for the German exclusive economic zone in the North Sea and Baltic Sea
About the procedure
In the context of the second round of consultations on the update of the spatial plans for the German Exclusive Economic Zone (EEZ) in the North Sea and Baltic Sea, we are pleased to comment as follows.
In order to achieve the German and European climate targets, hydrogen production from offshore wind energy has been identified as an indispensable component within the framework of the European as well as the German hydrogen strategy. At the national level, this is also reflected in the explicit mention in the recently published climate pact as well as in the announced allocation of corresponding funds in the federal budget. The German EEZ, and the North Sea region in particular, will play a key role in the development of large-scale hydrogen production.
as an overarching initiative of now more than 60 organizations, research institutes and companies, already recognized this potential last year. Electricity from offshore wind turbines is to be used in several subprojects, each located in the German EEZ of the North Sea, to operate electrolysis plants also installed at sea on an industrial scale and thus to build electrolysis plants with a total volume of 10 gigawatts (GW) by 2035 – this corresponds to a production capacity of up to 1 million metric tons of green hydrogen per year, which today could supply about half of the local steel industry.  The offshore generated hydrogen will be transported via the AquaDuctus gathering pipeline. The transport pipeline fulfills two necessary functions: First, it transports the hydrogen to land; second, it provides the necessary energy/commodity storage capacity.
Against this background, we regret that the topic of hydrogen production is not given the consideration in the present draft that would be required in view of the committed hydrogen strategy of the federal government and the EU. Of course, we are aware that the hydrogen projects under consideration will take several more years before they can be planned in detail or realized. However, since experience has shown that the spatial plans for the EEZ have a very long existence phase, the following points must still be taken into account in this update.
1. equalization of hydrogen and electricity generation
Fortunately, the draft regional plan for the German EEZ in the North Sea and Baltic Sea (as of 2.6.20021) already identifies additional areas for wind energy. It is not made clear that the production of green hydrogen is also permitted on these areas in addition to conventional power generation. However, the BSH had confirmed this during the consultation process (11.6.2021). However, in order to increase planning certainty for the developers and investors of hydrogen projects, this point must also be made clear in the ROP. There should no longer be any doubt that the designated areas for wind energy (priority and reserved areas) can also be used in full for the production of hydrogen.
2. clarification of the collective term “lines
Information on the objectives and principles of regional planning with regard to pipelines can be found in Chap. 2.2.3 of the ROP. Para. 5 makes design for permanent covering of power and data lines. However, there are no comments on hydrogen pipelines. However, they are crucial for the transport of H2 produced offshore: the AquaDuctus pipeline system provides the capacity required to transport the hydrogen produced in the EEZ. The pipeline not only fulfills a transport function, but also has considerable storage capacity, depending on its dimensions, and thus replaces up to five high-voltage direct current (HVDC) transmission links that would be required to transport the electrolysis current onshore. The pipeline-based transport of hydrogen is therefore particularly in line with the requirement to use land sparingly. The pipelines required to transport the hydrogen produced offshore should therefore be considered on an equal footing with power lines. The development of a hydrogen economy, as postulated by the National Hydrogen Strategy and the Climate Pact, will only succeed if an appropriate infrastructure is in place. It must therefore be made clear that pipelines for the transport of hydrogen produced by offshore wind turbines are also covered by the term “pipeline” used here.
3. development of duckbill and preparation of international connections
In order to be able to generate even larger quantities of green hydrogen within a European domestic market in the long term, the cooperation of the North Sea littoral states in the field of offshore wind energy and hydrogen production should be strengthened. This was also advocated by the German government in its last report on the maritime economy. AQV is therefore aiming for a joint North Sea offshore strategy by the North Sea littoral states in the long term. However, to ensure international connectivity, the reserved area for the LN 1 line would need to be extended to the end of the “duckbill”.
With regard to the demand for green hydrogen, which will be necessary for complete decarbonization, it should be noted that despite the expansion of areas for the use of wind energy, these will not be sufficient to make sufficient energy available for the production of green hydrogen in addition to conventional electricity generation. In this respect, it should be checked once again which areas are still available in the ROP.
In this context, we would like to point out that the designation of the areas for military use as a reserved area was not based on a formal consultation process, but merely on an informal notification by the Federal Ministry of Defense. Since the designated areas are the largest in extent of all competing uses and it is not apparent that the actual need for land for military use has ever been reviewed, we believe that the extent to which land designated for this use conflicts with the policy goal of expanding renewable energy must also be examined here. Based on a needs analysis, a cost-benefit assessment should determine at which (possibly alternative) sites and to what extent areas should be reserved for military use. Because of their relative proximity to the coast and the lack of competition from elsewhere, the areas now designated are also excellently suited for use by wind energy and would lead to considerable savings for German electricity consumers in this respect due to the production close to the coast. It can by no means be considered certain, or even likely, that the additional costs incurred by shifting wind energy use to areas farther from shore can be offset by any savings in alliance and national defense by using these specific areas.
Insofar as a designation as a reserved area is retained, a designation as a reserved area for wind energy use should be made at the same time in the areas without other competing uses. Alternatively, it should be made clear that the designation as a reserved area for military use is not based on an in-depth examination of the actual requirements and that, if such an examination and a cost/benefit analysis were to be carried out, these could also be made available in part for wind energy use, if necessary, in order to create this possibility in the spatial development plan.
 The demand for green hydrogen is huge. In Germany alone, it is estimated to be 20 TWh in 2030, rising further to 800 TWh by 2050, cf. Hebling, C., Ragwitz, M., Fleiter, T. [u .a.], A Hydrogen Roadmap for Germany, Fraunhofer Institute for Systems and Innovation Research ISI, Karlsruhe, Fraunhofer Institute for Solar Energy Systems ISE, Freiburg, with the participation of the Fraunhofer Institute for Microstructure of Materials and Systems IMWS, Halle and Fraunhofer Institute for Ceramic Technologies and Systems IKTS, Dresden, Karlsruhe, Freiburg 2019, p. 10.