France Hydrogène’s Position Paper on electrolytic low-carbon hydrogen methodology for GHG emissions
France Hydrogène welcomes the crucial work of the Commission to create a consistent regulatory framework for stimulating the downstream demand for electrolytic hydrogen (RFNBO and LCFNBO). Today, three legislations are particularly structuring for both transport and industry sectors (RED3 ; RefuelEU Aviation ; FuelEU Maritime).
What these three texts have in common is that they adopt an approach that establishes a level playing field to produce both renewable and low-carbon electrolytic hydrogen via the various objectives. It has a twofold interest :
- this approach goes hand in hand with the increasing recognition of the interest of nuclear energy for
the decarbonization of our energy mix and the achievement of climate targets ; - it will be essential to capitalize on the low-carbon electricity mixes (allowing a high load factor for electrolyzers), to deploy electrolysis within Europe and leverage orders for EU-manufactured electrolyzers.
Now that the production of RFNBO benefits from a regulatory framework, it must be complemented by the emissions accounting methodology qualifying the production of lowcarbon hydrogen during 2024 in application of Article 8 of the Hydrogen & Gas Directive.
Among different issues arises by that delegated act, the definition of the carbon content affiliated to nuclear installations will be crucial to the successful launch of an electrolysis industry in Europe.
The identified risk today would be to determine the carbon content of electrolytic LCFNBO based only on the average carbon intensity of the network mix in the bidding zone where the electrolyzer is installed, no matter the electricity sourcing strategy of the electrolyzer (e.g PPAs with nuclear installations, with respect of certain rules). This choice would have two consequences :
- it would slow down the scaling of decarbonized hydrogen production, particularly delaying the launch of e-fuels projects by pilot States like France or Finland before 2035;
- it would send a negative signal to investors regarding the structuring of the Small Modular Reactors value chain, despite their potential for producing synthetic molecules post-2035.
To define a specific carbon content for nuclear installations, France Hydrogène proposes that, similar to the delegated acts for Renewable Fuels of Non-Biological Origin (RFNBOs), other connection methods besides connection to the grid mix be recognized. Recognizing power purchase agreements (PPAs) and direct connections between nuclear electricity producers and hydrogen producers would be a way to value the lower average carbon content of nuclear power compared to the grid mix.
Find the position paper below: