Scottish Hydrogen and Fuel Cell Association
SHFCA
The Scottish Hydrogen and Fuel Cell Association (SHFCA) promotes and develops Scottish expertise in fuel cells and hydrogen technologies.
ID: 775127035898-44
Lobbying Activity
17 Jun 2022
The Scottish Hydrogen and Fuel Cell Association (www.shfca.org.uk) welcomes this consultation on two draft EU delegated acts and the Annex which will define the requirements and methodology for certifying green hydrogen.
Establishing suitable standards will encourage development and investment in additional production capacity for green hydrogen and derivatives across Scotland. Aligned standards for renewable and low carbon hydrogen will help deliver REpowerEU targets for 2030, including the import of 10 million tonnes of green hydrogen into Europe by 2030.
The development of offshore wind in Scottish waters will enable production of green hydrogen at mutli-GW scale. Scotland has access to 25% of Europe’s offshore wind potential, with Scotland’s ultimate offshore wind potential estimated at over 500GW. The recent ScotWind leasing round allocated offshore areas capable of an additional 25GW of offshore wind generation by the 2030’s. There is however the potential for significantly more offshore wind in Scottish waters,
Scotland is geographically well positioned to supply green hydrogen at scale into Europe by the early 2030’s. The distance of about 1000km from north-east Scotland to northern Europe will enable use of pipelines to transport gaseous hydrogen. Conversion into liquid hydrogen or production of hydrogen derivatives such as methanol and ammonia provides options for shipping of clean energy into European markets
Harmonisation of methodologies used for certification of green hydrogen and derivatives will be essential. The Annex for the EU delegated acts provides a methodology for assessing greenhouse gas emissions savings from renewable liquid and gaseous transport fuels of non-biological origin and from recycled carbon fuels. This approach used for this methodology is comprehensive, but there are several areas of detail which warrant further consideration such as indirect GHG emissions associated with venting and fugitive emissions, and should the downstream boundary be set at point of production, point of import into EU, or at the point of user demand.
Green hydrogen production in Scotland can meet the important EU requirements for additionality. Scotland’s annual production of renewable electricity now meets almost 100% of annual power demand. In 2020, Scotland produced 32 TWh of renewable electricity, equivalent to around 97% of its entire electricity consumption. This reflects renewables generation and electricity demand north of the GB B6 boundary, and establishing suitable network boundaries for a Scottish bidding zone would provide further clarity.
There will also be other potential impacts from large scale production of hydrogen and derivatives. It will be critical to identify and minimise any negative impacts, for example from use of water for production of hydrogen. The positive impacts will include the opportunity to transition high skilled jobs from oil and gas sectors, particularly with offshore expertise and experience, into low carbon, renewables, and green hydrogen. Establishing suitable standards and frameworks can help make progress with the Just Transition across Europe and beyond.
The harmonisation of requirements for green hydrogen will facilitate trade between Scotland and Europe. Scotland’s access to wind resources together with certainty of demand for clean energy from Europe will underpin onshore and offshore wind development activity. Europe’s need for secure supplies of renewable energy can be supported by additional Scottish wind generation capacity accompanied by investment in production of green hydrogen and RFNBO derivatives.
The development of offshore wind in Scottish waters will enable production of green hydrogen at mutli-GW scale. Scotland is well positioned to supply millions of tonnes of green hydrogen annually into Europe, together with security of supply and at a competitive delivered cost.
Read full responseResponse to A EU hydrogen strategy
8 Jun 2020
The Scottish Hydrogen & Fuel Cell Association (www.shfca.org.uk) welcomes this EU hydrogen strategy which can help reduce Europe’s carbon emissions in a timely and cost-effective way. This is in line with the EU’s goal – set out in the European Green Deal – to be climate-neutral by 2050, and fully aligns with Scotland’s target to achieve Net Zero by 2045. The latest evidence shows global atmospheric CO2 levels were at 417ppm in May 2020, a record CO2 high, which together with record high average temperatures for May 2020 clearly shows the increasing impacts of GHG emissions and climate change.
Energy production and use account for more than 75% of greenhouse gas emissions. Significant progress has already been made in Scotland with decarbonising electricity production; in 2018 the equivalent of 76.2% of Scotland’s gross electricity consumption was from renewables. However provisional figures indicate that progress towards the renewable energy target is much slower, at 20.9% in 2018. Fossil fuels remain predominant in end-use sectors such as transport, industry and buildings. For these hard-to-abate sectors where other alternatives might not be feasible or have higher costs, such as heavy-duty or long-range transport and energy-intensive industrial processes, clean hydrogen will play a key role in decarbonisation.
Scotland is host to many important EU funded demonstration and deployment projects including the FCH JU supported Aberdeen hydrogen bus fleet and the IPCEI Acorn project at St Fergus for H2 production with CCUS, as well as FCH JU, Interreg, & H2020 projects in diverse locations such as the BIG HIT project in the Orkney Islands (see attached schematic) which is one of many projects that are building knowledge and enabling the further development of new hydrogen valley clusters throughout Europe.
The international dimension of hydrogen is of critical importance due to its geopolitical implications in terms of security of supply and the ongoing work at global level on standardisation. Europe can benefit from an enhanced collaboration on hydrogen with its international partners, advancing technology breakthroughs with market deployment, together with the development of a well-functioning hydrogen market and corresponding cost efficient hydrogen transportation infrastructure such as pipelines across Europe. Scotland’s future renewable electricity generation potential from offshore wind has been estimated at more than 735GW (Offshore Renewable Energy Catapult, May 2020). By 2050 Scotland could be making a very significant contribution with the production of green hydrogen from offshore wind for decarbonising homes, transport, and industry across Europe.
This EU hydrogen strategy should aim to help Europe recover in a fair way from COVID-19’s economic impact. The hydrogen strategy can strengthen the production and use of clean hydrogen, focusing in particular on mainstreaming of renewable hydrogen with the repurposing of existing gas transmission and distribution infrastructure. The strategy can also enable the transfer of jobs and skills from existing high carbon emitting industries to stimulate the rapid growth of a low carbon economy. The hydrogen strategy can be part of an integrated Just Transition approach, such as that currently being developed in Scotland.
Read full response