EASE Inputs to the Public Consultation on Sustainable Finance

EASE welcomes the development of a classification system for sustainable economic activities that can incentivise investments in clean energy technology. Energy storage solutions have an important role to play in the clean energy transition by integrating higher shares of vRES while supporting efficient system operation and security of supply. Therefore, 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’, and ‘storage of hydrogen’ as activities that contribute substantially to climate change adaptation.

However, EASE is concerned about the assessment of pumped hydro storage (PHS) facilities due to unclear or unjust criteria, especially compared to other storage and renewable technologies. The draft technical screening criteria are not based on existing EU legislation and are not aligned with the proposals of the technical expert group. The classification of PHS within the category ‘storage of electricity’ is not fact-based and could lead to all PHS being excluded from the taxonomy.

Also, energy storage technologies, including PHS, are categorised as enabling activities only. They should be categorised as economic activities, making a substantial contribution based on their own performance.

EASE therefore calls for a careful revision of the draft criteria related to energy storage, hydropower and PHS, particularly the categorisation of different types of PHS, to ensure a fact-based approach that recognises the important contribution of energy storage including PHS to the energy transition.