Renewables developers, spearheaded by Iberdrola and trade body WindEurope, and a host of data analytics firms including Google have co-signed an open letter to the EU demanding new regulations with the strictest controls on how green hydrogen is produced, including an hour-by-hour accounting of renewable power supply to electrolysers.

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The companies believe that new software — some of which is under development by the letter’s signatories — can make hour-by-hour accounting more achievable.

The letter comes after the European Parliament scrapped its last set of draft regulations (proposed in a delegated act) due to lobbying from the hydrogen sector — which later came together to demand a second delegated act with monthly temporal accounting.

But according to Google and Iberdrola, hour-by-hour accounting is necessary to shore up green hydrogen’s renewable credentials and keep emissions down, citing a recent study from the Florence School of Regulation (FSR) that found that the cost of hour-by-hour accounting rises by just 4% compared to annual accounting.

The temporal accounting should be introduced after a phase-in period, the signatories said.

These regulations must be present alongside strict additionality rules — requiring green hydrogen producers to source power from new renewables capacity only — and “geographic correlation” stipulating that these power sources must be located close to the site of green hydrogen production, the group says.

'Achieveable'

And another working paper from Princeton University cited in the letter found that hourly temporal correlation added just $1kg to green H2 production compared to no regulation at all, and that reducing the temporal regulation would actually raise emissions from electrolytic hydrogen production above that of grey hydrogen made with fossil gas.

This appears to be because the extra load on the electricity system — for which California was used as an example in the Princeton modelling — would incentivise extra coal fired power capacity to come online.

In September, trade body Hydrogen Europe warned that hourly temporal correlation would require “hundred and thousands” of gigawatt-hours of battery storage attached to new renewables projects so that developers can run their electrolysers at high loads. The levelised cost of hydrogen reduces the more hours an electrolyser is in operation.

Daniel Fraile, Hydrogen Europe’s policy officer, told the Recharge Hydrogen Summit that the rule would double the cost of green hydrogen production, making projects unviable. Monthly correlation, on the other hand, would be possible without storage.

The FSR study, which used Germany as a template for its modelling, claims that hourly temporal correlation can be done without battery storage, using hydrogen storage instead at an added cost of up to €0.3/kg ($0.3/kg).

The Google-Iberdrola letter claims that temporal correlation is now “more achievable” with the development of “granular guarantees of origin”, certificates that use real-time energy data to verify electricity use (what power source an electrolyser is using and when) and carbon emissions.

Significantly, the letter, which was co-signed by renewable energy developers EDP and Eneco, was also signed by a variety of energy data analytics and emissions verification firms, including Energy Tag, Flexidao, Electricity Maps and Granular.

Google, one of the top signatories to the letter, is participating in Energy Tag, an initiative with EU funding that is developing hourly electricity accounting certificates. Other companies involved in the scheme include Microsoft, Engie, Statkraft and Ovo.

But the letter does not appear to have the support of the wider hydrogen industry —in fact the only notable hydrogen producer among the signatories is renewables giant Iberdrola, which is developing multiple H2 projects across Europe.

And the message on temporal correlation appears to directly contradict the position of the Renewable Hydrogen Coalition — of which Iberdrola and WindEurope are founding members — which with Hydrogen Europe has called for phased-in monthly accounting.

However both Hydrogen Europe and the Renewable Hydrogen Coalition, have previously stated that additionality is essential to prevent H2 “cannibalising” the renewables supply.

The signatories also urge the EU to make haste in finalising regulation, a sentiment that is shared by many in the H2 industry, warning that further delay risks the EU falling short on its targets of sourcing 20 million tonnes of green hydrogen by 2030.

“Without the Delegated Act, investment decisions for new electrolysers and associated renewable energy could be delayed by years, which will put delivery of the EU’s 2030 renewable hydrogen targets at risk,” the letter said.