The Green Hydrogen call for evidence
To be submitted by email. Deadline 29th March.
The Renewable Energy Association (REA) is pleased to submit this brief response to
the above consultation. The REA represents a wide variety of organisations,
including generators, project developers, fuel and power suppliers, investors,
equipment producers and service providers. Members range in size from major
multinationals to sole traders. There are over 800 corporate members of the REA,
making it the largest renewable energy trade association in the UK and the only
body to cover all forms of energy.
The REA has a keen interest in energy storage, and its role in the integration of
intermittent renewables. This response is submitted jointly by the REA’s UK Storage
and UK Solar Groups.
Q1 Should the Standard cover heat, power, transport and other hydrogen
applications? What sectors should it cover beyond these?
Yes. If the standard covers the carbon emissions embodied in the production and
transport to point of use of hydrogen as we advise, then all potential end use sectors
would be covered.
Q2 What is your view on the usefulness of the standard making assessments at Point
of Use (PoU) or Point of Production (PoP)? Does this vary by end use? For example,
might we require a different approach for hydrogen used in transport?
The carbon content of the hydrogen should be measured at the point of use , i.e.
taking into account the carbon involved in compression and transportation. There is
no logic to having different standards for different end uses.
There are two ways in which green hydrogen can be distributed;
 via injection into the natural gas distribution network (in which case it
contributes to the decarbonisation of grid gas) or,

transported, e.g. by truck, in the form of H2.
In the case of H2 that is injected into the grid we propose that emissions involved in
transportation beyond the point when it is added to the grid are assumed to be zero.
It could be argued that H2 having a lower calorific value than methane will entail
more energy input in pumping through the network, but because of the equivalence
principle, explained below, in reality it will be used at the point of closest demand
rather than transported any particular distance.
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Changes to biomass grandfathering RO policy consultation – REA response
Unlike renewable energy which is primary energy source hydrogen is a carrier of
energy or energy vector. As such it does not make sense to reward its production by
subsidising it. However, if hydrogen is produced from low carbon energy sources,
then the end user of that hydrogen should benefit from the fact that it is using a low
carbon energy fuel. E.g. it should be beneficial in companies’ greenhouse gas
reporting and exempt from levies that apply to carbon-containing fuels.
It is therefore important, that end users of green hydrogen can demonstrate that
they are using a green fuel and that green hydrogen is not double-counted. In the
case of green hydrogen injected into the natural gas grid, the only way that end
users can claim to be using green hydrogen is on the equivalence principle i.e. 1KWh
of green hydrogen put in the grid at location X should be equivalent to 1kWh-worth
of gas taken out of the network at location Y. The link between production and end
use should be via certification. Renewable Energy Assurance Limited runs a Green
Gas Certification Scheme which could be adapted to that purpose. (The GGCS has
submitted a response to this call for evidence, which we are fully supportive of.)
Q3 Assuming that regardless of whatever carbon intensity threshold is set by the
Standard, some production will involve blending ‘brown’ hydrogen with ‘green’ in
such a way as to meet the Standard, how should we account for this when defining
the system to be assessed?
If hydrogen is blended such that the end product achieves the standard, then the
full volume of gas should be regarded as green. For example, if the standard is
150gCO2/kWh H2 then1kWh of “brown” hydrogen at say 300gCO2/kWh was blended
with 2 kWh of 75g CO2/kWh green hydrogen then the resulting 3kWh would have an
intensity of 150gCO2/kWh and so it would qualify as green.
Q4 How should grid electricity used to produce hydrogen be treated within the
Standard, given its temporal variation?
If hydrogen produced from grid electricity is being blended with green hydrogen to
achieve certain carbon intensity, then for the sake of pragmatism, the grid electricity
should be regarded as having the yearly average grid carbon content. This carbon
content changes year on year, as the grid carbon intensity falls. Therefore greater
use of grid electricity can be made as time passes. Greater average utilisation across
life helps plant economics. This should replicate the approach taken in the
Renewable Energy Directive for electric transport.
However, more importantly, one of the major values of green hydrogen as its role in
assisting with the integration of greater amounts of renewables. Renewable
electricity cannot be accommodated onto the network at certain times and
generation has to be curtailed. This (along with periods where negative pricing
might be expected to occur) will increase as the proportion of intermittent
renewables on the network increases. Put another way, high penetrations of
renewables will not be achieved unless new demand (such as green hydrogen
production) is created to ensure renewable power can be usefully employed no
matter when the generation occurs.
When the production of H2 is timed to coincide with periods when extra demand is
required on the network, this electricity should be regarded as zero carbon. The
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Changes to biomass grandfathering RO policy consultation – REA response
generation of hydrogen (or synthetic natural gas derived from this hydrogen and
waste CO2) and its injection into the grid can be seen as a form of electricity storage.
The inertia of the gas network is vastly greater than that of the electricity network. In
other words matching supply and demand is far more forgiving. H2 injected onto the
gas network does not require a simultaneous increase in gas demand in order to stay
in balance. Instead it enables less natural gas to be released from storage onto the
network.
This simultaneous increase in electricity demand from electrolysis at times of excess
electricity supply would ideally be distributed geographically, so that localised
incapacity of networks is not an issue. (This applies both to electricity networks and
gas networks which can only accommodate a certain percentage of H2 mixed with
the CH4).
Thus it is crucially important to consider the temporal aspects of grid electricity. In
order to prevent curtailment, production over a certain contractually-set capacity
limit will need to be absorbed by electrolysis. The capacity limit for renewables
plants would be set according to their connection agreements with the DNO or grid
operator. An electrolysis plant (or an aggregated group of electrolysers in a region)
would need to be able to absorb the excess production from a number of local
renewables projects at times when their output would otherwise be curtailed. The
operation of the electrolysis plant can correspond to the needs of grid and network
operators.
Q5 How should hydrogen produced using a low carbon electricity source via private
wire be treated?
The actual carbon intensity of the power delivered by the private wire should be
used. E.g. if the private wire is transporting electricity produced by a renewable
energy source it will be zero carbon, if from a fossil fuel then it should be regarded as
having the carbon intensity relating to that fuel source.
Q6 Should hydrogen produced as a by-product of industrial processes be included
within the standard? If yes, how should we define system boundaries for reasonable
allocation of its carbon footprint?
If this H2 would have been produced any way, then use of this H2 is to be
encouraged.
Industrial processes, such as the chlor-alkali process use the hydrogen within the
process, thereby offsetting the use of an alternative (in this case natural gas). It
makes more sense to use this hydrogen within the process than to export it to other
markets. It could not be regarded as green if exported, because of the increased
carbon emissions entailed in replacing its use within the industrial process.
Q7 which industrial processes produce hydrogen as a by-product in useful
quantities?
No comment.
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Changes to biomass grandfathering RO policy consultation – REA response
Q8 How should biomass used to produce hydrogen be treated under the Standard?
This should be treated as low carbon, provided it is from sustainable sources. The
Renewable Energy Directive definition of sustainability should be used.
Q9 Should one carbon intensity threshold apply to green hydrogen irrespective of its
application?
Yes.
Q10 Is there a risk that a single threshold will exclude hydrogen produced from fossil
fuels from the Standard, when that hydrogen may represent a CO2 saving compared
to another fuel?
Yes, but this is entirely reasonable. Why should an energy vector be regarded as
green regardless of the carbon intensity of the energy used to produce it?
In reality it is unlikely to deliver any carbon saving, as energy will be involved in
converting it to hydrogen, and further energy lost in its conversion to electricity.
Q11Should the Standard be set using an increasingly tighter trajectory of allowable
emissions?
In our opinion, no. Obviously the carbon value assigned to regular grid electricity will
need to be adjusted as it is slowly decarbonised. Regular in this sense means
electricity which is not low carbon on account of its special temporal nature – i.e.
when used to help integrate additional renewable energy generation).
Q12 If yes, how should this trajectory be set? With reference to just our 2050 target or
with reference to intermediate Carbon Budgets too?
N/A
Q13 What is an appropriate emissions level to begin at?
We are not qualified to suggest a number, but on principle it should be a value
significantly lower than that of natural gas, but not so low as to stifle the
development of the market.
Q14 What is an appropriate emissions level to target, and when should the target be
hit?
In our view it would be premature to have a decreasing trajectory. It could be
reviewed after, say, 10 years of operation of the standard.
Q 14 Which technologies should the Standard cover in its first iteration? These should
be the technologies that are currently most widespread or have the most significant
potential in the very near term.
Any technology that can produce hydrogen at embodied carbon levels below the
standard should be covered. In other words the standard should be technology
blind and not stifle innovation.
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Changes to biomass grandfathering RO policy consultation – REA response
We appreciate that there may be work entailed in developing a methodology
against which to test hydrogen produced via different technologies, and for this
reason suggest starting with the electrolysis of water.
15. Which developing technologies should the Standard look to include in its later
iterations?
Neither UK Storage nor UK Solar are qualified to comment on this.
16. Beyond carbon emission reduction, should the Standard look to include other
benefits within its first iteration, such as a reduction in airborne particulate matter?
No. Hydrogen may well emit fewer particulates, but as a principle, airborne pollution
is regulated by the Environment Agency or local authorities. There is no merit in
making the standard more complex by the inclusion of other parameters.
17.
If yes, how should these benefits be factored in?
N/A
Q 23 Would it be an advantage to have a single EU standard, even if it was not
technology neutral? Is international consistency important or could the UK develop a
better Green Hydrogen standard?
A single EU standard would be the ideal. The UK’s Green Gas Certification Scheme is
a member of a group of European certification schemes which are developing the
foundation for cross-border biomethane trade in Europe. In theory these other
schemes could just as easily incorporate green hydrogen.
Q 24 How should we treat imported H2 if there is not a common agreed EU or
international standard??
“Import” of green hydrogen would best be done according to the equivalence
principle, so avoiding the emissions associated with compression and transportation.
The registries project referred to above would be the ideal place to explore this.
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