IOGP response to the public consultation on the draft Methodology to determine the greenhouse gas (GHG) emission savings of low-carbon fuels

This document provides IOGP's response to the public consultation on the Hydrogen and Decarbonized Gas Market package. 

Context

This Delegated Act is essential for providing the clarity and predictability needed to scale a hydrogen market in the EU, a key component in achieving the EU's decarbonization targets. It promotes technological neutrality and incentivizes greenhouse gas emission reductions. This methodology is vital for fostering a European market for low-carbon hydrogen and bolstering investor confidence for Final Investment Decisions. However, IOGP Europe has identified certain critical gaps and ambiguous provisions in the current methodology that still need to be addressed.

Key Points

• The methodology should allow the use of the actual values for project-specific elastic inputs in absence of methane intensity methodology.
• The methodology should provide more options for the use of low-carbon intensity electricity when producing low-carbon hydrogen.
• Certification and the use of the Union Database for Biofuels (UDB) should ensure accessibility for importers. Project developers need confirmation that the carbon intensity of feedstocks and low-carbon fuels transported via grids outside the EU will be recognized (based on mass balancing principles).
• Ensure flexibility when demonstrating alignment with EU legislation on CO2 storage in third countries. Certification bodies working under Voluntary Certification Schemes can verify CO2 storage compliance with the purpose of Directive (EU) 2009/31/EC, or alternatively ISO 27914 if national laws don’t align.

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