For many battery storage (BESS) project developers, the real challenge begins not with the grid connection but with the permitting process. Storage projects are increasingly stalling because authorities request additional assessments or impose requirements — often just before the planned building permit or during the technical review.
What starts as a routine process can quickly end in months of delay. This affects not only large projects with more than 10 MW capacity. Smaller storage systems being built at existing PV or wind sites are also increasingly caught up in complex review processes.
Which Assessments Are Frequently Requested?
Authorities can require a wide range of reviews depending on location and state law. Particularly commonly affected are:
Fire protection assessment — Following incidents with lithium-ion batteries, many permitting authorities have tightened requirements. The vfdb has recommended new minimum standards for large-scale storage since 2025, including separate fire compartments, 15 m safety distance, and firefighting water retention.
Noise emission assessment (TA Lärm) — Even with low operational noise, systems must be evaluated according to TA Lärm.
Water and soil protection — Under § 62 Para. 1 WHG, water-hazardous substances such as electrolytes or coolants must be stored in a way that excludes groundwater contamination.
EIA preliminary assessment — The authority may order a preliminary assessment under § 7 Para. 3 UVPG if it identifies particular site-related sensitivities.
Why Requirements Usually Come Late
The problem is rarely resistance from the authority, but rather the timing of specialist consultations. In a typical process, specialist departments such as the fire brigade, environmental, or water authority are only involved in the later stages of the process. Only then do additional requirements become visible.
The AGBF demanded in a 2024 technical paper that lithium-ion storage systems must in future have fire-protection-effective separation — a requirement that many already submitted permit documents did not meet.
The BMUV noted in its 2024 Environmental Impact Assessment Guide that battery storage systems should be subject to increased scrutiny with regard to fire and firefighting water hazards in the future.
Consequences for Project Development and Financing
An unexpected assessment can set a project back by months — and thereby devalue it economically.
Delayed building permit — New assessments halt the timeline. In some cases, the process must be publicly displayed again.
Additional costs — Fire and noise protection measures can account for up to 10% of project costs.
Financing risk — Banks require updated permits and cost estimates.
Investor reluctance — Late requirements signal planning risk; many investors avoid projects with unclear permitting status.
As a result, many projects are close to the building permit and then enter an administrative standstill.
Recommendations for Developers
Project developers should voluntarily obtain fire and noise assessments in early phases, even if the authority does not (yet) require them. Coordination with the local fire brigade before submitting documents is also worthwhile.
For large installations, a permitting concept under BImSchG instead of a simple building application may make sense, as it enables more standardized and faster consultation procedures.
Additionally: If an additional assessment is requested, it should be examined whether the project is transferable or saleable — before the permit is delayed by years.
Conclusion
Many storage projects fail not due to technology but due to unexpected assessments and requirements. Fire protection, noise, water, and EIA preliminary assessments are standard requirements today — but are communicated too late in many cases.
For project developers, this can mean: high additional costs, long standstills, and expiring financing commitments.
If your storage project is stuck due to retroactive assessments or requirements, we take over. Whether Ready-to-Build or in review: We evaluate your project, handle the additional requirements if needed, and bring it to the building permit.
Official Sources
- vfdb Information Sheet 02/2025 – Fire Protection for Stationary Lithium-Ion Battery Storage
- DGUV Information 209-093 – Fire Protection When Handling Lithium-Ion Batteries
- Technical Instructions on Noise Abatement (TA Lärm) – General Administrative Regulation under BImSchG
- Environmental Impact Assessment Act (UVPG) § 7 – Preliminary Assessment of Individual Cases
- AGBF / German Fire Brigade Association – Technical Recommendations for Stationary Energy Storage Systems 2024
- BMUV – Guide to Environmental Impact Assessment 2024
- Federal Immission Control Act (BImSchG) § 4 – Installations Requiring Permits
- Water Resources Act (WHG) § 62 – Requirements for Installations Handling Water-Hazardous Substances
