ERCST feedback to the RED Delegated Acts. Focus on Hydrogen
Author(s): Andrei Marcu, Olivier Imbault, Bartek Czyczerski, Antonio Fernandez
As part of ERCST’s work stream on hydrogen, we should like to share with you ERCST’s feedback to the RED Delegated Acts:
- Delegated act on the methodology setting out the rules for the production of RFNBOs.
- Delegated act on the methodology to assess the GHG emissions of RFNBOs and recycled carbon fuels.
The European Commission is envisaging a hydrogen economy where regulation rather than markets is playing the key role in the development of the hydrogen market. Consequently, the amount of renewable electricity required to produce RFNBOs will depend on the level of ambition of targets and incentives set in the hydrogen regulatory framework. In other words, a hydrogen regulatory framework with focus on just one specific technology (renewables) may increase the scarcity of renewable electricity and see usage that is not necessarily the most economical and ecologically efficient.
Allowing low-carbon hydrogen to play a clear and significant role during the transition would decrease the pressure on the availability of renewable electricity, reduce the need for regulatory intervention (i.e. the additionality) and create the necessary conditions to develop the Hydrogen market.
The Delegated Acts address to renewable hydrogen, but are insufficient to define all remaining hydrogen production processes. The lack of definition for low-carbon hydrogen is the elephant in the room whose methodology should have been published along with the methodology for RFNBOs and recycled carbon fuels. A joint publication of both methodologies would have provided greater clarity for investments and reduced regulatory risk, speeding up investment decisions and accelerating the ramp-up of the hydrogen economy.
