Implementing new technologies, such as large-scale hydrogen applications, often represents a challenge for society. For example, when assessing permits for new types of operations, considerable challenges exist, not least in terms of difficulties regarding the degree of hazardousness and what constitutes ‘best available technique’. The less knowledge there is about the activity, the higher the requirements for safety/protective measures typically become. Some guidance can be obtained from the examination of similar activities, but as the assessment must be made on a case-by-case basis, the possibility of analogously applying the process from another type of activity is limited. The environmental permit assessment in Sweden has often been accused for both dragging on and for containing significant elements of unpredictability. For hydrogen applications, the lack of a coherent regulatory framework risks amplifying these challenges, thus creating a situation characterized by a high level of uncertainty and thereby considerable costs, which may threaten the (necessary) investments. This study examines the Swedish environmental permit process with a focus on large-scale hydrogen applications. Using both quantitative methods (a survey distributed to key actors in the hydrogen industry and relevant authorities) and qualitative legal analysis, the study aims to identify potential legal barriers that may hinder the development of hydrogen technologies and, by extension, the green transition in northern Sweden.
Pettersson et al. (Thu,) studied this question.