H2eart for Europe has submitted a comprehensive response to the public consultation on ENNOH’s draft Cost-Benefit Analysis (CBA) Single-Sector Methodology. The alliance welcomes ENNOH’s ambition to establish a harmonised, transparent and system-wide framework for evaluating hydrogen infrastructure projects, but stresses that several methodological choices in the draft risk systematically undervaluing the contribution of underground hydrogen storage (UHS).
The CBA methodology will play a pivotal role in shaping future TYNDP cycles, informing the identification of Projects of Common and Mutual Interest and influencing the broader investment environment for hydrogen storage infrastructure. Ensuring a robust and balanced methodology is therefore essential.
In its consultation response, H2eart for Europe highlights several methodological choices that risk undervaluing the flexibility provided by underground hydrogen storage. These include fundamental modelling assumptions – most notably the need for robust cross-sectoral integration between the hydrogen, electricity and gas systems, as well as adequate spatial and temporal granularity. In addition, H2eart underscores the importance of differentiating between hydrogen products and ensuring that the methodology captures the role of storage in mitigating system uncertainty and supporting market stability.
Addressing these points is essential to ensure that the CBA framework properly reflects UHS’s full value within a deeply interconnected energy system.
The Alliance is committed to working constructively with ENNOH as the methodology evolves.