Hydrogen definitions – an unnecessary source of regulatory risk and uncertainty?
The paper will look at proposed definitions for hydrogen (e.g UK Low Carbon Hydrogen, EU RFNBOs etc.) and how the carbon intensity of hydrogen is measured (e.g. system boundaries, treatment of inputs such as electricity.) It will then consider the implications of this for policy making – in particular focusing on the impact of different rules for the treatment of renewable electricity can have on the carbon content of hydrogen, and how this may impact the development of hydrogen markets. The paper will argue that the current approach of some policy makers (e.g. EU and US) to loosen rules regarding the use of renewable electricity in the early years of their respective schemes risks undermining the development of the hydrogen market by preventing a proper comparison of hydrogen production projects on a carbon intensity basis. The paper will address some of the arguments made by those in favour of such loosening. It will propose an approach which takes account of the nascent state of the hydrogen market whilst maintaining the integrity of carbon intensity measurement.
