on technical criteria or existing EU legislation. The conditions for new hydro plants are lengthy & unclear. If not revised, the criteria will lead to high uncertainty about the treatment of PHS & hydro plants in the taxonomy. Another concern is the treatment of PHS within the category ‘storage of electricity’. This category includes ‘closed-loop pumped hydropower storage, defined as hydro plants with no natural water inflow into the upper reservoir, where the water that generates electricity was previously pumped uphill. Pumped storage connected to river bodies are not eligible’. This category is highly problematic. All PHS facilities are connected to a river or basin, whether or not they have a natural inflow into the upper reservoir. Therefore, the category in the technical screening criteria – closed-loop PHS not connected to a river/reservoir bodies – does not exist in practice. If this aspect is not amended, all PHS will be excluded from the taxonomy, resulting in a key technology which supports the transition to a decarbonised energy system being placed on an unequal footing vis-a-vis other flexibility providers. A technology-neutral approach should be adopted. Among other RES, hydropower is the only activity that must comply with general technical screening criteria (to prove that lifecycle emissions are below the threshold of 100 g CO2eq/kWh). This does not make sense: hydro is proven to be among the electricity generation technologies with the lowest lifecycle emissions. Applying a threshold of GHG emissions in gCO2 per kWh produced to mixed PHS plants is inconsistent & not implementable in practice. Like all storage, PHS plants do not produce electricity, but consume electricity (the electricity consumed by pumping a given volume of water is greater than the quantity restored by its turbines). This is why the storage technologies in § 4.10 are not subject to a GHG emissions criterion. Storage technologies, incl PHS, are categorised as enabling activities only. They should be categorised as economic activities making a substantial contribution based on their own performance. EASE calls for a careful revision of the criteria for storage, hydropower & PHS, to ensure a fact-based approach.
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Response to Strategy for smart sector integration

25 May 2020

EASE – the European Association for Storage of Energy – would like to provide input on how to better link up the energy system and exploit the synergies enabled by an integrated energy system. To achieve a truly integrated energy system, energy storage technologies are key drivers for smart sector integration. They can link different energy and economic sectors, thereby increasing the overall efficiency at energy system level while contributing positively to energy security. Please see EASE’s dedicated file.
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Meeting with Ditte Juul-Joergensen (Director-General Energy)

30 Jan 2020 · Green Deal aned Energy storage in Europe

Response to Commission Delegated Regulation establishing the Innovation Fund

10 Jan 2019

Comment 1: Table 1 ‘Illustrative Examples of Potential Projects’ The draft regulation provides a long and non-exhaustive list of eligible storage technologies. However, we noticed that pumped hydro storage (PHS) is the only mainstream storage technology not included in the list. The development of storage technologies is critical to reach the EU ETS targets. According to the EU-funded e-Storage project, the untapped potential of PHS (using existing reservoirs) is 2,291 GWh in EU15+Norway and Switzerland. Innovation in PHS can offer the energy system a great amount of high energy storage capacity at a competitive cost, without the need for scarce elements (Li, Co), and recycling problems at the end of life time. Product innovation and demonstration is highly needed for PHS, notably for head increase, variable speed, sea water pumping, hybrid micro PHS (more information on PHS innovation and demonstration can be found in the attached EASE-EERA Energy Storage Technology Development Roadmap). We would therefore suggest including PHS in the list of storage technologies.   Comment 2: Recital (7) Recital 7 states that ‘the major part of the Innovation Fund support should depend on verified avoidance of greenhouse gas emissions’. We strongly believe that the Innovation Fund should also look at the whole technology lifecycle and therefore take into account the global warming potential (GWP) of technologies and their end of life. Some technologies could indeed provide higher greenhouse gas (GHG) avoidance during operation while having higher energy intensity when manufactured than others. A wider approach based on the GWP would therefore be welcome to better assess the environmental impact of eligible technologies. This new approach should be shaped in collaboration with relevant stakeholders in order to best capture the benefits provided by the very different technologies covered by the IF. Comment 3: Article 5, paragraph 1 & Article 11, paragraph 1e We were very pleased to read that the draft Innovation Fund Regulation recognises the importance of various storage technologies for decarbonisation. However, we understand that the criteria to evaluate projects, including storage projects, are based on cost efficiency and GHG avoidance over ten years. This approach is not technology neutral since it gives an advantage to storage technologies with lower Levelised Cost of Storage (LCOS) over storage technologies which have a competitive LCOS and are more efficient over 30 years, such as liquid air energy storage. These technologies have a great potential to decarbonise the system over a longer duration (weekly, seasonal storage) but require also further demonstration. Considering their complementary contribution to decarbonising the EU economy, all storage technologies should be treated on a level playing field. Evaluation/assessment of projects and costs should therefore be done over longer periods than 10 years.
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Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker)

10 Oct 2018 · Energy Union and Climate Change

Meeting with Joachim Balke (Cabinet of Vice-President Miguel Arias Cañete)

27 May 2016 · Storage issues