Draft Hydrogen Action Plan
1. To what extent do you agree with the roles that hydrogen may play in our future energy mix and the pace of hydrogen uptake as set out in the Hydrogen Economy: route map to 2030 and 2045?
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Fully Agree
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Mainly Agree
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The draft HAP appears to recognise the role of hydrogen in all parts of the energy system including heat, power, transport and industry, as well as in the transport and storage of energy and export of energy.
2. What are your views on the actions themes and key actions identified to support the development of the hydrogen economy over the next 5 years?
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The themes are good, however it could be clearer where the role of regulation and standards resides. Is it in a single theme, or a number of themes? It also needs to be more explicit, as these are crucial aspects.
Also, given that every single fiscal and financial transaction will be based upon a flow measurement, it needs to be clear in which theme consideration will occur of how hydrogen will be measured and traded, including provision of a measurement traceability chain, as per the UK's National Measurement System.
Also, given that every single fiscal and financial transaction will be based upon a flow measurement, it needs to be clear in which theme consideration will occur of how hydrogen will be measured and traded, including provision of a measurement traceability chain, as per the UK's National Measurement System.
3. In your view, is there any further action that we, or other key organisations (please specify), can take to maximise the positive impacts and minimise negative ones on people, communities and businesses in Scotland in support of a just transition to net zero?
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Yes
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No
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Don't Know
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There needs to be more focus in the support mechanisms for hydrogen supply chain companies in Scotland. The support at present is very focused towards those leading the building of hydrogen projects and R&D, which does indirectly filter down to supply chain companies, but in a strongly attenuated way. There is relatively little support directly for supply chain companies to adapt their offering to support the hydrogen economy, and without this, there is a significant risk that a lot of the supply of goods and services will come from overseas, especially the EU.
4. Are there further actions that could be taken by government or industry that you think would drive a reduction in the cost of hydrogen? Please provide evidence to support any suggestions.
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Yes
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No
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Don't Know
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It is not my focus to answer this question.
5. What are your views on the funding principles and scope of the Emerging Energy Technologies Fund? In your view, are there any eligibility and project assessment criteria we should consider as part of the Emerging Energy Technologies Fund?
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As per Q3 above ** there needs to be criteria introduced to ensure that support of supply chain organisations occurs.
**
There needs to be more focus in the support mechanisms for hydrogen supply chain companies in Scotland. The support at present is very focused towards those leading the building of hydrogen projects and R&D, which does indirectly filter down to supply chain companies, but in a strongly attenuated way. There is relatively little support directly for supply chain companies to adapt their offering to support the hydrogen economy, and without this, there is a significant risk that a lot of the supply of goods and services will come from overseas, especially the EU.
**
There needs to be more focus in the support mechanisms for hydrogen supply chain companies in Scotland. The support at present is very focused towards those leading the building of hydrogen projects and R&D, which does indirectly filter down to supply chain companies, but in a strongly attenuated way. There is relatively little support directly for supply chain companies to adapt their offering to support the hydrogen economy, and without this, there is a significant risk that a lot of the supply of goods and services will come from overseas, especially the EU.
6. In your view, what should be the priority areas of focus for the Hydrogen Innovation Fund over the next 5 years?
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Whilst it is clearly a chicken and egg scenario, and as mentioned there needs to care taken to ensure supply and demand grow at similar rates, there should be more priority given to growing demand related to the use of hydrogen in transport. Transport represents a large portion of Scotland's emissions, and electric vehicles are only suitable for some transport needs (e.g. light vehicles, on short journeys, and used infrequently); with hydrogen vehicles representing a much better choice for a large number of transport needs, especially once consumer behaviour is considered realistically for the whole population, rather than the early adopter, climate conscious few.
Also, as greater numbers of electric vehicles start to exist, grid constraints for charging are going to begin to manifest.
If the adoption of hydrogen vehicles is not going to fall disastrously behind, their adoption needs to be accelerated very soon, and very quickly.
The future of transport is a mixture of the two options BEV and HV, one must not be allowed to fail, as this will inhibit the ability to achieve net-zero.
Also, as greater numbers of electric vehicles start to exist, grid constraints for charging are going to begin to manifest.
If the adoption of hydrogen vehicles is not going to fall disastrously behind, their adoption needs to be accelerated very soon, and very quickly.
The future of transport is a mixture of the two options BEV and HV, one must not be allowed to fail, as this will inhibit the ability to achieve net-zero.
7. What are your views on how we can use Scottish Government funding to leverage and encourage private sector and other forms of investment?
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It is not my focus to answer this question.
Strategic Environmental Assessment
1. Do you have any comments on the environmental baseline information referred to in the Environmental Report?
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No
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n/a
2. Are you aware of further information that could be used to inform the assessment findings?
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Yes
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No
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n/a
3. What is you view of the assessment findings?
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Having read the summary of the report only, the findings appear to be balanced, comprehensive (the scope under consideration was admirably broad) and inline with what I expected.
4. Are there other environmental effects arising from the Draft Hydrogen Action Plan?
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Yes
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No
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n/a
5. What are your views on the alternatives considered?
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n/a
6. What are the most significant environmental effects which should be taken into account as the Draft Hydrogen Action Plan is finalised?
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The only thing that seemed curious was the consideration of water usage and slight implication this could be negative, given that Scotland has an abundance of water, and using water for hydrogen is a water cycle anyway. However, the hydrogen is used, it ultimately ends up back as water again, whether used in combustion or through a fuel cell. So the overall amount of water is not being reduced.
7. How can the Draft Hydrogen Action Plan be enhanced to maximise positive environmental effects?
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n/a
8. What do you think of the proposed approach to mitigation and monitoring proposed?
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Reasonable
Partial Business and Regulatory Impact Assessment
1. What are your views on the costs and benefits associated with the publication of the Hydrogen Action Plan for businesses that have been identified within the Partial BRIA?
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n/a
2. Are there any other business and regulatory impacts arising from the Draft Hydrogen Action Plan?
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Yes
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No
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There are impacts related to how hydrogen will be traded/sold (whether domestically or internationally), both in terms of the financial basis and how this will be regulated (measurement accuracy, traceability and calibration requirements for flow measurement devices), and in terms of how the carbon intensity of the hydrogen with be certified.
At present neither has been given explicit recognition within the draft HAP, something that should be rectified.
Whilst Scotland may use the UK's low carbon hydrogen standard (currently under development), this needs to be commented on, along with how other schemes such as CertifHy and CMS 70 (both offered by my organisation TUV SUD) may be used. For the export of hydrogen, harmonisation of certification and use of schemes that satisfy both exporter and importer requirements is crucial.
At present neither has been given explicit recognition within the draft HAP, something that should be rectified.
Whilst Scotland may use the UK's low carbon hydrogen standard (currently under development), this needs to be commented on, along with how other schemes such as CertifHy and CMS 70 (both offered by my organisation TUV SUD) may be used. For the export of hydrogen, harmonisation of certification and use of schemes that satisfy both exporter and importer requirements is crucial.
3. What are the most significant business and regulatory impacts which should be taken into account as the Draft Hydrogen Action Plan is finalised?
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n/a
About you
What is your name?
Name
Dr Martin Hanton
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Individual
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Organisation
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Organisation
TUV SUD UK