Statement on the draft Site Development Plan of 1 July 2022. 31 August 2022. Ladies and Gentlemen, achieving the Federal Republic of Germany's climate and expansion targets for green hydrogen as an integral component of the National Hydrogen Strategy is a central concern for us. We therefore urgently await its update.
For the realisation of the AquaVentus concept of 10 GW of offshore electrolysis capacity, which has meanwhile become very concrete, a significant expansion of the other energy generation areas in the North Sea is central. Particularly in light of the Offshore Wind Energy Act (WindSeeG) adopted by the Bundestag on 7 July 2022, and against the background of the vision of producing up to one million tonnes of green hydrogen by 2035, we consider it urgently necessary to comment in detail on several aspects of the current draft Site Development Plan.
Enabling the pipeline transport of offshore-produced hydrogen via a collector pipeline with a throughput capacity of at least 2 GW is an important next step. The intended advance determination through the fixing of sites connected exclusively by electricity, extending into the so-called "Entenschnabel", however gives us pause. Subordinating the known and demonstrated opportunities of offshore hydrogen at large scale to the anticipated expansion pathway for renewable electricity already today is, in our view, not expedient. In the course of this statement we therefore wish to make clear what possibilities exist for integrating offshore hydrogen into the Site Development Plan and what this technology can deliver for the German and European hydrogen economy. AquaVentus, as an overarching initiative of now more than 100 organisations, research institutes and companies along the entire value chain, recognised this potential early, when the concept was first formulated 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. Our proposals can be found on the following pages.
We are glad to contribute constructively to this and remain available for further consultations at any time. With fresh greetings from the high seas.
Chair of the Board, AquaVentus Förderverein e.V.
Public notice of the Federal Maritime and Hydrographic Agency on the publication of the draft Site Development Plan and the environmental reports (North Sea and Baltic Sea)
Statement — Summary: AquaVentus welcomes the fact that the revision of the FEP now enables the generation of offshore hydrogen with subsequent transport away via a collector pipeline of at least 2 GW. This opens up a perspective for implementing the AquaVentus concept of 10 GW of offshore hydrogen and represents an important regulatory milestone for the initiative. The prerequisite for this, however, is further sites beyond the SEN-1 area, which together must enable at least 2 GW of electrolysis capacity. The current draft FEP does not designate such SEN sites and instead already assigns almost all sites currently available under spatial planning to electricity connection. AquaVentus regards this as an unnecessary and premature determination that ultimately has an inhibiting effect on the development of technology in the context of hydrogen generation. It is not prescribed by the Offshore Wind Energy Act and ultimately pre-empts technological developments that cannot be foreseen over such a long planning period. In order to develop available offshore wind sites more quickly and to initiate the rapid ramp-up of a German offshore hydrogen economy, we propose specific additional sites for the generation of 2 GW. This would also make an immediate contribution towards enabling the Federal Government's target of 10 GW of hydrogen by 2030, with all the known advantages of offshore production. We would be very glad to explain in detail the advantages of this step-by-step ramp-up of an offshore hydrogen economy and to discuss them in a workshop organised by the BSH ahead of the finalisation of the FEP, together with other stakeholders of the hydrogen sector.
Fundamental observations on the legislative basis of the Site Development Plan. Under Section 4 of the Offshore Wind Energy Act, the Site Development Plan (FEP) forms the sectoral planning basis for offshore wind expansion in the German Exclusive Economic Zone (EEZ) of the North and Baltic Seas and, as such, implements the targets now set by the new Offshore Wind Energy Act of 30 GW of installed capacity by 2030, 40 GW by 2035 and 70 GW by 2045 within the framework of the overarching requirements. In drawing up the Site Development Plan, the Federal Maritime and Hydrographic Agency (BSH) is therefore likewise bound by precisely these requirements, on the one hand from the upstream maritime spatial planning and on the other by the legal provisions on offshore wind expansion.
The AquaVentus Förderverein would therefore first like to emphasise that we perceive positive signals from industry for hydrogen generation on the high seas and thus for the AquaVentus vision. It deserves particular emphasis that the newly enacted Offshore Wind Energy Act has removed the former site limitation of 70 km² for other energy generation areas. At the same time it has been made possible to carry energy away from other energy generation areas by collector pipeline, as conceptually envisaged by the AquaVentus initiative. This concept has been taken up explicitly by the BSH in the first draft Site Development Plan now before us, in that a pipeline must enable the connection of further other energy generation areas while guaranteeing a minimum capacity for 2 GW of electrolysis capacity. Precisely in view of the urgently needed efficiency in sectoral planning within the German EEZ, which is small relative to the size of the German economy, the AquaVentus initiative welcomes this provision, which directly supports the AquaVentus vision.
It must, however, be expressly emphasised that the designation of further other energy generation areas (SEN) is still lacking and that the present draft FEP continues to be conceived from the perspective of pure electricity generation. Only with the provision of additional SEN areas will the prerequisite be created for generating relevant quantities of hydrogen at sea. The resulting need to transport larger quantities of hydrogen justifies the construction and operation of a correspondingly dimensioned transport infrastructure.
In order to resolve this factual contradiction in the further updating procedure of the Site Development Plan, the AquaVentus initiative therefore calls for the following fundamental changes:
Greater flexibility in sectoral planning to achieve the capacity expansion and climate protection targets. 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 makes consistent use of the sea area available for offshore wind expansion. At the same time, however, the FEP's planning horizon extending to 2038 is exceptionally long and is accordingly subject to a number of technological, economic and regulatory uncertainties. 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. The Site Development Plan, by contrast, makes unambiguous determinations extending to 2038 and thereby limits, without discernible necessity, the significant latitude for future planning in the EEZ. Three concrete examples make this particularly clear:
Avoid unnecessary advance determinations — the Electricity Network Development Plan currently in force, as the basis for planning electrical grid connections, assumes in Scenario C 2035, for instance, only 34 GW of installed offshore wind capacity and carries this assumption through in grid connection planning up to 2035. The additional expansion of offshore grid connections and of the onshore transport grid required by 2035 to reach 40 GW of installed capacity accordingly remains uncertain. Even with the raising of assumptions within the scenario framework for the next update of the Network Development Plan, the long time horizon and the comparatively high expansion ambitions remain a factor of uncertainty. Whether sufficient (electrical) grid connection and transmission capacity will therefore be available in good time, or whether electricity-based offshore
wind expansion will be considerably delayed or jeopardised overall — for instance through supply chain risks, local resistance to grid expansion, shortages of skilled workers, competition with other markets or a lack of availability of the necessary equipment — can in fact be assessed only with great difficulty today.
Enable an alternative hydrogen scenario in the planning — the study "Comparison of system variants for hydrogen provision from offshore wind power" published in May 2022 by AFRY Management Consulting shows clearly that the concept pursued by AquaVentus of up to 10 GW of electrolysis capacity in the areas of the German EEZ far from the mainland offers concrete advantages. 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, but it depends on the regulatory framework being created for it.
– The recently published Fraunhofer IWES study on offshore site potential shows clearly how, 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, 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, which is why it is important that this planning does not pre-empt the results in advance through unnecessary determinations. Instead, this open dialogue should be enabled and indeed prefigured. Exploiting the potential for co-use will foreseeably create further site capacity in the North Sea. In this sense, the AquaVentus initiative also expressly does not share the reasoning in Chapter II.8 for excluding further designations of other energy generation areas. Excluding offshore hydrogen already today on the grounds of a lack of sites, despite the objectively existing advantages, does not represent an efficient use of the sites to be tendered.
Think of offshore hydrogen internationally and take account of future interconnectors for hydrogen as well — the designation of additional sites for the generation of green hydrogen in Germany would be a decisive step for European and international interconnection. This applies both to the wind farms and to the collector pipeline, which would become an essential contribution to the internal hydrogen market involving Denmark, the Netherlands, Belgium, Norway and the United Kingdom. In our assessment, these perspectives have not yet, or not yet sufficiently, been taken into account in the drafts of the FEP. 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 in May 2022 (the Esbjerg Declaration).
Use the latitude in the Offshore Wind Energy Act and do not determine sites prematurely. The recently amended Offshore Wind Energy Act, as the legal basis for the Site Development Plan, provides in Section 5 that from 2026 sites are to be determined in such a way that they can be completed at the same time as the offshore connection lines required in each case, while ensuring compliance with the auction targets under Section 2a. Deviations from this are permissible as long as the fundamental expansion targets under Section 1(2) are achieved (30 GW by 2030, 40 GW by 2035 and 70 GW by 2045).
According to the auction volumes and associated commissioning dates provided for in the present draft Site Development Plan, the expansion target of 30 GW by 2030 is met exactly, while the expansion target of 40 GW by 2035 is significantly exceeded. In view of the examples cited above, this latitude should be used and advance determinations going beyond target fulfilment thereby avoided. This makes it possible, on the one hand, to respond flexibly to technical challenges such as those in grid connection and expansion. Advantages already known today are exploited by promoting the technological development of alternative concepts. The possibility also remains for an open dialogue on the best possible use of the EEZ, for example in the course of the necessary revision of the current maritime spatial planning.
In sum, for these reasons and in order to preserve flexibility in sectoral planning, up to 10 GW of site potential should be determined only once such determination becomes necessary to achieve the targets. This applies in particular to sites spatially far from the mainland in the so-called "Entenschnabel" with auction and/or commissioning years from 2030 onwards.
Further site potential for the other energy generation areas. As described above, greater flexibility is urgently needed in order to anticipate future developments and challenges already today. At the same time, a fundamental and concrete sectoral planning basis is required for the generation of green offshore hydrogen, in order to enable both the development of the technology needed for hydrogen generation at sea and its consistent market ramp-up now. The designation of further other energy generation areas in the new FEP is necessary in order to take appropriate account of the planning lead time for such projects at large scale. 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, through dedicated site designation — can the advantages already cited be exploited, particularly in the faster connection of sites, and cutting-edge technology "made in Germany" along with the associated jobs be promoted.
The AquaVentus initiative therefore calls for the designation of further other energy generation areas in the North Sea in the Site Development Plan currently under discussion. 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.
As set out, the latitude in sectoral planning can be used in drawing up this FEP. The second interim report of Fraunhofer IWES, as well as the recently published site potential study by Fraunhofer IWES, foreseeably indicate an overall potential of more than 70 GW if further potential is used. For the environmentally compatible realisation of this potential, spatial planning has issued the Federal Government a mandate to examine the matter by 2024.
Establishing the first green hydrogen cluster in the North Sea: designate N-21.1 and N-22 as SEN. Against this background, sites N-21.1 and N-22, still under examination and in the immediate vicinity of the already designated site SEN-1, should as a first step additionally be designated as other energy generation areas. This would enable the 2 GW minimum capacity for a collector pipeline — contrary to the determinations made so far — for the ramp-up of the technology. A further advantage is that the grid connection points for both sites have not yet been fixed, so that the already very high expansion pressure on the offshore and onshore transport grids would be further reduced. The planned commissioning of these sites and their connection to a collector pipeline by 2033 can thus, with high probability, even be brought forward. Via a first green hydrogen cluster, these sites could be developed faster than currently envisaged and contribute more quickly to achieving Germany's climate targets.
2 GW as the starting line for the large-scale offshore hydrogen economy. Designating sites N-21.1 and N-22 would in principle enable a spatially efficient pipeline solution with a minimum capacity of 2 GW to begin with, while at the same time keeping open the options for the future connection of further sites in the Entenschnabel as described above. Determinations on the dimensioning of the line, in line with the capacities from future hydrogen wind farms in the distant regions of the EEZ such as clusters N-17 to N-19 as well as neighbouring countries, could still be adapted to actual requirements up to 2026.
Answers to consultation questions F10, F11 and F12. F10: Can the minimum distance of 500 m to pipelines specified in 6.1.6 (a) be reduced to a structurally necessary minimum? What minimum distance would then have to be specified?
Answer: In our assessment, the minimum distance of 500 m specified in 6.1.6 (a) can be reduced to a value of 300 m. This minimum distance has also been applied in recent years to other offshore pipeline and cable projects in German waters and has been certified as safe by independent parties. In individual cases this standard can be modified where necessary upon appropriate demonstration.
F11: Which routes for a pipeline connecting SEN-1 come into consideration from a spatial and technical perspective? At which points outside the border corridors specified in the FEP are possible transition points to the territorial sea located?
Answer: The route of a connection line to SEN-1 must permit a sensible continuation of the routing for connecting further hydrogen wind farms. The route of the collector pipeline essentially follows the reservation areas for lines (ROP 2021). Possible feed-in points into the onshore hydrogen network currently under consideration are the greater Wilhelmshaven area or the greater Brunsbüttel (Büsum) area. Both landing points are readily reachable provided the crossing into the territorial sea takes place in the Schleswig-Holstein region. For this, either the existing border corridor N-V or an alternative transition point to the south-west can be used. The latter follows from the extension of the reservation areas for lines (ROP 2021) LN9 and LN8 up to the boundary between the EEZ and the territorial sea.
Figure: Planned route of the AquaDuctus collector pipeline, in 2 variants, between SEN-1 and the Schleswig-Holstein territorial sea. Possible transition points are the border corridor N-V or a newly designated border corridor (N-new).
F12: What further determinations and planning principles, including technical ones, do you consider necessary in the FEP, particularly for a hydrogen pipeline and for the specification of a corresponding minimum capacity?
Answer: In the view of AquaVentus, laying down separate planning principles for hydrogen pipelines in the FEP is not necessary. For the pipeline-based transport of hydrogen offshore, the same principles apply as for the transport of natural gas. The standard developed in other pipeline projects (best industry practice) ensures the necessary safety depending on the specific requirements and local conditions (e.g. water depth, intensity of shipping).
As AquaVentus we assume, looking ahead, a transport requirement for offshore-generated hydrogen of considerably more than 2 GW. Specifying a minimum capacity of 2 GW does not conflict with this assumption. The pipeline design can be adapted accordingly should transport requirements be greater.
Miscellaneous. The aforementioned expansion of the available site portfolio for offshore hydrogen in Germany is the cornerstone for the development and market ramp-up of this technology and the prerequisite both for Germany remaining a pioneer in cutting-edge technology for the energy transition and for a significant share of the urgently needed hydrogen also being produced domestically. Beyond this, further largely political course-setting decisions are needed to realise the AquaVentus vision, which for the sake of a holistic presentation should also find a place in this consultation:
National Hydrogen Strategy: 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, fundamentally call for a prompt revision of the national hydrogen strategy. While the so-called Easter Package will in future provide two new instruments to advance the expansion of electrolysis in Germany, these either exclude electrolysis at sea outright or largely leave open how offshore electrolysis can make its contribution to the target of around 10 GW of domestic electrolysis capacity. The overall strategy, still unclear at present, becomes particularly evident with regard to the generation potential for green hydrogen on the high seas, as this statement also makes clear. Contradictions — such as that between the collector pipeline with a 2 GW minimum capacity and the generation capacity lacking for it in the EEZ — should be addressed holistically and fundamentally by the national hydrogen strategy before they arise in future.
Funding: so far it is only apparent that there will be funding for green hydrogen on the offtake side. Whether the planned ordinance, based on the authorisation of the Federal Ministry under the Offshore Wind Energy Act, will also provide financial support for the production of green hydrogen remains open. It is, however, the expectation and understanding of the AquaVentus initiative that, with the Offshore Wind Energy Act, the legislator introduces via the ordinance authorisation a starting point for the financial support and hedging of offshore hydrogen, in order to reach the national targets of 10 GW of hydrogen by 2030. The FEP must also take account of this requirement by designating further sites — as already described — in line with this established expansion pathway. Furthermore, in shaping the ordinance it must be ensured that the generation potential for green offshore hydrogen is enabled to participate in the tenders on an equal and non-discriminatory basis.
Subordinate grid connection: the possible contradiction that has existed so far between the exclusion of a connection to the public (electricity) grid under the Offshore Wind Energy Act and the possibility of a cable-based connection to a nearby substation platform, apparent from the explanatory memorandum to the Ordinance on Other Energy Generation Areas, should be clarified in law with regard to its intended function and hoped-for added value. In sectoral planning terms, in the event of a possible cable connection this should also be reflected in the FEP (possibly as a route corridor).
Offshore Wind Energy Act: at the next possible revision it should bindingly set an expansion target for offshore hydrogen; for this, the insights gained from the current consultation on the Site Development Plan must also be drawn upon.