To summarise the basic principles that should be kept in mind when wanting to use hydrogen for the benefit of the climate:
- Hydrogen is not a source of energy and requires large amounts of electricity to be produced: that electricity must be renewable and additional to avoid it cannibalising the much-needed existing renewable electricity sources;
- Hydrogen should be used in a targeted manner, only where electrification or other more efficient energy vectors are not an option.
Yet, with the two delegated acts on RFNBOs, two main issues emerge:
- a grandfathering clause that allows any hydrogen production facility active before 2027 to benefit from very loose transitional rules for the entirety of its lifetime;
- a loophole that enables hydrogen producers to avoid additionality obligations by cherry-picking from a list of options that opens the door for on-grid production with little to no correlation with actual renewable electricity generation, as well as double counting of used renewable electricity by choosing the most profitable accounting system on an hourly basis.
Together with several NGOs, Bellona calls on the Commission to ensure that the strict principle of additionality be upheld in the Delegated Acts.