Wet jaarverplichting hernieuwbare brandstoffen van niet-biologische oorsprong in de industrie

Reactie

Vraag1

STX recognizes the current mix of production subsidies, annual obligations, and demand subsidies as a well-structured approach that reflects the Netherlands' leadership in renewable hydrogen policy. This combination effectively addresses key challenges, such as scaling up production, stimulating demand, and providing market certainty, while fostering the development of a robust renewable hydrogen market.
However, further refinement is necessary to fully unlock the potential of RFNBO units, particularly by addressing the tradability of HWI-WDs. The non-tradability of HWI-WDs is primarily linked to issues exclusive to ammonia as a hydrogen carrier. To optimize market efficiency and compliance generation, STX strongly recommends differentiating HWI-WDs based on carrier types (e.g., e-methanol and e-methane). This differentiation would:
• Promote Tradability: Enable the seamless integration of e-methanol and e-methane into compliance markets, allowing the free market to find the lowest path to compliance, and accelerating the adoption of renewable hydrogen carriers.
• Ensure Market Integration: Allow carriers with fewer infrastructural or market constraints to contribute to policy objectives without being hindered by challenges unique to ammonia.
STX advocates for the recognition of HWI-WDs tied to e-methanol and e-methane as tradable assets. Should the government maintain restrictions on the tradability of specific HWI-WDs, it is imperative to provide clear and robust justification, particularly for carriers beyond ammonia. Such justification should detail how these restrictions align with the broader goals of scaling renewable hydrogen and achieving EU climate targets.
By introducing differentiated treatment for HWI-WDs, the government would enhance market dynamics and support carriers like e-methanol and e-methane that are better suited for rapid adoption. This approach would not only optimize compliance generation but also play a pivotal role in meeting renewable hydrogen objectives while maintaining the Netherlands' leadership in the global energy transition.

Vraag2

A higher annual obligation, when coupled with supportive measures like production subsidies and infrastructure investments, can drive increased RFNBO consumption. However, the risk of scaling down or relocation exists, particularly for industries operating in competitive international markets. To mitigate this:
• Ensure competitive pricing for RFNBOs through subsidies and market mechanisms.
• Offer flexibility mechanisms that address the diverse needs of industrial users and extending the tradability of HWI-WD to e-methanol and e-methane could contribute to this.

Vraag3

STX commends the proposed draft annual obligation as a significant step toward decarbonizing industry through the consumption of RFNBOs supported by tradable units. This proposal reflects the Netherlands’ commitment to innovation in renewable hydrogen policy and its leadership in the global energy transition. However, there are opportunities for refinement to maximize the potential of RFNBOs and ensure the framework fully meets its objectives.
A key area for improvement lies in addressing the non-tradability of HWI-WDs. This issue is predominantly linked to challenges specific to ammonia as a hydrogen carrier. To optimize market efficiency, compliance generation, and broader policy goals, STX strongly recommends differentiating HWI-WDs based on carrier types, such as e-methanol and e-methane. This approach would:
• Promote Tradability: Recognizing e-methanol and e-methane HWI-WDs as tradable assets would facilitate their seamless integration into compliance markets, helping to accelerate industry adoption and meet renewable hydrogen obligations effectively.
• Ensure Market Integration: Differentiated treatment would enable carriers with fewer infrastructural or market constraints to contribute directly to compliance targets, avoiding delays or inefficiencies caused by challenges unique to ammonia.
STX emphasizes the importance of clear and robust justification if the government chooses to maintain restrictions on the tradability of specific HWI-WDs. Any justification should address not only the issues related to ammonia but also the rationale for including other hydrogen carriers, such as e-methanol and e-methane, under the same constraints. This transparency is critical to ensuring alignment with the broader goals of scaling renewable hydrogen adoption and achieving EU climate targets.
By incorporating a differentiated approach for HWI-WDs, the government would significantly enhance market dynamics and support the rapid adoption of hydrogen carriers that align with policy goals. This refinement would optimize compliance mechanisms, unlock the full potential of RFNBOs, and ensure the Netherlands continues to lead in decarbonizing industry and fostering a resilient, low-carbon future.

Vraag4

Taking the logic applied to the road transport industry, the price of an HWI-W will be set at the marginal ton produced, i.e. the highest price that still has a home in the market. For derivatives of hydrogen, the logical price would be to calculate the alternative, i.e. using the grey molecule and buying tradable HWI-Ws. Despite inefficiencies in conversion, hydrogen derivates are expected to be substantially lower cost to produce than hydrogen, owing to the fact they are more easily transported and therefore can be produced in areas with abundant low-cost renewable power. Where an obligated party has the flexibility to consume a derivative in place of hydrogen they would – however this is unlikely to be operationally possible today. Not accounting for carbon, hydrogen is more expensive than methane or methanol. Therefore today if an entity could use an alternative to hydrogen they would, and therefore wouldn’t face an obligation.