Czech Hydrogen Technology Platform
HYTEP
The Platform formation was initiated in 2006 by the Ministry of Industry and Trade of the Czech Republic in response to the European Commission's Initiative - ''technology platforms'' (COM (2004) 353).
ID: 469375842976-35
Lobbying Activity
Response to Greenhouse gas emissions savings methodology for low-carbon fuels
22 Oct 2024
HYTEP welcomes the European Commissions draft proposal on the methodology to determine GHG emission saving of low-carbon fuels, including low-carbon hydrogen (LCH). However. HYTEP has identified several unclear and problematic aspects within the DA on LCH as well as concerns regarding the EU´s overall approach to LCH. - LCH is not incentivized enough in the EU regulations and directives. Without a proper regulatory framework that allows LCH to contribute toward meeting GHG reduction targets (for example, under the Renewable Energy Directive, RED), the deployment of LCH is unlikely to occur. - The Commissions proposal in Article 3 to review the impact of alternative pathways for sourcing low-carbon electricity from nuclear power plants by July 2028 is insufficient to accelerate LCH production. This option should be incorporated into the Delegated Act from its entry into force. Furthermore, the scope should be expanded to include not only nuclear but also other low-carbon electricity sources that meet a certain GHG emissions threshold per unit of electricity produced (nuclear, gas power plant with CCS/CCU), provided they are certified. - Grandfathering guarding against any unforeseen changes to methodology and emission intensity threshold at least until 2050 should be provided to avoid regulatory uncertainty for projects which start operating before certain period (to be discussed). Grandfathering should also be applicable to currently unknown emissions such as hydrogen leakage rate if projects start operating before certain period. - The Commission should allow for use of project-specific emission data regarding upstream emissions not only for methane, but also CO2, hydrogen and other GHG upstream - emissions, provided they are certified on site. (GHG methodology, Annex, Point 7). - The Commission should allow the flexible allocation of renewable or low-carbon attributes to selected outputs, rather than the proportional allocation currently required, as seen in the DA on RFNBO On RFNBO methodology which works in close relation to LCH. - Rules for RFNBO production should be amended and applicability postponed. We urge the Commission to postpone additionality rule until 2035 and completely abandon rule, that no CAPEX or OPEX supported RES is allowed for PPAs route. - We urge the Commission to postpone hourly temporal correlation rule until 2035 at the earliest or abandon the rule entirely. - Geographical rules should be amended to allow for sourcing of RES from neighboring country or bidding zone. The Czech Hydrogen Technology Platform (HYTEP) is a national association representing 86 members from both commercial and research field. HYTEP closely cooperates with Czech state authorities, particularly Ministry of Industry and Trade, aligning similar approaches and priorities. At the European level, HYTEP is actively engaged and maintains partnerships with various neighboring national associations including Polish, Slovak, Hungarian as well as Bavarian and Saxonian national associations.
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