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EU REQUIREMENTS FOR RENEWABLE HYDROGEN AND ITS DERIVATIVES Analysis of the two delegated acts adopted by the European Commission in February 2023 specifying the conditions under which electricity used to produce renewable fuels of non-biological origin (RFNBO) may be counted as fully renewable & the methodology to assess the greenhouse gas emissions savings from RFNBO IMPRINT As a federally owned enterprise, GIZ supports the German Government in achieving its objectives in the field of international cooperation for sustainable development. Published by: Deutsche Gesellschaft fur Internationale Zusammenarbeit (GIZ) GmbH Registered offices: Bonn and Eschborn, Germany International PtX Hub Potsdamer Platz 10 10785 Berlin, Germany T +49 61 96 79-0 F +49 61 96 79-11 15 E [email protected] I www.ptx-hub.org Responsible: Jan-Hendrik Scheyl and Johanna Friese (GIZ) Researchers: Raffaele Piria (Ecologic Institute): Introduction & chapter on legal and policy background Christoph Heinemann, Dr. Roman Mendelevitch & Susanne Krieger (Oeko Institute): Chapter on the CDR 2023/1184 Miha Jensterle & Saskia Lengning (adelphi): Chapter on the CDR 2023/1185 The International PtX Hub is implemented by the Deutsche Gesellschaft fur Internationale Zusammenarbeit (GIZ) GmbH on behalf of the German Federal Ministry for Economic Affairs and Climate Action (BMWK). Financed by the International Climate Initiative (Internationale Klimaschutzinitiative, IKI), the International PtX Hub is a contribution to the German National Hydrogen Strategy of 2020 and represents one of the four pillars of the BMUV’s PtX action programme initiated in 2019. The opinions and recommendations expressed do not necessarily reflect the positions of the commissioning institutions or the implementing agency. Berlin, 17th April 2023 (updated 29th September 2023) In collaboration with CONTENTS ABBREVIATIONS...........................................................................................................................................0 INTRODUCTION ...........................................................................................................................................1 Relevance of these delegated acts for Power-to-X markets outside the EU ........................................................................ 2 Structure of this briefing ....................................................................................................................................................... 2 Key legal sources ................................................................................................................................................................... 3 LEGAL AND POLICY BACKGROUND ..................................................................................................................4 The EU Renewable Energy Directive: RED I, RED II and RED III ............................................................................................. 5 Overall and sectorial renewable energy targets ................................................................................................................... 5 Subtargets for the transport sector .................................................................................................................................. 5 Subtargets for the industry sector .................................................................................................................................... 6 What are RFNBO and why this concept was introduced ...................................................................................................... 6 What are “Delegated Acts” and how are they applied? ........................................................................................................ 6 What are “delegated acts” and Commission Delegated Regulations (CDR)? .................................................................. 6 The RED II mandate to the European Commission to adopt these delegated acts ......................................................... 7 Will the provisions of these CDR be changed? ...................................................................................................................... 7 CONDITIONS FOR COUNTING ELECTRICITY FOR RFNBO PRODUCTION AS FULLY RENEWABLE ...............................8 Option I: Direct connection ................................................................................................................................................. 11 Option II: Grid connection ................................................................................................................................................... 11 Option IIa: Electricity grid with high share of RES-e ....................................................................................................... 11 Option IIb: Electricity grid with low CO2-emissions ........................................................................................................ 11 Option IIc: Using imbalance settlement periods ............................................................................................................ 12 Option IId: All other grip options ..................................................................................................................................... 12 Open issues for hydrogen and RFNBO production in non-EU countries............................................................................ 14 Reference to the EU Emissions Trading System ............................................................................................................. 14 Reference to day-ahead electricity price ........................................................................................................................ 14 Definition of ‘bidding zone’ ............................................................................................................................................. 14 Definition of ‘imbalance settlement period’ ................................................................................................................... 14 Data availability ............................................................................................................................................................... 14 RULES FOR GHG ACCOUNTING OF RFNBO ..................................................................................................... 15 Overall methodology for GHG accounting .......................................................................................................................... 17 Emissions from inputs ..................................................................................................................................................... 17 Emissions from processing .............................................................................................................................................. 20 Emissions from transport and distribution..................................................................................................................... 20 Emissions from utilisation ............................................................................................................................................... 20 Emission reduction from carbon capture and storage ................................................................................................... 20 Time intervals ...................................................................................................................................................................... 20 Rules for co-processing ....................................................................................................................................................... 21 ABBREVIATIONS CBAM EU Carbon Boarder Adjustment Mechanism CDR Commission Delegated Regulation DA Delegated act(s) EP European Parliament ETS EU Emission Trading Scheme GHG Greenhouse Gases ITRE Committee on Industry, Research and Energy of the European Parliament MEP Member of the European Parliament MJ Megajoule PPA Power purchase agreement PtX Power-to-X RCF Recycled carbon fuels RED (I – II – III) EU Renewable Energy Directive (1st version of 2009, 2nd of 2018, and 3rd likely to be adopted in 2023) RES Renewable energy sources RES-e Electricity generated from renewable energy sources RFNBO Renewable (liquid and gaseous transport) fuels of non-biological origin (with different definitions in RED II and RED III, as explained in the text) 1 INTRODUCTION This briefing analyses the contents of the two Commission Delegate Regulations (CDR, also known as delegated acts) adopted by the European Commission on 10 February 2023 and entered in force in June 2023: CDR 2023/1184 contains detailed rules on the conditions under which electricity used to produce hydrogen may be counted as fully renewable according to European Union (EU) law; CDR 2023/1185specifies a methodology to assess the greenhouse gas (GHG) emissions savings from renewable fuels based on hydrogen (so called renewable fuels of non-biological origin, RFNBOs) and for recycled carbon fuels (RCFs). 2 Relevance of these delegated acts for Power-to-X markets outside the EU Besides their direct applicability on activities inside the EU, the two CDR are likely to have a wider impact on the emerging global markets for PtX products. This is for three main reasons: • First, their requirements will be applicable for producers inside and outside the EU, if products used in the EU market should benefit from being counted towards achieving the recently increased EU renewable energy targets. This benefit includes access to renewable support schemes or public procurement rules, and greater chances of being considered under voluntary renewable energy and decarbonization commitment schemes by companies (e.g., steel makers, airlines). • Second, the EU has often been a trendsetter in environmental and climate standards and regulations. As the EU is the first actor to adopt comprehensive and detailed regulations in this field, it is conceivable that the rules described in this briefing might influence standards in other parts of the world. • Third, the long-awaited adoption of these two CDR will prompt certification schemes (so called voluntary schemes) to be recognized for the EU criteria and therefore kickstart official certification of hydrogen/RFNBOs under these criteria, which might benefit markets players and regulators also outside the EU. Structure of this briefing This briefing consists of three chapters: • A concise, yet updated and precise introduction to the legal and policy background of the two CDR, looking both at their immediate legal basis (RED II of 2018,) and at very recent developments of EU legislation (adoption of RED III) that will or are likely to impact the frame for the application, and possibly the further development, of these two delegated acts. • An analysis of the delegated act CDR 2023/1184, pursuant to Article 27(3) of RED II, which specifies the conditions under which electricity used to produce RFNBO may be counted as fully renewable. • An analysis of the delegated act CDR 2023/1185, pursuant to Articles 25 (2) and 28(5) of RED II, which, among other provisions, sets the methodology to assess the GHG emissions savings from RFNBOs. 3 Key legal sources This briefing largely consists of an analysis of the following documents: Short Name: RED II Official Name: Directive (EU) 2018/2001 of the European Parliament and of the Council of 11 December 2018 on the promotion of the use of energy from renewable sources URL: At this page, you can find a complete version of RED II in HTML as well as in PDF format, in each of the 24 official languages of the European Union: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.L_.2018.328.01.0082.01.ENG -------------------------------------------------------------------------------- Short Name: CDR 2023/1184, also known as delegated act (DA) pursuant to Art 27(3) RED II Official Name: Commission Delegated Regulation (EU) 2023/1184 of 10 February 2023 supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council by establishing a Union methodology setting out detailed rules for the production of renewable liquid and gaseous transport fuels of non- biological origin. URL: https://eur-lex.europa.eu/eli/reg_del/2023/1184/oj At this URL, the document is available in all 24 official languages of the European Union. -------------------------------------------------------------------------------- Short Name: CDR 2023/1184, also known as delegated act (DA) pursuant to Art 25(2) and 28(5) RED II Official Name: Commission Delegated Regulation (EU) 2023/1185 of 10 February 2023 supplementing Directive (EU) 2018/2001 of the European Parliament and of the Council by establishing a minimum threshold for greenhouse gas emissions savings of recycled carbon fuels and by specifying a methodology for assessing greenhouse gas emissions savings from renewable liquid and gaseous transport fuels of non-biological origin and from recycled carbon fuels. URL: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1185. At this URL, the document is available in all 24 official languages of the European Union. LEGAL AND POLICY BACKGROUND 4 LEGAL AND POLICY BACKGROUND The two Commission Delegated Regulations (CDRs) analyzed in this briefing have been adopted in February 2023, as delegated acts pursuant to the version of the EU Renewable Energy Directive that was adopted in 2018 and is currently in force (RED II). The two CDRs entered in force in June 2023, just few months before the EU legislators will finally adopt a comprehensive overhaul of this Directive (RED III). On its turn, RED III will trigger a future revision of at least some of the provisions of these CDR. This chapter provides background information on this intricate situation. We first look at the structure of the basic legal acts underlying the two CDRs; then we look at their provisions concerning targets, with a special attention to the specific targets most relevant for the deployment of renewable hydrogen and PtX products, e.g., the RFNBO targets; then we shortly explain the concepts of RFNBO and of delegated acts in the EU; finally, we discuss the context for possible future revisions of the two delegated acts. 5 The EU Renewable Energy States only after they will have transposed RED III into national law, which will probably be in June/July 2025. Directive: RED I, RED II and Until then, all detailed provisions of RED II will still be fully applicable, including the two CDR analysed in this RED III briefing. The EU Renewable Energy Directive (RED) is the legal framework for promoting the deployment of renewable Overall and sectorial energy sources (RES) across all sectors of the EU renewable energy targets economy. The first RED (RED I) was adopted by the EU in 2009. Among many other provisions, it set a target of With the RED III, the EU has strongly increased its 20% renewables share on the total final EU energy renewable energy target for 2030, from 32% (as consumption by 2020, which the EU overachieved. agreed in 2018 in the RED II) to 42.5% of the EU’s overall energy consumption, with an additional 2.5% indicative RED I was replaced by a second version (RED II), which top up that would increase the target to 45%. Except for was adopted in 2018 and is currently in force. In the the addition of osmotic energy, the general definition legislative process, Directives are proposed by the of what is considered as energy from renewable European Commission (EC), then amended and finally sources has not changed 2. adopted by the two legislators, the European Parliament (EP) and the European Council, where the Besides this overall target, RED III also strongly Member States are represented. increases and modifies the rules concerning sector After a long negotiation among the two legislators, on targets, which include specific targets for (hydrogen 12 September 2023 the EP adopted a text of the third based) renewable fuels of non-biological origin version (RED III), which had been previously informally (RFNBO). agreed upon by the Council. It can be assumed that this text will be adopted by the end of 2023 and enter in Subtargets for the transport sector force shortly afterwards 1. With the RED III, the 2030 binding subtarget for the transport sector increases from at least 14% (as EU Directives are not directly applicable: they must foreseen in RED II) to at least 29% of renewables within first be transposed into national legislation. For RED the final consumption of energy in the transport sector III, the Member States will have to do so within 18 by 2030. Alternatively, Member States may choose to months after the date of entry to in force of RED III set a binding target of 14.5% reduction of the transport sector’s GHG intensity by using renewables. This means that, while RED III is likely to enter into Additionally to these two general options for the force in December 2023 or January 2024, its provisions transport sector target, RED III sets a minimum will become fully applicable in the individual Member requirement of 1% of RFNBO in the share of 1 The analysis in this briefing is based on the final text approved by the European Parliament on 12 September 2023, which is available here: https://www.europarl.europa.eu/doceo/document/TA-9-2023-0303_EN.html#title2 Previously, the identical legal text had been formally endorsed (see: https://www.consilium.europa.eu/media/65109/st10794- en23.pdf ) by COREPER, which is the Council’s main preparatory body and consists of the member states’ permanent representatives to the EU. It is extremely seldom, but formally not precluded, that the Council changes its mind after COREPER has adopted a text. If such a change of mind does not happen, the text approved by the EP in September 2023 will enter in force, pending the correction of potential technical or legal mistakes. 2 According to Art 2 RED III: “…‘energy from renewable sources’ or ‘renewable energy’ means energy from renewable non-fossil sources, namely wind, solar (solar thermal and solar photovoltaic) and geothermal energy, osmotic energy, ambient energy, tide, wave and other ocean energy, hydropower, biomass, landfill gas, sewage treatment plant gas, and biogas ”. Osmotic energy is defined as “energy created from the difference in salt concentration between two fluids, such as fresh water and salt water”. The proposal by some EU Member States to include nuclear energy in this list encountered strong opposition from other EU Member States and was finally rejected. On the other hand, nuclear energy might contribute to achieve one of the conditions necessary for electricity used to produce RFNBO to be counted as fully renewable, though this is into likely to play a major role in practice. More on this in Chapter 3 of this paper. 6 renewable energies supplied to the transport sector in transport sector subtarget either with biofuels and 2030, as well as a minimum requirement of 5.5% for the biogas or with RFNBO. The rationale for setting a sum of biofuels and RFNBOs. The latter means that, in specific subtarget for the transport sector was that, case of a low availability and/or competitiveness of while renewables deployment was rapidly progressing biofuels complying with the relevant EU sustainability in the electricity and, to a lesser extent, in the heating criteria, the share of RFNBO in the transport sector sector, at that time there had been very little progress might need to be higher than 1%. in the transport sector. In 2009, the costs of green hydrogen were still prohibitively high. However, when The clause that allows Member States to fulfil the RED II was adopted in 2018, the massive cost transport sector target with recycled carbon fuels as reductions of wind and solar power made a wide use of well remains unchanged in RED III. 3 green hydrogen seem potentially viable in the foreseeable future. Thus, the rationale for introducing Subtargets for the industry sector the RFNBO concept was that the EU needed a legal Moreover, article 22a of RED III introduces for the first concept for (at that time only transport) fuels of non- time a specific renewable energy target for the industry biological origin that fulfil the EU renewable energy sector, expressed as an indicative increase of at least targets. 1,6 % as an annual average calculated for the periods However, as seen above, RED III introduces specific 2021 to 2025 and 2026 to 2030. In addition, RED III sets renewable energy targets also for the industrial sector, a binding target, according to which at least 42% of the which can be fulfilled using RFNBO. Therefore, in RED III hydrogen used in industry should come from RFNBO RFNBO count regardless of the sector in which they are by 2030, and 60% by 2035. A derogation (20% less) is consumed. Accordingly, Article 2 of RED III establishes a foreseen for Member States that fulfil two conditions: new definition of the RFNBO concept, without the word First, they must meet their expected contribution to the transport: “ ‘renewable fuels of non-biological origin’ overall EU renewables target; second, the share of means liquid and gaseous fuels the energy content of hydrogen from fossil fuels consumed (in all sectors) which is derived from renewable sources other than may not be more than 23% in 2030 and 20% in 2035. biomass”. What are RFNBO and why this What are “Delegated Acts” concept was introduced and how are they applied? In short, RFNBO means renewable fuels of non- What are “delegated acts” and Commission biological origin. In other words, RFNBO can be seen Delegated Regulations (CDR)? as a subpart of Power-to-X (PtX) products, with two Although both legal acts analysed in this briefing are additional requirements: first, the electricity must fulfil commonly called “delegated acts”, their formal the criteria for renewable energy according to EU law; denomination is “Commission Delegated second, the RFNBO must meet a certain GHG emissions Regulation”. According to EU law 4, Regulations are reduction threshold. Also, RFNBO must be by definition binding in their entirety and - unlike Directives - are fuels, whereas the PtX concept also includes power- directly applicable in all EU countries. While ordinary based feedstock. These requirements are discussed in Regulations are jointly adopted by the EU’s main detail in the following chapters of this briefing. legislators (European Parliament and European Council), Delegated Regulations are adopted by the The RFNBO concept was first introduced in the RED II, European Commission, if it has been given the mandate according to which the EU Member States can reach the to do so by the two main legislators in a legislative act. 3 Recycled carbon fuels (RCF) are defined by RED II as “liquid and gaseous fuels that are produced from liquid or solid waste streams of non-renewable origin which are not suitable for material recovery (…), or from waste processing gas ad exhaust gas of non-renewable origin which are produced as an unavoidable and unintentional consequence of the production process in industrial installations”. In other words, RCF can be for instance synthetic fuels produced with CO2 captured from fossil-based industrial processes. 4 For an official overview of all existing EU legal instruments, see: https://eur-lex.europa.eu/EN/legal- content/glossary/eu-legal-instruments.html. 7 The RED II mandate to the European Commission to adopt these delegated acts Will the provisions of these In RED II, this was the case among others for the two delegated acts discussed in this briefing. Specifically, CDR be changed? article 27 (3) of RED II shortly defines general rules on the conditions under which electricity used to produce According to RED III, the European Commission must RFNBO may be counted as fully renewable. It contains a submit a report to the Parliament and the Council by 1 mandate to the European Commission to adopt a July 2028, assessing the impact of the methodology delegated act establishing a methodology setting out defining when electricity used for producing RFNBO more detailed rules on this topic. Additionally, articles can be considered to be fully renewable, e.g., the 25(2) and 28(5) of RED II set further general rules for contents of CDR 2023/1184, which is described in detail renewable energy in the transport sector. They include in the next chapter of this paper. For the case that the a mandate to the European Commission to adopt a report concludes that there is a need for revision RED III delegated act specifying the methodology for assessing gives the Commission the mandate to adopt a new GHG savings from RFNBOs and from recycled carbon delegated act amending CDR 2023/1184. fuels. 8 CONDITIONS FOR COUNTING ELECTRICITY FOR RFNBO PRODUCTION AS FULLY RENEWABLE The delegated act CDR 2023/1184, pursuant to Art. 27(3) RED II, defines two general options under which electricity supplied to the installation producing RFNBOs (RFNBO plant) may be counted as fully renewable. The first one is a direct connection between the installation generating renewable electricity (RES-e plant) and the RFNBO plant. In the second option, the RFNBO plant uses electricity from the grid. 9 General • The provisions in CDR 2023/1184 explicitly apply both to domestic and imported RFNBO. • The underlying assumption is that electrolysis will be the main technology used to produce hydrogen. The rules concerning electricity supply set by the CDR 2023/1184, however, also hold for other less common technologies that have electricity as a major input. The CDR 2023/1184 defines two general options under renewable electricity used to produce RFNBO which electricity supplied to the installation producing is no longer available for other uses. RFNBOs (RFNBO plant) may be counted as fully 2. The principle of temporal correlation renewable. The first one is a direct connection should incentivize RFNBO production to take between the installation generating renewable place at times when it supports the electricity (RES-e plant) and the RFNBO plant. In the integration of RES-E production into the second option, the RFNBO plant uses electricity from electricity system, thus reducing the risk that the grid. RFNBO production triggers additional fossil- For both Option I and Option II, CDR 2023/1184 sets based electricity generation. very detailed rules. Their main rationales are the 3. The principle of geographical correlation intention to minimize GHG emissions associated with should incentivize RFNBO production to take the additional electricity demand caused by the RFNBO place in grid areas with high RES-E shares production and to limit additional stress to the and/or low carbon emissions, thus limiting electricity grid. CDR 2023/1184 is based on three the risk that RFNBO production causes underlying principles: additional stress to the electricity grid. 1. The principle of additionality should The following diagram shows the overall structure of incentivize the deployment of additional and CDR 2023/1184 and the options it defines. The options new renewable electricity generation and requirements are described in detail in the capacity, thus avoiding the risk that following sections. 10 Under which conditions may electricity used to produce RFNBO counted as fully renewable? Figure 1. Source: Own illustration 11 Option I: Direct connection are met during this period (curtailment of RES-e plants). The aim is to use electricity from RES-e that would have been lost A direct connection between the RES-e plant and the otherwise. RFNBO plant is considered a reliable option to provide II.d If the three options above do not apply, evidence that renewable electricity is being used. For further requirements are set to count this option to be valid, each of the following three electricity taken from a grid (with no specific requirements must be complied with: qualities) as fully renewable. 1. There has to be a direct connection between In the following, further details about each of these four the RES-e plant and the RFNBO plant. This options are explained. can be a direct electricity line or, alternatively, generation of electricity and RFNBO Option IIa: Electricity grid with high share of RES-e production takes place within the same In this option, RFNBO production takes place in a installation (for example if an electrolyser is bidding zone with an average RES-e share above 90%. located directly at a wind farm). To count the electricity used to produce RFNBOs as 2. The RES-e plants need to be new, meaning fully renewable, both of the following requirements that they came into operation at the earliest must be fulfilled: 36 months before the RFNBO plant came into operation. 1. The average RES-e share must exceed 90%. 3. Either the RES-e plant is not connected to the This share has to be documented for the grid, or if it is connected, a smart metering previous calendar year in the bidding zone system has to prove that no electricity has where the RFNBO production takes place. been taken from the grid to produce RFNBOs. Once the share exceeds 90% in one calendar year, it is assumed that it also exceeds 90% for the next five calendar years. Detailed rules Option II: Grid connection on how to calculate the RES-e share can be found in Article 4(1) of CDR 2023/1184. As shown in the chart above, there are four general 2. The maximum number of hours of RFNBO options for counting electricity taken from the production is limited in proportion to the electricity grid as fully renewable. RES-e share within the bidding zone. The number of hours eligible for RFNBO II.a The RFNBO plant uses electricity from a grid production is calculated by multiplying the with a high share of RES-e. This is considered total number of hours per calendar year to be the case if the RFNBO production takes during which the RES-e share exceeds 90% by place in a bidding zone 5 with an average RES- 8760 (= number of hours per calendar year). e share above 90%. This should incentivize a reduction of RFNBO II.b The RFNBO plant uses electricity from a grid production during times of low RES-e shares. with low CO2 emissions. This is considered to be the case if the RFNBO production takes Option IIb: Electricity grid with low CO2-emissions place in a bidding zone with average In this option, RFNBO production takes place in a emissions intensity of electricity below bidding zone with average emissions intensity of 18gCO2eq/MJ. electricity below 18gCO2eq/MJ. To count the electricity II.c The RFNBO plant uses electricity from a grid used to produce RFNBOs as fully renewable, all of the during an imbalance settlement period 6. This following four requirements must be fulfilled: option is only applicable if specific conditions 5 ‘Bidding zone’ according to the EC means the largest geographical area within which power market participants are able to exchange energy without capacity allocation (equivalent concepts can be applied for countries outside the EU). In the EU, some countries have one bidding zone, while others have several. 6 ‘Imbalance settlement period’ is defined as the time unit for which an imbalance of the balance responsible parties is calculated. This is the case for example if electricity supply and demand cannot be balanced via the electricity grid. For third countries, an equivalent concept may be applied. 12 1. The production of RFNBOs is located in a Option IIc: Using imbalance settlement periods bidding zone where emission intensity of In this option, electricity sourced to produce RFNBO is electricity is lower than 18gCO2eq/MJ. 7 This is consumed during an imbalance settlement period to ensure that RFNBO-production is (curtailment of installations generating renewable associated with relatively low GHG emissions. electricity) 8. To count the electricity used to produce Once the emission intensity of electricity is RFNBOs as fully renewable, the producer of RFNBOs proven to be lower than this threshold in one has to show evidence from the transmission system calendar year, it is assumed that it is below operator that both following requirements are fulfilled: this value for the next five calendar years as well. Detail rules on how to calculate the RES- 1. The electricity consumed to produce RFNBOs e share can be found in article 4(2)(b) of CDR is consumed during a time period in which 2023/1184. RES-e plants had to deviate from their 2. Fuel producers must conclude power planned production schedule and purchase agreements (PPAs) with RES-e deliberately reduce electricity output due to plants. The amount covered by those PPAs grid bottlenecks (curtailment). has to be at least equivalent to the amount 2. The electricity consumed to produce RFNBOs used for RFNBO production that is claimed to reduces the need for redispatch by the be fully renewable. In this case, the RES-e corresponding amount. plants do not need to be new or unsupported (in contrast to “additional renewable Option IId: All other grip options electricity generation” in Option IId below). If the three options above (IIa to IIc) do not apply, 3. Temporal correlation has to be proven, electricity from the grid may be counted as fully please see below section “Temporal renewables, if requirements on additionality, temporal correlation” and geographical correlation are met. Electricity 4. Geographical correlation has to be proven, consumption from the grid may be counted as fully please see below section “Geographical renewable, if all of the three following conditions on correlation” additionality, temporal correlation and geographic correlation are met. 7 This clause has been criticised or welcomed, depending on the point of view, for paving the way for nuclear-based electrolysis to fulfil the criteria for renewable based hydrogen. However, it should be noted that the other three conditions above must be met, including concluding a PPA with RES-e plants. Moreover, in the RED III, the definition of RES will not include nuclear (see footnote 4 above). In the EU in 2020, this value was met only by Sweden (4.1 CO2eq/MJ), which has a very high combined share of renewables and nuclear. The only other EU country close to this benchmark was France (19.6 CO2eq/MJ). These values are provided in Table A in the Annex to the CDR 2023/1185 discussed in the next chapter of this briefing. 13 Addtionality To comply with the additionality condition, each of the three following requirements must be fulfilled: 1. RFNBO producers must conclude power purchase agreements (PPAs) with RES-e plant operators. The amount of electricity covered by those PPAs has to be at least equivalent to the amount used for RFNBO production that is claimed to be fully renewable. 2. The RES-e plants have to be ‘new’. This means they came into operation no earlier than 36 months before the RFNBO plant. RES-e plants are also considered to be ‘new’ if they have ended a PPA with a RFNBO producer before entering into a new PPA. In case additional capacity is added to the RES-e plant up to 36 months after its initial deployment, they are assigned the same date of initial deployment. This means that the added capacity is considered to have come into operation at the same time as the initial installation. 3. The RES-e plant has not received operating or investment support. Excluded from this rule is support received before a repowering, support for grid connection, support that is fully repaid or support received in the context of research, testing and demonstration of RFNBOs production. Transition phase: In case the RFNBO plant comes into operation before 1 January 2028, the requirements 2 and 3 described in this section do not apply until 1 January 2038. Temporal correlation To comply with the temporal correlation condition, it is sufficient to meet one of the following requirements. 1. The production of RFNBOs takes place during the same time period as renewable electricity is produced in the RES-e plants contracted by the PPAs. Another option is the use of electricity from new electricity storage assets that are connected to the same electricity-grid connection point as the RFNBO plant or RES-e plant. However, the storage must be charged during the same time period in which the electricity contracted by the PPA is produced. The definition of the ‘time period’ gets stricter over time: • Until 31 December 2029 the ‘time period’ is defined as the ‘same calendar month’. • From 1 January 2030 the ‘time period’ is defined as the ‘same hour’. 2. The production of RFNBOs takes place during a one-hour period when the day-ahead price of the bidding zone where RFNBO production takes place is a. below 20€/MWh, b. or lower than 0.36 times the price of an EU ETS emission allowance, corresponding to the right of emitting one ton of CO2 eq. Geographical correlation To comply with the geographical correlation condition, one of the following requirements must be met: 1. The RFNBO plant and the RES-e plants contracted by the PPA are located in the same bidding zone. 2. The RFNBO plant and the RES-e plants contracted by the PPA are located in interconnected bidding zones. Interconnected means that there is an electricity-grid connection between the bidding zones. However, this option can only be applied in time periods (monthly or hourly, see above ‘temporal correlation’) when the following condition applies: The electricity price on the day-ahead market in the RES-e plant’s bidding zone is equal or higher than the electricity price on the day-ahead market in the RFNBO plant’s bidding zone. 3. RES-e plants contracted by the PPA are located in an offshore bidding zone that is interconnected to the bidding zone where the RFNBO production takes place. EU Member States may introduce additional criteria on geographical correlation valid on their territory. 14 Open issues for hydrogen and Definition of ‘bidding zone’ A number of options and requirements within the CDR RFNBO production in non-EU 2023/1184 refer to bidding zones. A bidding zone is defined as the largest geographical area within which countries market participants are able to exchange energy without capacity allocation. The third recital (the legally non-binding statements in the preamble of the Article 1 of the CDR 2023/1184 states that the rules shall legal document) of the CDR 2023/1184states: apply, regardless of whether the RFNBO is produced inside or outside the EU. “Where reference is made to bidding zone and imbalance settlement period, concepts that exist in the However, some of the rules are based on the EU Union but not in all other countries, it is appropriate to regulatory framework and very specific to the EU allow fuel producers in third countries to rely on context. The compliance with them might be difficult to equivalent concepts provided the objective of this demonstrate when producing RFNBO outside the EU. Regulation is maintained and the provision is The following paragraphs show the main issues that implemented based on the most similar concept might become a hurdle for third countries. The EU existing in the third country concerned. In case of has not yet established an official procedure on how to bidding zones such concept could be similar market deal with them, which will be object of future regulations, the physical characteristics of the discussions. Evolving certification systems for RFNBO electricity grid, notably the level of interconnection or as a last resort the country.” production might play a major role for proof of compliance and need to further define those open Besides this, there currently is no further definition of issues. what can be declared by whom as such an ‘equivalent Reference to the EU Emissions Trading System concept’. One of the options to comply with the temporal Definition of ‘imbalance settlement period’ correlation requirement (see section “Temporal Similarly, to the definition of the bidding zone, an correlation”) refers to the EU Emissions Trading System equivalent concept for third countries might be (ETS). In non-EU countries with no or fundamentally applied. Again, it is not defined what can be declared as different emission trading schemes, this rule might not such an ‘equivalent concept’. Also, it is yet to be be directly appliable. defined which institution can attest this ‘equivalent concept’. Reference to day-ahead electricity price Some of the options refer to an electricity price on the Data availability day-ahead market. However, if the electricity system or Sufficient and validated data needed to comply with the market structure in third countries does not include the regulations might not be given in third countries. some form of day-ahead price, this option might not be For example, data needs to be available to prove a grid applicable. share of above 90% or that RES-E plants have not received financial support. Again, certification systems might fill the gap and define which data needs to be documented. 15 RULES FOR GHG ACCOUNTING OF RFNBO 16 Both RED II and RED III define a minimum GHG savings fuels” (see Annex III RED II), into 3.38 tCO2 threshold of 70% for RFNBOs in relation to the fossil eq/ ton of hydrogen from renewable comparator of 94 gCO2eq/MJ: sources. • RFNBOs exceeding this threshold are not • This translates into a maximum GHG forbidden in the EU, but they will not count intensity threshold of 28.2 gCO2 eq/MJ or, for the purpose of achieving the RES targets based on the table “Energy content of according to RED II and RED III. Overall context of the delegated act CDR 2023/1185 • RED II and RED III set for RFNBOs a minimum GHG savings threshold of 70% in relation to the fossil comparator. This means that synthetic fuels that do not meet this threshold cannot be considered as of “renewables origin” according to EU law. However, RED II does not determine the methodology for GHG accounting for RFNBO. • The CDR 2023/1185 sets the rules for GHG accounting for RFNBOs. • The CDR 2023/1185 also sets a minimum GHG savings threshold of 70% for all types of RCFs and sets the rules for GHG accounting for RCFs; however, RCFs do not lie in the focus of this briefing and will only be mentioned where necessary for explaining the contents of the DA relevant for RFNBO. Figure 2. Source: Own illustration 17 The CDR 2023/1185 provides more detailed rules: To calculate the total emissions when producing RFNBO, the emissions of the whole value chain need to • The methodology and rules for GHG be accounted for using the following formula. Not accounting for RFNBO: accounted for are emissions from manufacturing of o Considers full life cycle emissions; machinery and equipment. o Considers three greenhouse gases: 𝑬𝑬 = 𝒆𝒆𝒊𝒊 + 𝒆𝒆𝒑𝒑 + 𝒆𝒆𝒕𝒕𝒕𝒕 + 𝒆𝒆𝒖𝒖 − 𝒆𝒆𝒄𝒄𝒄𝒄𝒄𝒄 , CO2, N2O and CH4, the latter two are accounted as CO2 equivalents according to RED II (§4 Annex V Part Where: C); o Defines the methodology to avoid • ei are emissions from inputs (rigid, elastic and emissions from inputs’ existing use or fate), double-counting of emissions • ep are emissions from processing, savings. • etd are emissions from transport and • The conditions under which the emissions of distribution, captured CO2 incorporated in a RFNBO may • eu are emissions from utilization be subtracted. (combustion), and • The rules for co-processing and co- • eccs are emissions savings from carbon production with conventional fuels and capture and storage. biomass. • The default GHG emissions intensities for In the following, we discuss each element of this common inputs (e.g., national grid electricity formula. emissions intensity). Emissions from inputs The Annex to the CDR 2023/1185 includes nearly all Emissions from inputs are split into three parts: rules and definitions. 𝒆𝒆𝒊𝒊 = 𝒆𝒆𝒊𝒊, 𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓 + 𝒆𝒆𝒊𝒊, 𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆 − 𝒆𝒆𝒊𝒊, 𝒆𝒆𝒆𝒆 𝒖𝒖𝒖𝒖𝒖𝒖 Overall methodology for GHG accounting Emissions from rigid inputs Rigid inputs are inputs where “supply cannot be The emission savings of the RFNBO compared to the expanded to meet extra demand”. If inputs are outputs fossil fuel comparator (EF) are calculated in the from incorporated processes 9, they need to be following manner: produced in fixed ratios and make up less than 10 % of the economic value of the incorporated processes’ 𝑬𝑬𝑭𝑭 − 𝑬𝑬 outputs. 𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬 𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔𝒔 = ≥ 𝟕𝟕𝟕𝟕% 𝑬𝑬𝑭𝑭 An example for a rigid input can be flue gas; per EF = 94 gCO2-eq/MJ definition, all carbon sources qualifying to produce RCF are rigid (on the latter point, see below). 9 Incorporated processes are defined as taking place in the same industrial complex, or supplying the input via a dedicated supply infrastructure, or supplying more than half of the energy of all inputs to the production of RFNBO. 18 The calculation of the emissions intensity of rigid inputs production, the emissions resulting from the must include: replacement of the provided heat must be accounted as well. This can be calculated • All emissions resulting from diversion of with standard emissions factors that are feedstock from previous use provided in the annex of the DA. However, the • Emissions from additional treatment and DA does not prescribe the method for transport determining the replacement process. • Emissions from lost production: When a Accounting for lost production is illustrated in feedstock of a previous process (for example the following figure: using heat from a flue gas stream) is diverted to be a rigid input for RFNBO or RCF Rigid inputs: lost production On the left-hand side, the figure shows flue gas being led through a heat exchanger, providing heat to an end use application such as space heating; in the middle, it shows the flue gas being diverted to create fuel; on the right-hand side, the replacement process for the lost heat is depicted which needs to be taken into account for the GHG balancing of the fuel. Figure 3. Source: Own illustration Emissions from elastic inputs When calculating emissions, the data needs to be Elastic inputs are inputs where “supply can be based on the actual production process and must increased to meet extra demand”, as well as inputs include: from incorporated processes that make up more than 10 % of the economic value of the incorporated • Emissions from the extraction of primary processes’ outputs, or where the ratio of the processes’ energy required to make the input. outputs can be changed. • Emissions from the processing and the transportation of the inputs. Examples for elastic inputs include hydrogen, • Not including emissions from the combustion electricity and petroleum products. of inputs (those are counted under ep or eu). 19 Emissions from non-incorporated processes can be o Alternatively, the GHG emissions assessed on the basis of Annex Part B of the CDR value of the marginal unit 2023/1185, on the basis of LCA databases or from peer- generating electricity at the time of reviewed literature. RFNBO production in the relative bidding zone, if this value is publicly For the emissions associated with electricity used as available. input to produce RFNBO or RFC, the CDR 2023/1185 stipulates the following: Emissions from inputs’ existing use or fate Emissions from inputs’ existing use or fate are • Electricity qualifying as renewable emissions “that are avoided when carbon is used as according to article 27(3) RED II shall be input for fuel production” (own bolding). They can be accounted with zero emissions. The detailed counted as avoided and subtracted from the emissions rules to determine whether electricity of the RFNBO only if the CO2 was captured and qualifies as renewables are established by the incorporated into the fuel from one of the following CDR 2023/1184, analysed above. carbon sources: • In all other cases, during each calendar year, one of the three following alternatives can be • CO2 from direct air capture used. • CO2 from biofuels/-liquids/-mass if it o Grid emissions at country level or, if complies with the sustainability and GHG data are publicly available, at the saving criteria of RED II. level of the bidding zone. • RFNBO or RCF according to RED II. The formula to calculate the grid • Geological sources where CO2 was previously emissions includes both emissions released naturally. incurring in the power plants and • CO2 from activities subject to the EU ETS upstream emissions. Part B of the (Emission Trading Scheme), provided that: CDR 2023/1185 contains a list of o It was subject to an "effective standard values for the GHG carbon pricing scheme". This is by emission intensities of elastic inputs definition the case within the EU. (including fossil fuels used for Under which conditions carbon electricity generation), which pricing schemes outside the EU can indicates both combustion be considered as “effective” will emissions and upstream emissions. likely be determined in the Part C explains the methodology to upcoming EU Carbon Boarder be used to calculate grid emissions Adjustment Mechanism. at the country or bidding zone level. o The CO2 has been incorporated in o Alternatively, where „the number of the chemical composition of the fuel full load hours of the installation by the end of 2035 if it comes from producing RFNBO is equal or lower electricity generation, or by the than the number of hours in which end of 2040 if it comes from other the marginal price of electricity processes. was set by installations producing renewable electricity or nuclear Emissions which are not considered avoided may not power plants in the preceding be subtracted. These include: calendar year” (own bolding of the text by the authors of this briefing), • All cases not explicitly mentioned above. The emissions can be counted as zero; if EU does not forbit specific carbon sources, the installation producing RFNBO however the rules above need to be followed. exceeds this number of full load • CO2 from fuel deliberately combusted with hours, grid electricity used during the purpose of producing CO2. these hours is attributed a standard • CO2 which "has received emissions credit value of 183 gCO2 eq./MJ. under other provisions of the law". 20 The EU does not forbid the use of any particular CO2 Emissions from utilisation sources. However, in order to be able to count the In the above formula, the term eU means emissions product as RFNBO, the rules of this DA must be from utilization, which in this case refers to the followed. For this purpose, it is necessary to meet the combustion of the RFNBO. 70% minimum GHG reduction threshold and using CO2 sources that may be counted as “avoided emission” Emission reduction from carbon capture and storage The CDR 2023/1185includes the possibility to subtract makes an important contribution to meeting this negative emissions. This only counts for carbon threshold. emissions that are permanently stored in accordance with Directive 2009/31/EC. These rules are expected to be applied to future imports of synthetic fuels into the EU as well. Time intervals Emissions from processing Processing describes the parts of the value chain where The calculation interval for GHG averaging is one the fuel is produced, for example an electrolyser or a calendar month or less. Where electricity qualifying synthesis process. Emissions from processing include as fully renewable according to RED II (as specified in atmospheric emissions stemming directly from detail in the CDR 2023/1184, see chapter above) is used processing, emissions from waste treatment, from as input, the time interval shall be in line with the leakage and from storage operation associated with requirements applying for temporal correlation CCS (including transport of CO2). between the electricity production and fuel production. If these individual time intervals are shorter than the Emissions from transport and distribution calculation interval for GHG averaging, they can be After processing, the finished fuel usually needs to be used to calculate the average, but each one of these stored, transported and distributed. The associated individual time intervals must meet the GHG savings emissions must be included in the accounting. threshold of 70%. 21 Rules for co-processing If an output is a mix of RFNBO and RCF or other fuels, all types of fuels are considered to have the same emissions intensity, calculated according to the following formula: 𝒌𝒌𝒈𝒈 𝑪𝑪𝑪𝑪𝟐𝟐 𝒆𝒆𝒆𝒆 𝒕𝒕𝒕𝒕𝒕𝒕𝒕𝒕𝒕𝒕 𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂 𝒐𝒐𝒐𝒐 𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆 [𝒌𝒌𝒈𝒈 𝑪𝑪𝑪𝑪𝟐𝟐 𝒆𝒆𝒆𝒆 ] 𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬 𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊 𝒐𝒐𝒐𝒐 𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐 [ ]= 𝑴𝑴𝑴𝑴 𝒕𝒕𝒕𝒕𝒕𝒕𝒕𝒕𝒕𝒕 𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂𝒂 𝒐𝒐𝒐𝒐 𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑 𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇 [𝑴𝑴𝑴𝑴] When RFNBO and RCF are co-processed with conventional fuels or biomass-based products, meaning the inputs don’t fully qualify as of renewable origin, the share of RNFBO/RCF is determined by relevant shares of input energy according to: 𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓 𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊 𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆 𝒕𝒕𝒕𝒕 𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑𝒑 𝑹𝑹𝑹𝑹𝑹𝑹𝑹𝑹𝑹𝑹 𝒐𝒐𝒐𝒐 𝑹𝑹𝑹𝑹𝑹𝑹[𝑴𝑴𝑴𝑴] 𝑺𝑺𝑺𝑺𝑺𝑺𝑺𝑺𝑺𝑺 𝒐𝒐𝒐𝒐 𝑹𝑹𝑹𝑹𝑹𝑹𝑹𝑹𝑹𝑹 𝒐𝒐𝒐𝒐 𝑹𝑹𝑹𝑹𝑹𝑹 [%] = 𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻𝑻 𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊𝒊 𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆𝒆 [𝑴𝑴𝑴𝑴] Additionally, emissions can be allocated to by-products such as chemicals, heat, mechanical energy and electricity. If the output ratio of these products is fixed and the outputs are all fuels, electricity or heat, emissions of each output are calculated based on the emissions of relevant inputs as well as on the energy-related fraction of the other emissions components: 𝒌𝒌𝒈𝒈𝒈𝒈𝒈𝒈𝟐𝟐 𝒆𝒆𝒆𝒆 𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝑬𝒔𝒔𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐𝒐 � � = 𝒆𝒆𝒊𝒊,𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓𝒓 + 𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇𝒇 ∗ (𝒆𝒆𝑷𝑷 + 𝒆𝒆𝒕𝒕𝒕𝒕 − 𝒆𝒆𝒄𝒄𝒄𝒄𝒄𝒄 ), 𝑴𝑴𝑴𝑴 where fraction is the share of relevant input energy. The text of the CDR 2023/1185 is not unambiguous with regard to the role of eu in the above equation. In contrast to all other emissions, it does not mention it explicitly; however, the view of the authors of this briefing is that these probably also have to be taken into account in case the output is fuel. If the process used allows for varying the output ratios, then the process emissions have to be allocated based on the effect on the process emissions of incrementing just one of the outputs (while the shares of others remain constant). For co-products without energy content, the allocation is based on the economic value. Saatja: Kaspar Peek - MKM </O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=BBFC0B2DE7154DDF95A8E6AF83878E90-5681BCD8-2E> Saaja: [email protected], Marie Allikmaa - MKM, Kaie Nurmik - MKM Teema: Rohevesiniku võimalused Eestis Tere Lp Oliver Ruus Allolevaga vastan teie küsimustele. 1. Rohevesiniku tootmise võimalused Eestis * Millised on teie hinnangul suurimad võimalused ja eelised rohevesiniku tootmiseks Eestis? Rohevesiniku toomist Eestis soodustab meie üleminek 100% taastuvenergiale aastaks 2030 ning loodav vesiniku taristu, mis ühendab Saksamaa Soome läbides Baltikumi. Samuti on olemas potentsiaal kasutada rohevesinikku juhitava energiatootmise kütusena, millega tagada varustuskindlus tuule- ja päiksepaistevabadel perioodidel. * Milliseid tehnoloogiaid ja meetodeid nähakse Eestis kõige sobivamate ja realistlikemate lahendustena rohevesiniku tootmiseks? Riigi eesmärk on toetada läbi meetmete ja poliitikate rohetehnoloogia kasutuselevõttu, kuid lõpliku valiku ja otsuse tegemine jääb ettevõtjale. Meie huvi on, et ettevõtted teeksid maksimaalselt kasumliku otsuse, mis panustaks ka maksimaalselt meie kliima-eesmärkidesse. 2. Väljakutsed ja takistused: * Millised on suurimad takistused ja väljakutsed, millega Eesti võib rohevesiniku tootmisel silmitsi seista? Esiteks kuulub riskide hulka energiahind. Kui Põhjamaades on energia oluliselt odavam, kui meil, siis võib meie tootmine olla vähem konkurentsivõimeline. Samuti puudub meil hetkel siseturg, mis juba tarbiks vesinikku. * Kuidas on plaanis ületada regulatiivsed ja tehnilised takistused, et vastata ELi nõuetele ja saavutada soovitud kasvuhoonegaaside heitkoguste vähendamine? Kliimaeesmärgid toob ära kliimakindla majanduse seadus. Sellega saab tutvuda siin: Kliimakindla majanduse seadus | Kliimaministeerium <https://kliimaministeerium.ee/eesti-kliimaseadus> 3. Rahvusvahelised standardid ja koostöö: * Kuidas näete Eesti rolli rahvusvahelistes vesiniku tootmise ja standardiseerimise protsessides? Meie huvi on, et IPCEI projektide raames saaksid ka Eesti ettevõtted võrdselt koheldud ning areneksime eesrindlikult saavutades oma potentsiaali. * Milliseid koostöö võimalusi ja -projekte näete olevat olemas või arendamisel, mis toetaksid Eesti rohevesiniku tootmise eesmärke? Eelmainitud IPCEI projektid, lisaks näiteks taksonduse ja transpordi vesinikule minek. Samuti vesiniku energiasalvestina kasutamine. Täpsemalt kaks suunda: sisetarbimise tekitamine, ekspordivõimekuse loomine. 4. Majanduslikud ja keskkonnaalased mõjud: * Milliseid majanduslikke ja keskkonnaalaseid mõjusid ennustate rohevesiniku tootmisele Eestis? Üks ühiskondlikult käegakatsutav lahendus on ühistranspordi ja taksode vesinikule üleminek, mille mõjude arvutuste metoodikat leiab siit https://www.riigiteataja.ee/akt/102072021012 lisade sektsioonist. https://kik.ee/et/projektid/tallinna-rohevesiniku-tervikahel * Kas on olemas uuringuid või analüüse, mis toetavad rohevesiniku tootmise laiaulatuslikku rakendamist Eestis? Eesti vesiniku teekaart: https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&ved=2ahUKEwjpn_2w_-SGAxV_FBAIHcjqAcIQFnoECAYQAQ&url=https%3A%2F%2Fkliimaministeerium.ee%2Fmedia%2F9265%2Fdownload&usg=AOvVaw2cUYGgMzcu2P6DuHdbm1ic&opi=89978449 <https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=&ved=2ahUKEwjpn_2w_-SGAxV_FBAIHcjqAcIQFnoECAYQAQ&url=https%3A%2F%2Fkliimaministeerium.ee%2Fmedia%2F9265%2Fdownload&usg=AOvVaw2cUYGgMzcu2P6DuHdbm1ic&opi=89978449> Vesiniku teemaleht: Vesinik | Majandus- ja Kommunikatsiooniministeerium (mkm.ee) <https://mkm.ee/energeetika-ja-maavarad/taastuvenergia/vesinik> Parimate soovidega Kaspar Peek tööstusvaldkonna juht Ettevõtluse osakond Majandus- ja Kommunikatsiooniministeerium 51931015 [email protected] <mailto:[email protected]> www.mkm.ee <https://www.mkm.ee> | Suur-Ameerika 1, Tallinn Saatja: [email protected] Saaja: "MKM info" Teema: Rohevesiniku võimalused Eestis Kuupäev: 2024-06-05 07:48 Tähelepanu! Tegemist on välisvõrgust saabunud kirjaga. Tundmatu saatja korral palume linke ja faile mitte avada. Tere, Loodan, et teil läheb hästi. Olen tutvunud dokumendiga, mis käsitleb Euroopa Liidu poolt kehtestatud nõudeid rohevesiniku ja selle derivaatide tootmise kohta. Dokument sisaldab põhjalikku analüüsi kahest Euroopa Komisjoni delegeeritud määrusest, mis täpsustavad, millistel tingimustel võib rohevesiniku tootmiseks kasutatavat elektrit lugeda täielikult taastuvaks ja kuidas hinnata kasvuhoonegaaside heitkoguste kokkuhoidu. Dokument tõstab esile mitmeid olulisi aspekte, nagu täiendavuse, ajalise ja geograafilise korrelatsiooni põhimõtted ning vajaduse täiendavate taastuvenergiaallikate järele. Lisaks kirjeldatakse seal võimalusi ja väljakutseid, mis kaasnevad rohevesiniku tootmisega väljaspool ELi, sealhulgas andmete kättesaadavus ja sobivus kohalike regulatsioonidega. Olen huvitatud teie nägemusest ja kommentaaridest järgmistes küsimustes: 1. Rohevesiniku tootmise võimalused Eestis: * Millised on teie hinnangul suurimad võimalused ja eelised rohevesiniku tootmiseks Eestis? * Milliseid tehnoloogiaid ja meetodeid nähakse Eestis kõige sobivamate ja realistlikemate lahendustena rohevesiniku tootmiseks? 2. Väljakutsed ja takistused: * Millised on suurimad takistused ja väljakutsed, millega Eesti võib rohevesiniku tootmisel silmitsi seista? * Kuidas on plaanis ületada regulatiivsed ja tehnilised takistused, et vastata ELi nõuetele ja saavutada soovitud kasvuhoonegaaside heitkoguste vähendamine? 3. Rahvusvahelised standardid ja koostöö: * Kuidas näete Eesti rolli rahvusvahelistes vesiniku tootmise ja standardiseerimise protsessides? * Milliseid koostöövõimalusi ja -projekte näete olevat olemas või arendamisel, mis toetaksid Eesti rohevesiniku tootmise eesmärke? 4. Majanduslikud ja keskkonnaalased mõjud: * Milliseid majanduslikke ja keskkonnaalaseid mõjusid ennustate rohevesiniku tootmisele Eestis? * Kas on olemas uuringuid või analüüse, mis toetavad rohevesiniku tootmise laiaulatuslikku rakendamist Eestis? Teie kommentaarid ja teadmised oleksid hindamatud, et paremini mõista rohevesiniku tootmise tulevikuvõimalusi ja väljakutseid Eestis. Ette tänades, Oliver Ruus Innotech Advisory OÜ