Sfen’s Response to the European Consultation on the Draft Methodology for Low-Carbon Hydrogen Production
Hydrogen plays a crucial role in decarbonisation efforts. The French Nuclear Society (Sfen) has therefore reviewed the draft delegated regulation proposed by the European Commission, currently under consultation, aimed at establishing a methodology for low-carbon hydrogen production.
Low-carbon fuels can play a role in the energy transition, especially in the short and medium term, as they emit fewer emissions than existing fuels and promote the adoption of renewable fuels. The European Union (EU) has established a certification process to ensure that low-carbon fuels indeed reduce emissions in practice.
This delegated regulation defines the methodology for calculating greenhouse gas (GHG) emission reductions for low-carbon fuels. It is based on a life-cycle analysis of the total GHG emissions of these fuels.
The European Commission has launched a call for comments on this draft. Sfen has contributed to this consultation, highlighting the following key points:
- Operating Hour Limitations for Electrolysers: The European Commission is considering time-based restrictions on electricity use in certain production processes, which could impact the competitiveness of clean hydrogen in France. Most studies conclude that a continuous electricity supply (over 7000 hours per year) is the optimal operational mode to make clean hydrogen more competitive.
- Uncertainties Related to Small Modular Reactors (SMRs): Postponing the delegated act to 2028 concerning electrolyser operation via alternative pathways, including nuclear power, could delay SMR development due to investor uncertainty. Investors require long-term clarity on SMR applications and associated revenue streams.
- Overestimation of Nuclear’s Emission Factor: The emission factor of 13.09 gCO2 equivalent per kWh used by the European Commission is considered overestimated compared to other studies. For example, EDF estimates that CO2 emissions from nuclear energy are around 3.1 gCO2 equivalent per kWh.