H2V
H2V Industry is a constructor and operator of large-scale renewable hydrogen production plants (100 MW or more).
ID: 136401446852-54
Lobbying Activity
16 Jun 2022
As a developer, constructor, and operator of large-scale renewable hydrogen production plants (100 MW or more), H2V welcomes the opportunity to provide feedback on the effects that this Delegated Act will have on the hydrogen industry and on the EU meeting its decarbonization objectives.
H2V has chosen to produce hydrogen on an industrial scale to optimize production costs and produce tens of thousands of tons of renewable hydrogen, contributing to the ambitious production objectives of the Fit for 55 legislative package and REPowerEU.
Part C of the Annex, establishing the methodology for determining greenhouse gas emissions savings from renewable liquid and gaseous transport fuels of non-biological origin and from recycled carbon fuels, sets out the conditions for assessing greenhouse gas emission intensity of electricity. For fuels associated with electricity production from renewables (wind, solar, hydro, and geothermal), the carbon emissions associated with the construction and decommissioning of renewable installations are equal to zero. For nuclear, this is not the case leading to an inconsistency in treatment between different energy sources.
For the French market, in which H2V is active, the methodology leads to an incorrect calculation of 72g/kWh for the French energy mix. However, according to the independent assessment of the French electricity transmission system operator, Réseau de Transport d'Électricité (‘RTE’), a more accurate assessment would be 30-35g/kWh. Consequently, hydrogen producers in France are unfairly disadvantaged vis-à-vis producers in other Member States and third countries.
H2V, therefore, requests that emission intensity is calculated in a fair manner, particularly given its significance for the future definition of renewable hydrogen. In this regard, we consider that grid operators should be the reference point for assessing emission intensity.
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