Summary • AquaVentus continues to welcome the fact that sufficient sites remain in Zones 4 and 5 to enable the prospect of up to 10 GW of electrolysis capacity at sea. The long planning horizons call for flexibility in sectoral planning here — determinations that are not necessary should be avoided. • AquaVentus further welcomes the fact that the concept of a national and European collector pipeline integrating hydrogen potential from both SEN areas and North Sea riparian states has been made possible, along with the associated option of routing through existing or extendable border corridors. • Site development planning must ensure that hydrogen produced in the SEN-1 area and in further possible SEN areas can be transported into the mainland hydrogen infrastructure. The plans for the hydrogen core network, which provide for the landing point "Wilhelmshaven area", must therefore be incorporated into the FEP. • With the "Wilhelmshaven area" landing point in mind, it makes sense from a planning perspective to connect the SEN-1 area to the mainland as directly as possible and without crossing existing infrastructure. A route for the collector pipeline north-east of the SEN-1 area and running parallel to existing infrastructure suggests itself. Entry into the territorial sea could take place through border corridor N III or, preferably, through a new corridor located east of N III. Exactly how the SEN sites can be connected efficiently can only be answered once the specific delineation of the SEN-1 area is known. • Beyond this we advocate close coordination among all stakeholders within a "development alliance for hydrogen generation at sea". Such a body could address the growing challenges facing projects of this kind and seek approaches to resolving them. Only close cooperation between science and research, industry, policymakers and public administration promises to do justice to the undertaking.
In detail. 1. Long planning horizons call for flexibility in sectoral planning in order to achieve capacity expansion and climate protection targets as effectively as possible
Options for flexibility in the face of future developments • The AquaVentus Förderverein e.V. underlines once again that, in order to achieve the climate protection targets and in the interests of energy security, the limited site potential of the German EEZ in the North and Baltic Seas must be used as efficiently as possible. In this respect it is right that the Site Development Plan makes consistent use of the sea area available for offshore wind expansion. At the same time, however, the FEP's continued planning horizon extending to at least 2037 is exceptionally long and is subject to corresponding technological, economic and regulatory uncertainty. Future developments cannot be reliably accounted for and anticipated today. For this reason, comparable planning documents — such as the Network Development Plan — set out scenarios for how the underlying assumptions may evolve, in order to allow the greatest possible flexibility of response over time. • When determining the further sites in Zones 4 and 5, the potential of hydrogen generation at sea and of potential further sites should also be given adequate consideration. This, however, presupposes a longer and open-ended stakeholder dialogue as well as political steering. From the perspective of AquaVentus it is therefore decisive that the outcome of such a dialogue can feed into the further sectoral planning, so that the necessary determinations can be developed from it.
Thinking and planning together in the face of new challenges • We perceive from the industry side that there are increasing challenges in economic, technological and regulatory terms, so that the situation of possible projects has changed as a result. • This applies both to conventional offshore projects and to projects on the SEN sites. It is essentially external factors that are making project planning and implementation more difficult. These include inflation, cost increases along the value chain, and bottlenecks and gaps in the supply chain. A joint effort by all involved is therefore required, including by policymakers and public authorities, to underpin the objectives of the National Hydrogen Strategy and to enable production and transport on the high seas by supporting the likelihood of realisation through suitable instruments and planning.
Developing the plans further on the basis of concrete and comprehensible modelling • Various studies, such as those by AFRY or DNV, underline the considerable advantages of the concept pursued by AquaVentus of up to 10 GW of electrolysis capacity in the areas of the German EEZ far from the mainland. The speed of expansion is increased significantly, investment costs fall and critical environmental impact is reduced to a minimum. Harnessing these advantages represents a technical, ecological and economic opportunity to make urgently needed green hydrogen available in large quantities and with security of supply through generation at sea. Whether it can be harnessed depends on the regulatory framework. The latitude available under the Offshore Wind Energy Act should therefore be used, and further sites should not be determined prematurely and hastily with regard to energy transport. • Hydrogen generation at sea should not become a competitor to electricity generation at sea. We see the greatest potential precisely in the interplay of these two complementary technologies. • AquaVentus will therefore shortly publish a further study demonstrating the potential of "combined connection concepts" of electricity transport and pipeline. Particularly in view of the challenges in transporting offshore electricity (e.g. prices and utilisation of submarine cables and converters), diversified concepts could achieve greater resilience in offshore wind expansion.
2. Collector pipeline • We welcome the fact that the concept of a collector pipeline for transporting away the hydrogen produced in the other energy areas has found its way into the update of the FEP. Whether the connection of the SEN-1 area and further SEN areas can be realised efficiently and promptly depends on the routing. • In order to keep the intervention in the marine environment as small as possible while implementing the project cost- and time-efficiently, the routing of the AquaDuctus pipeline and the connection of the SEN-1 site to the mainland will be decisive. In this, the plans for the hydrogen core network, applied for by the gas transmission system operators at the Federal Network Agency on 22 July 2024, must necessarily be taken into account in the FEP planning. There is now a planning-related demonstration of need for the pipeline. The core network provides for the Wilhelmshaven area as a hydrogen hub for several offshore and onshore projects for production and infrastructure (see Figure 1). In the interests of efficient planning it is therefore necessary to locate the landfall of AquaDuctus and its continuation into onshore infrastructure there.
Figure 1: Excerpt from the hydrogen core network, as at 22 July 2024 — As long as no decision has been taken on the division of the SEN sites, consultation question F9 is difficult to answer. In principle AquaVentus supports and prefers a route that keeps the core network landing point "Wilhelmshaven area" in view. A route for the collector pipeline north-east of the SEN-1 area, running parallel to existing infrastructure, suggests itself. Entry into the territorial sea should, in the interests of routing that is as direct and space-saving as possible, take place through border corridor N III or through a new corridor (the preferred variant) located east of N III. • Furthermore, the draft FEP states in section 3.1 "Border corridors to the territorial sea" at the bottom of page 60: …border corridors are explicitly intended for power lines. No capacity is provided here for pipelines [the AquaDuctus pipeline], so that these are to be routed outside the designated border corridors… This wording contradicts consultation question F9, must be adjusted, and should be brought into line with a preferred routing through a new corridor located east of N III. • The Federal Government moreover attaches great importance to pipeline-based imports through the North Sea corridor and underlined this in its update of the hydrogen import strategy adopted on 24 July 2024. Looking ahead, Europe can benefit from a coordinated, jointly planned offshore interconnected network that sensibly connects producers with offtakers. Germany should coordinate early with neighbouring states (e.g. Norway, the Netherlands) in maritime planning. The update of the Site Development Plan should take this into account from the outset as well.
Consultation question F9: possible routes for connecting SEN-1. One possible route for a hydrogen pipeline through which SEN-1 could also be connected runs from SEN-1 in a south-easterly direction to the priority area for defence. There it is to turn south and run west of N-2 to border corridor N-I. As an alternative, a routing towards N-III is put out to consultation.
Figure 2: Hydrogen pipeline — possible route between SEN-1 and the territorial sea. In your view, are there fundamental objections to the route described? Would the alternative of routing the line from the priority area for defence east of area N-3 to border corridor N-III be more advantageous in that case? Please give reasons. Answer
A landfall in the greater Wilhelmshaven area is planned for the AquaDuctus hydrogen core network project. Connecting SEN-1 via a route extending border corridor N-I is not sensible. On the section from the exit from SEN-1 to border corridor N-I alone, 24 crossings with existing or planned line infrastructure (cables and pipelines) would be required. A continuation within the territorial sea from N-I to the greater Wilhelmshaven area would have to be planned south of the
priority area for shipping over a route length of approximately 100 kilometres parallel to the coast, largely through the national park and Natura 2000 area. Within the territorial sea, a further 28 crossings including the associated crossing structures would be required in areas of shallower water depth. Such a routing cannot therefore be preferable. A routing combining a westerly exit from SEN-1 with an extension of border corridor N-III is likewise not preferable, given the large number of resulting crossings (37). An easterly routing with two route variants is to be preferred instead (cf. Figure 3). This routing requires considerably fewer cable and pipeline crossings and enables correspondingly space-saving planning. Compared with the line routes proposed in the draft FEP, the number of crossings within the EEZ can thus be reduced from 24 (or 37) to 8. One of the route variants runs parallel to existing and planned cable routes throughout the EEZ. The transition into the territorial sea could take place as an easterly extension of N-III. A second variant likewise runs bundled with planned cable routes and then turns south along the eastern edge of the priority area for defence (submarine diving area). The easterly routing and the transition into the territorial sea east of border corridor N-III minimise potential conflicts with the future grid connection systems to Baltrum/Langeoog. In addition, the cable corridor running towards N-III in the east is not constrained by a pipeline.
Figure 3: Preferred variants for the routing of AquaDuctus within the EEZ between SEN-1 and the transition into the territorial sea.