Bewertung der Nachhaltigkeitsanforderungen der RED

Zum Forschungsvorhaben: Kriterien für eine nachhaltige Bereitstellung und klimagerechte Integration von strombasierten Energieträgern. Teilbericht

Authors: Horst Fehrenbach, Thomas Fröhlich

Huge expectations are placed on electricity-based renewable energy sources such as green hydrogen and its derivatives in terms of their future role in climate protection and the transformation of energy system, industry and mobility. At the same time, the issue of environmental effects and overall sustainability is rarely discussed. This brief paper analyses the extent to which the legally binding rules of the Renewable Energy Directive in its new versions (RED II and RED III) and the associated Delegated Regulations set requirements for greenhouse gas reductions and sustainability for electricity based hydrogen and hydrogen derivatives.

While RED II already requires a minimum GHG reduction of 70 % compared to fossil fuels, it did not originally contain any information on the calculation methodology. This was done with the publication of the Delegated Regulation (EU) 2023/1185 in 2023. As part of this brief paper, a number of exemplary pathways for electricity-based renewable energy sources were calculated.

These show a considerable range regarding the GHG reduction results. The Delegated Regulation (EU) 2023/1184 provides central regulations for proving the renewability and additionality of electricity. Both regulations deal with complex issues and raise questions regarding their concrete application.

The brief paper therefore concludes with a list of critical aspects and shortcomings. For example, there is a clear inconsistency between the strategic objectives from the policy (e.g. National Hydrogen Strategy) and the quota obligations of RED III for electricity-based renewable energy sources as well as the forecasts for a realistic ramp-up. Within the framework of RED III and the Delegated Regulations it is criticized that a) allowance of long transition periods with regard to the obligation for renewable electricity and b) inconsistencies with regard to the restriction of electricity from biomass and electricity from non-renewable sources. A major point of criticism is a lack of sustainability criteria beyond the criteria of renewability and GHG savings. Furthermore, it is worth criticising the fact that the requirement for GHG reduction of at least 70%, which has been in place since 2018, is not being developed in the course of the transition to GHG neutrality.