Advice Netherlands Environmental Assessment Agency on SDE ++

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Advice Netherlands Environmental Assessment Agency on SDE ++

North Sea Port and Smart Delta Resources have jointly provided a written response to the SDE ++ consultation this summer. The reaction was also elucidated by North Sea Port and SDR in a discussion with the Netherlands Environmental Assessment Agency. The most important comments on the advice relate to the SDE ++ deployment for CCS and hydrogen electrolysis.

Comments on electrolysis consultation

  • Calculating with the expected CO2 emission factor for electricity from the grid in 2030 results in a negative emission factor. Based on a final picture of 100% renewable electricity towards 2050, this is unwise. This assumption will delay the development of hydrogen production via electrolysis. Moreover, when the production of hydrogen is increasingly connected directly to renewable sources, the assumption of the CO2 emission factor for electricity from the grid is no longer correct.
  • For industrial applications, hundreds of MWs must be taken into account rather than tens. In coordination with ISPT, work is being done within the SDR region, for example, on an exploration study into the integration and realization of a 1 GW plant.
  • To what extent are cross-border projects taken into account, especially if the CO2 reduction takes place in the Netherlands? The industry within North Sea Port does not stop at the national border. The exchange of flows, including heat, hydrogen and CO2, will increasingly have to take place in the future in order to realize climate objectives cost-effectively.

Comments CCS-consultation

  • The processing surcharge that represents the costs for transport and storage is based on the Porthos project in Rotterdam. To open up the relatively cost-effective potential from the industrial complex within North Sea Port and to guarantee a level playing field, the processing surcharge will also have to compensate for transport from North Sea Port to Porthos (whether or not in a separate category).¬†
  • Together with the ports of Rotterdam and Antwerp, North Sea Port has applied for PCI status for the development of a joint¬†CCS project. This is based on connection to the Porthos network. This initiative must therefore be fully integrated into the design of the SDE ++ by compensating for the costs of transport to the Porthos network from North Sea Port. The industrial complex within North Sea Port will not be able to achieve the Paris climate targets without CCS. Moreover, CCS can be applied relatively cost-effectively in this region.
  • Linking industry within North Sea Port to Porthos through a pipeline network is a realistic and necessary option. Simply assuming requests from parties involved with Porthos and Athos is a far too narrow focus. Because the scheme is based on Porthos and Athos, an uneven playing field arises at a Dutch level. Firstly, the industry within North Sea Port will not be able to meet the climate targets. Moreover, a competitive disadvantage arises because ETS rights still have to be paid without CCS (not to mention a possible national CO2 tax). It is up to the national government to prevent such imbalances in policy.
  • It is advisable to add a category to the SDE ++ for transport by ship to storage locations such as Porthos in Rotterdam and Northern Lights in Norway. This form of transport offers flexibility and in some situations can be applied more cost-effectively than transport by pipeline. Moreover, the necessary European legislation and regulations will also have to be adjusted for this.