Fuelling Trucks with LNG/CNG along the Core Network

Additional information – Building and Environmental permitting reports: Germany


As part of activity 8 of the LNG Motion project, we reviewed the regulatory and administrative framework existing in the four EU Member States within the scope of the Action.

In October 2020 the initial report on the Building and Environmental permitting reports were published on the LNG Motion project website. After publishing this report, we gained more knowledge on the German permitting process relevant for the review of the regulatory and administrative framework existing in the four EU Member States within the scope of the Action.

In this report, the more recent experience regarding the permitting process in Germany will be described in addition to the earlier published report[1]

2. German Permitting process: recent experiences

As described in the report published in October 2020, the design plans of the installation and all the information provided for the permitting process need to be very detailed. However, the level of detail which is required was unknown based on the information at hand.

As described in 4.2 of the report published on the project website, there is a list of documents which need to be submitted with the local authorities to get the process of the permitting request started. Once everything has been submitted, the authorities will then look at the content of what has been submitted. In this phase, we have received questions from authorities we could not have anticipated on beforehand. The information request regarding one of the permitting reports in Germany was e.g., to explain what the effect is if the LNG tank would potentially be hit by a bullet. Another instance was that the authorities asked to submit a dewatering plan for the designated site, even when this was not in the initial list of required information for the permit.

The emergency plan for all stations had to be submitted even though this was not on the official list of documents and information requested when submitting the permit. This caused a delay in the overall permitting process.

Once information requests like these were sent by the local authorities, the deadline of 3 months to either deny or grant the permit gets extended. During this extension there is no transparency from the government regarding new timelines. Every information request delays the total process and there are no deadlines set for the government while these requests are pending.


3. Conclusion

The German permitting process has been more extended than expected beforehand. As a result of COVID-19 and new requests from the government, the indicated deadline of 3 months to respond to the permit request was not met in any of the permit request processes. On the contrary, the entire process of each permit request in Germany has been much longer than the timelines which were given by the local authorities.

[1] Building and Environmental permitting reports: The Netherlands, Belgium, Germany and France