Statement on the draft Site Development Plan of 28 October 2022. 21 November 2022. Ladies and Gentlemen, with this second draft of the Site Development Plan (FEP), the realisation of the AquaVentus concept of 10 GW of offshore electrolysis capacity has moved a step closer, in that the pipeline concept is now included and at least one further SEN site has been designated. We also welcome the removal of the advance determinations of an electrical connection for the sites in the so-called Entenschnabel, and point out once again that further sites for offshore hydrogen generation should be designated in the next update of the FEP, particularly for reasons of efficiency. Beyond this, in order to realise a collector pipeline on schedule and efficiently, the options for such a pipeline to cross into the territorial sea should be taken into account spatially in the Site Development Plan.
With reference to our previous consultation contributions, we comment below in supplementary fashion on the second draft of the Site Development Plan.
AquaVentus, as an overarching initiative of now more than 100 organisations, research institutes and companies along the entire value chain, recognised the opportunities for offshore-produced hydrogen early and first formulated the concept in 2020. This great potential was already acknowledged through the inclusion of the two sub-projects AquaPrimus and AquaDuctus in the national pre-selection for IPCEI funding.
The AquaVentus family of projects can contribute substantially to decarbonising the German and European energy supply while at the same time promoting domestic value creation, creating skilled jobs in the northern German region and minimising environmental impact. To make this concept a reality and enable the associated advantages, a political expansion pathway providing planning and investment certainty, important adjustments to the FEP, and accompanying funding are required.
We are glad to contribute constructively to this and remain available for further consultations at any time.
With fresh greetings from the high seas. Public notice of the Federal Maritime and Hydrographic Agency on the publication of the 2nd draft of the Site Development Plan and the environmental reports (North Sea and Baltic Sea)
Statement — supplementary observations on our previous statements in light of the 2nd draft of the FEP. The AquaVentus Förderverein would first like to emphasise that, after many further discussions with all industries that urgently need green hydrogen as a raw material on a large scale, we perceive positive signals for its generation on the high seas and thus for the AquaVentus vision.
The designation of a further SEN site, or the extension of the SEN-1 site, is consistent and likewise very welcome. We welcome the fact that the concept of a collector pipeline continues to feature in the 2nd draft of the Site Development Plan produced by the BSH. Nevertheless, the 95.4 km² of site area then available in total yields a potential of only around 1 GW of electrolysis capacity, which is not yet sufficient for the efficient and economic operation of a pipeline of such dimensions. The AquaVentus initiative therefore continues to call for the designation of additional other energy generation areas in the North Sea in the Site Development Plan currently under discussion. Without an early designation of further other energy generation areas, offshore hydrogen technology risks becoming stuck at the trial stage in Germany for want of scaling prospects and being implemented elsewhere. Only by creating the scaling perspective in good time — that is, a corresponding designation of sites — can the advantages already named in our first statement be exploited and cutting-edge technology "made in Germany", along with the associated jobs, be promoted. In principle these sites should be designated in the so-called "Entenschnabel", since the advantages in terms of speed, lower costs and reduced environmental impact come to bear particularly clearly there. We refer in this regard to the short study by AFRY Management Consulting.
Beyond this it must be noted critically that the second draft of the Site Development Plan still does not take account of the transition of a collector pipeline into the territorial sea. A collector pipeline should as far as possible be routed within the reservation areas for lines established in the Spatial Development Plan (ROP) 2021. At the transition between the EEZ and the territorial sea, the ROP 2021 defines a total of seven border corridors, GN 1 to GN 7. Five of the border corridors defined in the ROP 2021 are provided for offshore connection lines in the FEP (N-I to N-V). Their use for routing to connect SEN-1, and thus for transporting away offshore-produced hydrogen, is excluded. This substantially complicates the determination of a suitable route, the approval process, and thereby the creation and timely realisation of a robust transport concept for carrying away the quantities of hydrogen produced offshore. The creation and reservation of potential border corridors for a collector pipeline — for instance by opening or dividing those border corridors that are not yet so heavily occupied, or by spatially designating new border corridors — is therefore urgently required.
The AquaVentus Förderverein emphasises 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 seeks to make consistent use of the sea area available for offshore wind expansion. In this context we welcome the fact that the advance determination of an electricity-side connection for sites far from the coast in Zones 4 and 5 is no longer the subject of the current 2nd draft FEP. Precisely there, efficient alternatives to an electricity connection can now be examined on a technology-neutral basis. We are convinced that the AquaVentus concept offers considerable advantages here.
The Fraunhofer IWES study on offshore site potential moreover shows clearly that, in the interests of climate protection, both greater overall capacity and higher site efficiency can be achieved through repowering or co-use. Such potential must not remain unused, but it does presuppose an important — and of course longer, intensive and open-ended — stakeholder dialogue as well as political steering. The outcome of such a dialogue must be able to feed into the further sectoral planning. The withdrawal of the determinations has enlarged the range of options for this, which we very much welcome. As a next step we now ask the BSH to initiate this stakeholder process with a view to the further update of the FEP. Exploiting the potential for co-use will foreseeably create further site capacity in the North Sea.
As already set out in our first statement, we consider it decisive to think of offshore hydrogen in international terms from the outset and to take account of future interconnectors in Europe for hydrogen as well. In our view it is not sufficient for Germany to understand this interconnection as a mere import option. That would fall short of the political declarations of intent made at the North Sea Summit. We therefore welcome the indications in the current draft FEP that talks with European partner countries are taking place, and we place our hope in these being advanced fruitfully with a view to a European hydrogen economy.
The great challenges in the future reliable, low-cost and above all sustainable supply of green hydrogen, together with the high complexity of the subject, call for a prompt revision of the National Hydrogen Strategy (NHS). Contradictions — such as that between the 2 GW collector pipeline and the generation capacity lacking for it in the EEZ — should be addressed holistically and fundamentally by the National Hydrogen Strategy. In order to exploit the potential of hydrogen generation at sea and to create investment and planning certainty, the NHS should therefore be supplemented by an "offshore hydrogen strategy" with a 10 GW offshore electrolysis target by 2035 and a corresponding offshore expansion target.
We would be very glad to discuss in detail, ahead of further adjustments to the FEP and together with the BSH and other stakeholders of the hydrogen sector, the advantages of this step-by-step ramp-up of an offshore hydrogen economy (for example within the framework of a workshop).
Beyond this we would like to make one further remark on Chapter 6.1.12. We support the view of the BSH set out in that chapter and its accompanying reasoning, namely that discharges of anti-fouling agents and biocides into the marine environment should be reduced to a minimum or prevented entirely. A distinction must be drawn between systems that use seawater merely as a heat transfer medium and systems that discharge anti-fouling agents or biocides into the marine environment for this purpose. In offshore hydrogen production, both a water inflow and an outflow are strictly necessary for fresh water production in order to carry out electrolysis. The water returned from this process discharges heat, but no chemicals. A separate coolant circulates through the plant to the equipment requiring cooling in a closed circuit and is not discharged into the sea. The alternative of air cooling consumes more energy, takes up more space, is less efficient and therefore more expensive, while the need for a water inflow and outflow for fresh water production continues to exist. We assume that this discharge is negligible within the meaning of the FEP given its minimal environmental impact. We therefore ask for clarification that concepts for offshore hydrogen production which withdraw seawater for desalination and discharge only heat into the marine environment via the water outflow are not covered by the restrictions of Chapter 6.1.12.
Answers to consultation questions F9 and F10. F9: Should two other energy generation areas be designated instead of one large other energy generation area SEN-1 (see the following figures)?
Answer: We expressly welcome the designation of a further SEN area, or the extension of the SEN-1 area, in order to accelerate the technological and economic breakthrough of the technology. In our view, dividing the area into two separate other energy generation areas is clearly preferable to a single large other energy generation area. This enables a step-by-step scaling of the technology and the design, installation and technology improvements to be expected, particularly on the part of the entire supply chain, which can be transferred continuously to subsequent projects. Costs can thereby be lowered and efficiency increased. A staggered tendering of two sites thus offers the best possible basis for directly implementing the learning effects and applying the next generation of technology in a second, then more cost-efficient, follow-up project.
Such a step-by-step approach reduces the funding costs necessary for the ramp-up of this new technology, since the support required per MW or per kilogram of hydrogen in the second tender will already be significantly below that of the first tender thanks to the learning effects. From a macroeconomic perspective, too, a staggered tendering of two sites with a sufficient interval is therefore preferable. Sequential tendering of the sites likewise enables the tender design to be optimised on the basis of experience from the first tender.
In our view the originally envisaged site size of around 27 km² is a sensible order of magnitude for Germany's first large-scale offshore hydrogen flagship project, since here the considerable financial, technical and operational risks on the part of the project developers stand in a bearable relation to the expected added value. With a considerably larger project delineation for the first large-scale realisation of offshore hydrogen production, these risks and the investment costs increase significantly and make financing and realising the project more difficult.
Independently of this, we support the medium- to long-term designation and tendering of further large-scale SEN sites in the gigawatt range. In order to make full use of the economies of scale envisaged and to build a viable infrastructure and supply chain, early predictability is strictly necessary here.
F10: If two other energy generation areas are preferred, what delineation do you consider sensible (see the possible variants in the following figures)?
Answer: As already set out in our answer to question 9, we consider a staggered approach with a sufficient interval between the award of sites SEN-1 and SEN-2 to be the most sensible and cost-efficient route, since corresponding improvements in technology, installation and design can be implemented directly in the follow-up project. An interval of 2-3 years between the two auctions appears suitable here in order to realise considerable learning effects, and given suitable framework conditions it would already enable significant offshore hydrogen production before long. To ensure appropriate predictability, both tender dates should be announced promptly and integrated into an overall concept for the expansion of offshore hydrogen production.
For the technology ramp-up of offshore hydrogen production, as is customary when introducing a new technology, a start should first be made with a smaller site, so that the technology improvements and cost savings can feed directly into the second, larger project. In our view a size of around 25-27 km² appears fundamentally suitable for the first project, since this permits sufficient scaling and accords with the main features of the development and planning that has been under way for almost two years (the size of the former SEN-1). An adjustment on the project side can therefore be made quickly if the original SEN-1 site is redelineated. In our view, both variants (A and B) thus offer the possibility of starting with a smaller project and following it 2-3 years later with a larger one. For this, variant B would have to be adjusted so that the smaller site (SEN-2) is tendered first and only then the larger site (SEN-1) (cf. the adjusted variant B — swapping SEN-1 and SEN-2). In this way the expected technological improvements could already be implemented on the larger site and the total and funding costs for both projects considerably reduced. In view of the German Exclusive Economic Zone (EEZ) being small relative to the size of the German economy, a high degree of efficiency in sectoral planning is decisive. Provided a prompt start of tendering for SEN-1 and the possibility of connecting an export pipeline can be enabled, the adjusted variant B in our view offers the most advantageous layout for an efficient use of the available area while at the same time minimising the cable crossings required.
Figure 1: Adjusted variant B