The purpose of our paper is to provide to those involved in the consultation process a fact-based assessment of the IPHE methodology.
Among other issues, the paper concludes that the IPHE methodology is likely to lead to a substantial underestimation of the fugitive methane emissions. According to the draft IPHE methodology, data concerning the GHG emissions embodied in the natural gas used may be simply sourced from gas suppliers, while the EU Methane Strategy aims at creating an independent international body to monitor methane emissions and verify company reporting in this field. Furthermore, the EU Methane Strategy gives great importance to satellite and drone-based methane emission monitoring, whereas the draft IPHE methodology fails to mention them and could even be interpreted as excluding them. Finally, the IPHE methodology refers to an outdated and too low global warming potential of methane. Without addressing these points, the IPHE methodology would result in a bias in favour of hydrogen production pathways that are more methane emission intensive, essentially steam methane reforming with or without CCS (blue and grey hydrogen).
For hydrogen produced via electrolysis, the draft IPHE methodology can underestimate GHG-emissions in some project settings, if the electricity is sourced from the public grid. Moreover, the comparability between GHG-emissions of hydrogen from different countries is neither guaranteed for electricity emissions nor for methane emissions.
Concluding, the draft IPHE methodology is neither in line with the EU Hydrogen and the EU Methane Strategy nor with provisions of the EU Renewable Energy Directive.