Bellona welcomes the opportunity to provide feedback on the methodology for assessing hydrogen and electrolyser candidate PCI/PMI projects within the TEN-E framework. Building on our previous contributions to this process on hydrogen infrastructure needs and the 1st Union List of Candidate Projects, we commend the Commission’s recognition of the role of hydrogen as a decarbonisation tool for hard-to-abate sectors where alternative decarbonisation pathways may not be feasible or economic and aspiration to assess candidate projects for a trans-European hydrogen infrastructure and electrolysers against that background.  

Given that selected projects will “benefit from accelerated implementation and eligibility to apply for EU financial support”, we consider it paramount that exclusively no-regret hydrogen infrastructure projects make the cut. Such are projects which have a very low risk of becoming stranded assets and operate under conditions that are conducive to a most efficient and rapid decarbonisation of the overall energy system.  

To do justice to those requirements, we recommend the following changes to the PCI/PMI assessment methodology.

Download the consultation response:

Consultation Response: Methodology for Assessing the Hydrogen and Electrolyser Candidate PCI/PMI Projects 2022-2023 Exercise