Evaluating Regulatory Frameworks for High-Temperature Energy Storage in Europe within the Project PUSH-IT

The project PUSH-IT (Piloting Underground Storage of Heat In geoThermal reservoirs) is piloting the implementation of high-temperature underground thermal energy storage (HT-UTES) in aquifers (HT-ATES), boreholes (HT-BTES) and mines (HT-MTES). The project is testing the potential for HT-UTES in six pilot sites, three demonstrator and three follower sites (two per technology), in four European countries: the Netherlands, Germany, Czechia and the United Kingdom. In this work we present results of the review and analysis of regulatory frameworks for HT-UTES in European countries, with special consideration to the PUSH-IT sites. By interviewing project developers and regulators, we have gained a deeper understanding of the current regulatory frameworks. The interviews were analysed to extract key messages, identify what elements are perceived as regulatory barriers by the different stakeholders and develop a set of recommendations aiming to increase HT-UTES deployment in Europe. Among the regulatory barriers identified as potential causes of prolonged permit evaluation and approval, some are / were common to all sites, including understanding of the technology and their potential environmental impacts by regulators, lack of guidance and difficult access to information, coordination between authorities, agile communication between project developers and regulators or imposition of additional requirements when project fall outside general regulatory limits. When some of these have been facilitated, such as by providing online information, developing clear guidance or with well-established and quick communication between regulators and developers, they have constituted enablers for the technology leading to faster permitting and, ultimately, greater adoption of the technology.