Storengy
Lobbying activities towards the European institutions & relevant stakeholders.
ID: 151508738054-23
Lobbying Activity
Response to Revision of the EU’s energy security framework
13 Oct 2025
H2eart for Europe is an alliance committed to accelerating the decarbonisation of the EU energy system through the deployment of underground hydrogen storage (UHS). Introduction The EU must continue to adapt its security of supply (SoS) architecture to reflect new realities, also taking into consideration long-term perspectives. In particular, this means leveraging existing gas storage capacity not only for SoS today, but also as strategic assets that can be converted to hydrogen (H2) storage in the future, thus supporting long-term decarbonisation. Integrated strategies are also needed for the transition, ensuring SoS throughout H2s development, thereby supporting an early, clean and cost-efficient transition to H2. This requires that underground storage assets are recognized for their role across the energy system. Within this perspective, policy measures should promote UHS as a core element of energy system resilience. Below, we outline the value of UHS for SoS and propose policy levers to overcome deployment barriers. UHS for energy SoS and system resilience UHS will support the energy transition. H2 is a key lever to decarbonise industry that is central to EU competitiveness and independence. H2 is also facilitating the gradual transition to renewable power generation while maintaining electricity supply even in situations with low wind and solar availability. Potential renewable energy sources (RES) across the EU can support domestic H2 production, complementary to other cost-competitive supplies. UHS is critical to make this H2 market a reality: accelerating energy integration thanks to a smooth, constant H2 supply for users that require visibility and certainty of supply, supporting the H2 Corridors and Backbone. UHS will become a vital element of EU energy architecture. Its flexible, large-scale, long-duration energy storage possibilities will enhance SoS in a system increasingly dominated by RES. UHS will ensure that particularly industrial demand is reliably met, offering secure supply even beyond normal demand profiles. Additionally, it will help manage imported H2 volumes and strategic reserves, mitigating energy shortage risks. Policy to unlock UHS potential Current market conditions are insufficient to deliver the optimal level of H2 storage capacity for a resilient system. To realise the full potential value of UHS, policy action is required: Official Recognition. Acknowledge H2 storage as a prospective strategic asset, integrating UHS in the definition of the Gas SoS regulation. Integrated SoS Planning. Adapt the Gas SoS framework to strengthen the resilience of the entire system by ensuring that underground storage meets long-term needs: Recognize the strategic role of underground gas storage assets, while also facilitating their conversion to / the construction of new UHS facilities as the system evolves. Increase flexibility (especially in the power sector) while an H2 eco-system emerges. Establish risk assessments that integrate gas and electricity system synergies, thus ensuring that investment can support energy integration and long-term resilience. Accounting for specific SoS drivers such as the integration of RES. Emphasize the importance of RES integration for system continuity and resilience, so that underground storage (including future H2) can support evolving requirements for flexibility, stability, and peak demand management. Simplified and standardised approval processes and permitting. New projects and repurposed sites currently can face 611yr lead times, due to approval processes. This process should be streamlined and accelerated. Support Mechanisms. Enable timely investment via: Adjusting the PCI framework to reflect the specificities of hydrogen storage needs. Implementing revenue-stabilisation mechanisms and early de-risking instruments in UHS projects to accelerate the development of the H2 ecosystem by fostering investor confidence and facilitating final investm
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