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.