Senior government officials from Germany, Spain, the Netherlands, Poland and Austria have called for specific revisions to the EU’s RFNBO rules in a joint letter to the European Commission, claiming that the Delegated Act setting out the regulations “does not align with the economic realities of the hydrogen market development in the EU and worldwide”.

 

The three-page English-language letter, seen by Hydrogen Insight, was sent from the top civil servants at the energy and climate ministries of the five countries to the European Commission’s director-general for energy, Ditte Juul Jørgensen.

 

It states: “We would like to draw your attention to the challenges we are facing concerning the implementation of the criteria laid down in the Delegated Act.

 

“Only a few long-term offtake contracts have materialized despite national and EU funding support and binding EU quota [sic].

“Despite the efforts of the Member States, together with the Commission, the ramp-up of the hydrogen market is not progressing at the pace required.

 

“The cost of producing renewable hydrogen under the current RFNBO criteria remains, in certain cases prohibitively, high. The cost gap between renewable hydrogen and fossil-based alternatives has widened, also due to the current framework.

 

“The cost reductions for the production and installation of electrolysis plants predicted in previous studies are not materializing – instead, the acquisition and manufacturing costs continue to rise.”

 

The letter is highly unlikely to have been sent without the explicit approval of government ministers, and may have been sent on a civil-servant-to-civil-servant basis to avoid the appearance that politics were involved in the opinions expressed.

 

“A timely, efficient and targeted revision of the Delegated Act is essential to achieve the European Union's climate and industrial ambitions,” the letter continues.

 

“Immediate action should prevent further delays, stalled investments and a loss of competitiveness. If left unchanged, the current RFNBO Delegated Act criteria risks slowing down the hydrogen ramp-up by imposing a very significant burden on projects, and making it more difficult to reach the ambitious targets set out in the Renewable Energy Directive, in particular for industrial use under Article 22a [which states that 42% of industrial hydrogen must be RFNBO by 2030]. Current market development shows that the existing rules are already constraining market development today.”

 

The letter calls upon the European Commission to bring forward the planned 2028 review of the RFNBO Delegated Act to this year and propose the following “targeted adjustments on the main rules hindering the market ramp-up of RFNBOs”:

To postpone the introduction of additionality requirements for green hydrogen projects sourcing electricity through power-purchase agreement from 2028 to 2035, while extending the existing grandfathering rules (which exclude developers from such rules if they sign contracts before 2028) to 2040 (from 2038 under current rules);

 

Extending the switch from monthly to hourly temporal correlation from 2030 to 2038 for countries with “relatively clean electricity systems”, and for the Commission to “assess whether an extension of the use of monthly correlation beyond 2035 supports the objectives of the Delegated Act while respecting its legal requirements”;

 

For the European Commission to assess whether the threshold that allows projects in regions where the average proportion of renewable energy exceeded 90% in the previous calendar to be exempt from additionality and time matching rules could be reduced.

 

The joint letter also calls for revisions to include legal safeguards for early investments, in order to ensure “predictability and continued bankability for first-movers”; for revisions to enter force as soon as possible “to prevent investment standstill and further project delays”.

“We remain committed to working closely with the European Commission and stand ready to contribute constructively to this process,” the document concludes.

 

The letter was signed by:

 

Benedikt Ennser, Director-General for Energy, Ministry for Economy, Energy and Tourism, Austria

Bernhard Kluttig, Director-General for Security, Gas, Hydrogen and State holdings, Ministry for Economic Affairs and Energy, Germany

Christian Schmidt, Director-General for Electricity, Ministry for Economic Affairs and Energy, Germany

Michel Heijdra, Director-General, Ministry of Economic Affairs and Climate Policy, Netherlands

Krzysztof Bolesta, State Secretary at the Ministry of Climate and Environment, Poland

Manuel García Hernández, Director General for Energy Policy and Mines, Ministry for the Ecological Transition and the Demographic Challenge, Spain

 

Source:HydrogenInsight