Hydrogen and Additionality
Position paper in relation to delegated act RED II Art. 27.3
WaterstofNet, as coordinator of the Benelux Hydrogen Industry Cluster (WIC), calls on the Commission to suspend all requirements laid out in this Delegated Act until an Impact Assessment has been made. To avoid slowing down the roll-out of pioneering electrolysers, we urge the Commission to exclude installations built before 2030 from the requirements for their entire lifetime, or, at least, to extend the grandfathering clause to the contents of the transitional clause (monthly temporal correlation) and to projects built before 2030 instead of 2027. A review of the Delegated Act by 2030 could then re-evaluate the need for and impact of the delegated act based on experiences from the first projects. Additionally, a general exception for small installations (e.g. up to 25 MW) for compliance with all rules should be considered, because the administrative burden would be disproportionately large for smaller projects, especially compared to the relatively small impact on the energy mix and its emissions.
In the paper, it is explained why the Delegated Act in its current form forms a significant burden to the roll-out of hydrogen production facilities in Belgium in particular. In addition, we are already formulating concrete recommendations to adjust various points in the case of an adapted proposal for the Delegated Act (after impact assessment) in order to achieve a workable implementation of additionality, taking into account the specific preconditions for renewable energy production in Belgium.
About WaterstofNet
Hydrogen network
WaterstofNet unites the hydrogen industry in Flanders and the Netherlands via the Waterstof Industrie Cluster. Together with industrial partners, WaterstofNet initializes and develops hydrogen projects. The cluster also aspires to facilitate thorough knowledge sharing, acting as a representative mouthpiece that addresses authorities.
Hydrogen knowledge centre
WaterstofNet drafts roadmaps and works on studies involving hydrogen for companies.
From the many corporate contacts and our project experience, unique knowledge has emerged that is safeguarded, valorised and unlocked by WaterstofNet. For matters involving hydrogen, we serve as the point of contact for governments, authorities, companies and the broad public. Through our own educational range and the organisation of congresses on hydrogen, we ensure knowledge about hydrogen is properly disseminated.
Realisation of projects
WaterstofNet develops and realises projects. Over the past ten years, WaterstofNet, together with industrial partners, knowledge institutions and governments, has coordinated and realised multiple hydrogen projects. This has led to hands-on experience and concrete achievements in Flanders and the Netherlands that prove the technology works.
Advisor to Government
WaterstofNet is a partner of the Flemish and Dutch governments in the realisation of their goals involving hydrogen. We are a preferred point of contact for the Flemish and Dutch governments in relation to their hydrogen visions and legislation, supporting them with solid policy wherever possible.
The four pillars supporting WaterstofNet
WaterstofNet
Mission
WaterstofNet is a knowledge and collaboration platform. We aim to contribute to a carbon-neutral society by supporting and realising hydrogen projects in Flanders and the Netherlands. Together with the industrial sector and the government, we enable concrete achievements in the field, laying the basis for further collaboration. By doing so, we assist in the further development of Flanders and the Netherlands as leaders in hydrogen.
Vision
Sustainable hydrogen will play a key role in the decarbonisation of our community. It can contribute to zero-emission transport and function as a sustainable raw material for industry, as a means of energy storage and a carbon-free source for heat.
Flanders and the Netherlands host a unique value chain of companies and research institutes that are active in the field of hydrogen. As a knowledge and collaboration platform, WaterstofNet acts as a catalyst for this ecosystem in the further realisation of a hydrogen economy.
