EU Renewable Hydrogen (RFNBO)
The recently released EU delegated act 1 covers the next generation non biological transport fuels produced from renewable energy sources such as solar, wind and hydro.
The second Act covers Recycled Carbon Fuels (i.e. fuels made from non-recyclable waste and industrial waste) and also provides a methodology to calculate GHG emissions for both types of fuels.
These delegated acts since their recent approval are now the mandatory standard to classify a fuel as RFNBO and RCF within the EU states or imported into the EU (along side renewable, biogenic transport fuels which are also covered in RED II).
Principles
3.348 Kg of CO2 / Kg of Hydrogen
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One of the main objectives of this standard is to reduce the transport sector's GHG emissions by 70%.
The standard sets the current emission from comparator fossil fuel as 93g of CO2 per MJ of fuel, thereby setting a threshold limit of 27.9g of CO2 per MJ of fuel.
Well to Wheel
emissions
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Scope 1, 2 and partial scope 3 emissions, both upstream and downstream, need to be taken into account when calculating the total emissions in the fuel production process.
Significantly, downstream fuel distribution and combustion emissions must be accounted for in GHG calculations.
Renewable source of electricity
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RED II, the delegated acts and current technologies means electrolysis is the main pathway for production of Hydrogen or derivative as RFNBO transport fuel.
The electricity for electrolysis must come from one of the following renewable sources
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Solar
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Wind
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Hydro electric (excludes pumped storage)
Direct electricity connection
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Technically, the simplest option.
Compliant hydrogen is produced when renewable electricity is generated.
If there is a grid connection to the facility, it must be kept separate and not used in any part of the fuel production process.
If a storage unit like a battery system is used, this must also be connected directly to the fuel production facility and supply only from a renewable energy connection.
Using the Grid
Options:
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Connected bidding zone grid uses > 90% renewable, on average
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Connected bidding zone grid emissions is <18g CO2 per MJ
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Fuel is only produced when renewable electricity re-dispatch is avoided
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The Additionality route (see below)
Note 1: Temporal and Geographical correlation rules apply to options 2 and 4, see below. Although the other two options also need to demonstrate correlation to the renewable source
Note 2: Renewable PPA required for all options
(4) The Additionality route
The electricity needs of the fuel production facility must be met by a new, renewable electricity generation facility from one of the 3 types mentioned before.
If the fuel production facility becomes operational after 1 Jan 2028:
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This new electricity generation facility must have become operational no earlier than 3 years before the fuel generation plan becomes operational
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No state financial support for operational costs in electricity production (loans okay)
If the fuel production facility becomes operational before 1 Jan 2028, these constraints don't apply until 2038. However, capacity of such sites cannot be augmented after 1 Jan 2028 under this exception.
Geographical correlation rules
Renewable source of electricity generation must happen
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In the same bidding zone
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In an interconnected bidding zone if the price for electricity during the fuel production hours, is lower in the fuel generation bidding zone than the interconnected bidding zone
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Offshore bidding zone interconnected to the bidding zone where fuel production happens
Temporal correlation rules
Until end 2029 - monthly matching
In a month, the total number of hours when electricity was used from a renewable source to produce the fuel must match the total number of hours of renewable electricity produced and supplied to the facility.
Note: national governments may apply stricter requirements
From 2030 onwards - hourly matching
For each hour, the electricity that was used to produce the fuel must match the renewable electricity generated and supplied to the facility
Alternatively (this will most likely only apply for EU member states),
The temporal correlation requirements are met if it can be proved at an hourly granularity, that the price of electricity was less than either 20 EUR per MWH, which rules out production of fuel using fossil sources or 0.36 times the price of an allowance to emit 1 ton of CO2 equivalent
LifeCycle Emissions
Scope 1
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Fuel production facility’s carbon emissions for all activities
Scope 2
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Emissions intensity of 3rd party supplied energy (electricity) to the facility
Scope 3
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Upstream emissions from 3rd party supply raw materials such as water, alkaline, etc
Upstream emissions in raw material supply process
Downstream emissions in the distribution of fuel from the fuel production facility to the end user
Carbon emissions during end user combustion (in case of hydrogen, ammonia)
All GHGs listed in RED II need to be accounted for
Other
No Financial Support
The renewable electricity generation facility or the fuel production facility must not receive any state financial support towards its operating costs, except loans that are paid back and support towards initial facility setup or restart support.
Mass Balancing
The scheme will use a 'mass balancing' system with transaction records captured in EU wide data base as well as national databases.
Certification
Certification of compliance is required from a recognised, voluntary schemes. If a scheme is recognised by the commission, the member states are obliged to accept such certificates without any additional requirements.
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Capacity Extensions
Extensions within 3 years of the main facility going operational are treated as if this additional capacity were existing at the start.
For example: new PPA requirements for the extra capacity are not required.
Important: See exception under additionality.
References
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Directive 2018/2001 (RED II) - 32% renewables target for 2030
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EU Rules for Renewable Energy (Feb 2023)
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​​RePowerEU - 45% renewable energy by 2030
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Fit for 55 (RED III) - 55% emissions cuts by 2030
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EU Hydrogen Strategy - July 2020
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EU strategy on energy system integration - July 2020
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EU regulation 2019/943
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EU strategy for low emission mobility - July 2016
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European Green Deal
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EU nations EU National energy and climate plans (NECPs)
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2030 Climate Target Plan
Other
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H2 Global project - importing hydrogen into germany