ENVIRONMENT

Environmental permitting: a strategic factor in green hydrogen projects

The growing momentum of green hydrogen as a key driver of the energy transition is giving rise to a new generation of highly complex industrial projects from technical, territorial, and administrative standpoints. While the technological potential and favorable regulatory environment are important, experience shows that the success of these projects largely depends on how their environmental permitting process is handled in the early stages. In this context, it is becoming increasingly clear that environmental assessment must be conceived as an integrated, strategic process that goes beyond mere regulation.

Environmental permitting: from an administrative requirement to a critical project factor

In green hydrogen projects which are often associated with large industrial facilities, energy infrastructure, and significant resource consumption, the environmental permitting process cannot be viewed as a final or reactive phase. On the contrary, it is a critical factor that determines the project’s implementation, viability, and timeline.

A well-planned environmental assessment from the outset allows for:

• Identifying relevant territorial and environmental constraints.
• Evaluate realistic alternatives for location, design, and technology.
• Reduce regulatory risks and the risk of administrative rejection.
• Avoid costly redesigns and delays in advanced phases.

Experience shows that many of the roadblocks that arise during the permitting process stem from decisions made too early on without an adequate environmental basis.

Incorporate environmental, land-use, and regulatory criteria from the pre-feasibility stage

One of the key lessons learned in the planning and development of green hydrogen projects is the importance of strengthening the pre-feasibility phase by integrating environmental, land-use, and regulatory criteria from the outset on the same level as technical and economic considerations.

This early approach allows for:

• Anticipating impacts on protected areas, existing infrastructure, or planning regulations.
• Analyzing the project’s urban and industrial compatibility.
• Assess the project’s alignment with various sectoral regulatory frameworks (energy, industry, water, coastal zones, biodiversity).
• Design technical solutions that are more robust and defensible before regulatory authorities.

Environmental pre-feasibility thus becomes a tool for optimizing the project, not only in terms of regulatory compliance but also in terms of overall efficiency.

Common risks in environmental permitting and how to anticipate them.

In practice, many green hydrogen projects face recurring risks during the environmental permitting process. Among the most common are:

• Site selection involving critical environmental factors that were not initially assessed.
• Insufficient definition of the project in the early stages.
• Underestimation of the actual timelines for environmental procedures.
• Misalignment between different sector-specific permits.
• Changes in criteria among the relevant authorities.

Anticipating these risks requires a comprehensive view of the project and a deep understanding of administrative procedures, as well as early and fluid communication with the relevant agencies.

Water is one of the main bottlenecks.

The availability and management of water resources have emerged as one of the main constraints on the development of green hydrogen projects in Spain.

The growing pressure on conventional water resources, the lack of uniformity in criteria among river basin agencies, and the need to rely on alternative sources, primarily the use of reclaimed water, make it essential to incorporate this factor from the earliest stages of the project.

Experience shows that inadequate management of water-related issues can:

• Affect the project’s environmental viability.
• Cause significant delays in the permitting process.
• Create significant financial uncertainties.

Early evaluation of available alternatives, their technical, environmental, and administrative implications, and coordination with water authorities are key to ensuring the project’s viability.

An evolving regulatory framework that calls for a comprehensive approach.

The development of green hydrogen takes place within a constantly evolving regulatory context, where energy, environmental, industrial, and climate policies converge. This scenario requires an approach that goes beyond mere compliance with requirements and combines technical expertise, administrative procedures, and project viability.

Only through an integrated approach is it possible to:

• Ensure consistency between technical design and regulatory requirements.
• Ensure the project can be processed within reasonable timeframes.
• Reduce uncertainty for developers and investors.
• Move toward sustainable and robust long-term projects.

Consult the European legislation related to hydrogen.

IDOM supports promoters and developers of green hydrogen projects from the earliest stages. We bring extensive experience in environmental assessment, regulatory compliance, and the management of complex industrial and energy projects, both domestically and internationally. We integrate technical, regulatory, environmental, and land-use aspects from the beginning to ensure projects are technically viable, environmentally sound, administratively feasible, and sustainable in the long term.