Statement on the draft Act implementing the EU Renewable Energy Directive in the fields of offshore wind energy and electricity grids. The AquaVentus Förderverein e.V. would like to thank you in advance for considering this statement on the current ministerial draft implementing the RED III Directive in the field of offshore energy and grids.
The implementation of this Directive is intended to increase the share of energy from renewable sources in the European Union's gross final energy consumption to at least 42.5 per cent by 2030. The amendments form part of Germany's overall efforts to align its entire climate, energy and economic policy with the 1.5-degree climate protection pathway. To this end, electricity supply is to be based at least 80 per cent on renewable energies by 2030. The Federal Government further emphasises in its coalition agreement that domestically produced hydrogen (onshore and offshore) will make a decisive contribution to this.
With this statement we would like to offer important suggestions for the further development of the draft. The AquaVentus Förderverein e.V. therefore urgently calls for the classification of hydrogen production at sea — together with offshore transport by pipeline — as a project of overriding public interest and public security, as provided for in the original draft (2024 version), to be reinstated in full. This would correspond to the necessary implementation of Directive 2010/75/EU on industrial emissions for the field of hydrogen production at sea.
The draft as it currently stands thus fails to recognise the strategic importance of offshore electrolysis for the future energy system as a whole. The combination of offshore wind power, hydrogen production and pipeline connection is a central lever for:
– achieving climate targets efficiently, – relieving grid infrastructure and expanding the overall energy system cost-effectively,
– increasing security of supply, – driving forward the hydrogen ramp-up with domestic production, and – supporting the transformation of industry in Germany and Europe.
Hydrogen production at sea is not a subordinate special case but an integral component of a future-proof overall offshore strategy. AquaVentus therefore recommends adopting the following wording in the draft legislation:
"The construction and operation of facilities for the production of hydrogen at sea, as well as the transport of the hydrogen by pipeline, are of overriding public interest and serve public security." Only through this clarification can legal certainty for investments be created and the swift market ramp-up of the offshore hydrogen industry be assured.