Europaudvalget 2023-24
EUU Alm.del Bilag 572
Offentligt
2880025_0001.png
Stakeholder consultation on draft of economic Terms and Conditions (T&C) of the
2024 Innovation Fund Auction for RFNBO hydrogen production
Feedback table
Instructions
Thank you for taking the time to provide written feedback on the
draft Terms and Conditions (T&C) of the 2024 Innovation Fund
auction for RFNBO hydrogen production.
We further hope to see you in person or virtually at our workshop on
12 June 2024,
to
discuss the feedback provided
We invite you to provide feedback in the below table on the different design elements of the auction scheme for renewable hydrogen
production. Given the high number of interested stakeholders and our ambition to review all relevant feedback in very short time,
please mind the following:
-
-
-
-
Short, concise feedback, e.g. in bullet points is sought. If you have overall, high-level feedback, please provide it at the begin-
ning restricting yourself to a few paragraphs.
Please substantiate your feedback with evidence.
Don’t feel obliged to provide feedback on all points in the table.
Please indicate what type of stakeholder you are and whether you intend to bid
Please send your feedback via email to [email protected] by 6 June 2024.
1
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
Table of contents
Information about the respondent and general feedback ......................................................................3
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
General auction design elements ..................................................................................................4
Qualification requirements ............................................................................................................. 7
Design elements defining the auction procedure .................................................................. 10
Design elements defining rights and obligations ................................................................... 13
Design elements defining the auction and framework conditions .................................... 15
Qualification Requirements .......................................................................................................... 16
Rules for cumulation of support.................................................................................................. 16
Other Comments ............................................................................................................................. 17
2
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
Information about the respondent and general feedback
Name:
The Danish Government
Position:
NA
Company / Institution / Member State:
Member State, Denmark
Type of Stakeholder (e.g. “H2 project developer”, “H2 offtaker”, “industry association”, “Member
State”
etc.):
Member State
Intention to bid in IF24 auction:
NA
General feedback (optional):
The Danish Government welcomes
the opportunity to comment on the European Commission’s Stakeholder
consultation on the draft of economic Terms and Conditions (T&C) of the 2024 Innovation Fund Auction for RFNBO hydrogen production.
3
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0004.png
I.
No.
General auction design elements
Design Element
Specific implementation in Innovation Fund renewable hydrogen
auction
To cost-efficiently support the production of renewable fuel of non-
biological origin (RFNBO) hydrogen within the EEA.
RFNBO hydrogen produced from water electrolysis in line with re-
quirements put forward in the Renewable Energy Directive (Di-
rective (EU) 2018/2001) and its Delegated Acts C(2023) 1086 final
and C(2023) 1087 final.
The RFNBO hydrogen needs to be produced by new production ca-
pacity (i.e. capacity for which at the time of application start of
works did not yet take place) in order to ensure an incentive effect
of the subsidy.
Feedback
Substantiating evidence, data sources, back-
ground information
1.0
Objective of the auction
Denmark welcomes the objective of the auc-
tion.
Denmark welcomes the scope of the auction. It
is crucial to uphold the limited scope to only
cover RFNBO-certified hydrogen, as sector-spe-
cific targets in various legislative acts are ex-
pected to require a significant ramp-up of the
EU production capacity for RFNBO hydrogen.
1.1
Auctioned good
1.2
Constraining value
The total available Innovation Fund budget of EUR [TBC] million is
the constraining value of the auction and is known in advance.
For the specific basket for maritime sector, the budget will be EUR
[TBC]
The total RFNBO hydrogen volume for which support will be
awarded derives from the total available budget and the individual
bids with their respective bid prices and volumes.
The European Commission may decide to make use of a budget
flexibility rule of up to an additional 20% of the total budget availa-
ble based on the pipeline of the projects received.
A general scrutiny reservation remains con-
cerning the allocated budget, as the budget for
the overall constraining value of the auction is
still unknown.
Denmark is cautiously against the introduction
of baskets, as it is considered inefficient to tar-
get a specific sector, rather than to seek the
broadest base for the auction. A design with
baskets will not necessarily result in an auction,
where the producers with the lowest marginal
production price win.
1.3
Support type
Output-based support (payment per unit of verified and certified
RFNBO H2 production).
No reference price needs to be defined for a fixed premium auction.
Fixed premium
Ensuring competition through market testing, total available
budget, a ceiling price, and feedback on the level of competition
from one round to another.
1.4
1.5
1.6
Reference price
Support form
Safeguards against over-sub-
sidisation
4
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0005.png
No.
Design Element
Specific implementation in Innovation Fund renewable hydrogen
auction
No claw backs.
Feedback
Substantiating evidence, data sources, back-
ground information
1.7
1.8
Ranking of bids
Bid components
Price-only ranking
1) Fixed premium (“bid price”) in EUR/kg of RFNBO hydrogen pro-
duction (basis for ranking of bids), expressed with two digits after
the comma.
2) Expected average yearly volume of RFNBO hydrogen production
in kg per year over a 10 year production period.
The maximum grant amount is therefore calculated as:
[������������ �������������������� �������� ] ∗ [�������������������������������� ���������������������������� ������������������������ ������������������������ ��������
kg
€
��������
����������������
]∗
10 ��������������������
3) The new electrolyser capacity in MWe that will be installed and
verified as being operational by the time of entry into operation.
1.9
Minimum and maximum
yearly production thresholds
No upper or lower limits to the expected average yearly production
as stated in the bid.
However, the maximum grant amount requested by each proposal
must stay within 1/3 of the total available Innovation Fund budget
for the auction (see points 1.2 and 2.3).
In the case of the specific basket for maritime sector, the maximum
grant amount requested by each proposal must stay within 1/2 of
the total available budget in this basket.
As a general remark, the limit of the maximum
grant amount requested should based on a
monetary value.
This essentially means setting a set maximum
monetary size of the possible grants e.g. a max-
imum of 500 mio. EUR over 10 years, instead of
having the maximum size of the grant some-
what arbitrarily decided before the fund budget
is set. This would ensure that it is possible in ad-
vance to weigh the trade-offs between the ad-
vantages of having a maximum size of the grants
and the losses from larger projects not being
feasible within the auction design.
1.10
Production flexibility rules
Semi-annual production can be increased up to 140% compared to
half of the expected average yearly volume of RFNBO hydrogen pro-
duction as stated in the bid (see point 1.8). Semi-annual production
beyond 140% is possible but not supported by grant payments.
The total grant amount is restricted to 100% of the maximum grant
amount.
See points 4.2 on severe underperformance and 4.3 on semi-annual
payment schedule.
5
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0006.png
No.
Design Element
Specific implementation in Innovation Fund renewable hydrogen
auction
The grant agreement will end ten years after the Entry into Opera-
tion of the project (unless the total RFNBO Hydrogen production
volume as stated in the bid is reached earlier, due to the production
flexibility rules (see line 1.10).
See also point 4.2 on grant agreement termination.
Feedback
Substantiating evidence, data sources, back-
ground information
1.11
Grant
duration (disbursement pe-
riod)
1.12
Indexation of support
No indexation.
Denmark is hesitant to have no indexation of
the support. Not indexing the support will
leave the possibility of the support being hol-
lowed out by inflation, which brings additional
risk to the bidder, ensuring relatively higher
bids for the fund.
Indexing the support
–
for instance, with the
general or energy-specific inflation, would limit
this possibility.
1.13
Technology baskets, differen-
tiation by regions or actors
There will be two budget baskets: (i) a budget of EUR [TBC] million
will be earmarked for projects with maritime off-taker(s) and (ii) a
general basket. The remainder of the budget is earmarked for pro-
jects which do not have off-takers in the maritime sector. For more
information on the clearing mechanism, please refer to line 3.8.
For a definition of an off-taker in the maritime sector, please refer
to Section 3, Qualification Requirements.
If a portion of the budget remains unawarded in the maritime bas-
ket, that amount will be transferred to the general basket.
Denmark is hesitant to limit takers for the auc-
tion
–
and in particular against budget baskets
by regions, technologies and actors
–
as long as
there is not a demonstrable difference in the
hydrogen produced or other externalities in
the production.
1.14
Method and estimate of sub-
sidy per ton of CO2e abated
The value of the subsidy per tonne of CO2e abated will be calcu-
lated by CINEA and does not have to be provided by the applicant /
does not form part of the evaluation.
The expected CO2e abatement per kg of renewable hydrogen pro-
duced will be calculated using the 2021-2025 ETS benchmark of
6.84 t_CO2e/t_H2. This is a conservative estimate in not taking into
account additional carbon abatement due to substitution effects in
the RFNBO H2 end use application.
1.15
Resilience related require-
ments for the electrolyser
The bidder will have to provide as part of its electrolyser procure-
ment strategy (see section 3) information about (i) percentage of the
value of the electrolyser allocated to critical raw materials, (ii) end of
Denmark welcomes the possible inclusion of
resilience-related requirements for electrolyser
6
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0007.png
No.
Design Element
Specific implementation in Innovation Fund renewable hydrogen
auction
life / recycling strategy plans, (iii) responsible business conduct, (iv)
compliance with safety and performance requirements and standards,
and (v) public subsidies received for the production of the electro-
lyser.
Beyond information gathering, the European Commission is looking
into incorporating and operationalising solid resilience aspects
through the auction design (e.g in the form of non-price criteria, or
pre-qualification criteria) in
line with the Union’s international obli-
gations. In the light of stakeholder comments in response to this con-
sultation and a stakeholder event in June 2024, further discussions
between the Commission’s services will take place before the final
Terms & Conditions will be published in Q3 2024.
Feedback
procurement as a means to safeguard the resil-
ience of the Union. This inclusion should, how-
ever, be based on the same criteria as laid out
in the Net Zero Industry Act. Thus, guiding prin-
ciples should be based on equal requirements
for all actors ensuring a level playing field.
It should also be considered that resilience-re-
lated requirements would likely lead to higher
bidding prices and thus require more support
to equal the effect on the green transition.
Substantiating evidence, data sources, back-
ground information
II.
No.
Qualification requirements
Design Element
Specific implementation of the Innovation Fund renewable hydro-
gen auction
For further details on qualification requirements see section 3 of the
Terms & Conditions.
Admissibility:
•
Strict respect of submission deadlines, use of forms provided
by the granting authority and submitted through the Funding
and Tenders Portal, and compliance with presenting all re-
quired documentation (Application Forms), together with
mandatory documents and supporting documents, including a
Gantt chart outlining the project timeline and a financial infor-
mation file (with a template-based financial model and bid
components))
Feedback
Substantiating evidence, data sources, back-
ground information
2.1
Qualification requirements
Eligibility:
•
•
Proposals must relate to projects located in the EEA.
Project and budget size in the limits expressed in point 2.3
7
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0008.png
No.
Design Element
Specific implementation of the Innovation Fund renewable hydro-
gen auction
•
•
The bid amount may not exceed the ceiling set in point 3.7
Compliance with legal entity checks (compliance with EU ex-
clusion situation limitations (default, prosecution, etc). All
beneficiaries will have to be validated.
No geographical limitation on origin of members of the con-
sortium.
Signed self-declarations, see section 3 of the Terms & Condi-
tions (also part of Application Form Part B)
Feedback
Substantiating evidence, data sources, back-
ground information
•
•
Relevance and Quality.
•
The proposals will be evaluated on a pass/fail basis on rele-
vance, technical, financial, and operational maturity assessed
based on the documents listed in section 3 of the Terms &
Conditions and their description in Application Form B.
After evaluation and before grant agreement signature, an addi-
tional financial capacity check will be made, to ensure that appli-
cants have stable and sufficient resources to successfully implement
the projects and contribute their share.
2.2
Completion guarantee
A completion guarantee covering 10% of the maximum grant
amount (see point 1.8) will be requested. The guarantee must be is-
sued by a bank or financial institution (rated at least BBB-/Baa3) and
must be able to be called by the granting authority if the project
does not reach approved entry into operation within 3 years after
signing the grant agreement (see point 4.1).
The completion guarantee shall be issued at the latest two months
after receiving the evaluation result letter inviting the selected ap-
plicants for grant agreement preparation. It shall be valid from the
date of issuance until six months after the maximum time to entry
into operation (i.e. after verification that the electrolyser capacity
stated as part of the bid production capacity is operational). The du-
ration of the completion guarantee is expected to be at least 3 years
and 11 months, and it will have to be issued no later than two
months after the receipt of the invitation letter. A template will be
made available and will have to be used.
If entry into operation is reached earlier, the guarantee can be re-
leased earlier.
As a general point, the requirements for a
completion guarantee should be considered
alongside all other qualification requirements.
Increasing the requirements for a completion
guarantee could have several adverse effects.
Firstly, it could lead to higher bidding prices,
as bidders would include the cost of additional
security in their bids.
Secondly, it would favor larger companies,
which can more easily manage the risks asso-
ciated with posting securities and diversify
these risks within their portfolios. This would
make it much harder for smaller companies to
compete.
Additionally, larger projects might need to be
divided into smaller sub-projects to meet the
guarantee requirements, potentially delaying
the full realization of the project's capacity.
8
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0009.png
No.
Design Element
Specific implementation of the Innovation Fund renewable hydro-
gen auction
A letter of intent from a bank or financial institution to issue a com-
pletion guarantee will be required as part of the proposal. A tem-
plate will be made available and will have to be used (no changes to
the template are allowed).
The enforcement of completion guarantees is further explained in
point 4.2.
Feedback
On the positive side, stricter completion guar-
antees would provide more assurance that
projects will be completed. It could also re-
duce the risk of fund misuse, as the conse-
quences of not completing projects would be
greater.
Substantiating evidence, data sources, back-
ground information
2.3
Minimum or maximum re-
striction for project size and
for bid volume
Maximum grant amount restriction for each bid: 1/3 of the total
available budget defined for the auction basket.
In the case of the specific basket for maritime sector, the maximum
grant amount requested by each proposal must stay within 1/2 of
the total available budget in this basket.
Minimum technical requirements: 5 MWe of newly installed electro-
lyser capacity (which must be in a single location; virtual pooling of
capacity is not permitted).
The limit of grant amounts available to each
proposal should be evaluated based on the to-
tal budget of the auction as there is a trade-off
in disallowing bigger projects. In general, the
smaller the budget, the larger the share that
each project can take home should be.
2.4
Off-taker restrictions
No off-take restrictions in the overall auction.
However, limitations apply within each budget basket. Please refer to
section 1.13
2.6
Regulations for transporting
hydrogen
Infrastructure costs can be priced into the bid but there is no explicit
mechanism to offset comparative disadvantage of projects with in-
frastructure costs.
Denmark welcomes the design element. It
would be inefficient to let projects offset infra-
structure costs in the bid, as a lower infrastruc-
ture cost implies a lower total cost of produc-
tion, transport and utilization of the hydrogen.
It makes terms and conditions less transparent
for bidders.
2.7
Consideration of “General
measures”
1
See section 4 of the Terms & Conditions on cumulating support un-
der auction with other public support.
1
(e.g. green premium stemming from regulations)
9
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0010.png
No.
Design Element
Specific implementation of the Innovation Fund renewable hydro-
gen auction
See section 4 of the Terms & Conditions on cumulating support un-
der auction with other public support.
Feedback
Substantiating evidence, data sources, back-
ground information
2.8
Cumulating support under
auction with other public sup-
port for RFNBO hydrogen pro-
ducer
Cumulating support under
auction with other public sup-
port for RFNBO hydrogen off-
taker
Exclusion of cross-subsidisa-
tion of “grey” hydrogen
2.9
See section 4 of the Terms & Conditions on cumulating support un-
der auction with other public support.
2.10
Beneficiaries will need to provide certification that the total volume
of hydrogen produced by the supported capacity achieves at least
70% GHG savings following the rules set out in the Delegated Act
C(2023) 1086 supplementing Directive (EU) 2018/2001 (on average
during the disbursement period of the scheme). The certification will
be required as a deliverable for the last work package (independent
third-party certificate or audited reports).
Denmark supports the requirement of exclud-
ing cross-subsidisation
of “grey” hydrogen. The
requirement aligns with RED III’s emphasis on
and requirements for green hydrogen and pro-
vides safeguards for the green value. Further-
more, sector-specific requirements for RFNBO
uptake in ReFuelEU Aviation and FuelEU Mari-
time are expected to increase the demand for
hydrogen certified in line with DA
C(2023)/REDIII.
III.
No.
Design elements defining the auction procedure
Specific implementation in Innovation Fund renewable hydrogen
Auction
No discrimination against participants in auction.
Transparency on requirements and sufficient lead times to prepare
bids.
Total available budget with possible 20% budget flexibility is a limit-
ing constraint.
No ex-post adjustments of auction rules.
Feedback
Substantiating evidence, data sources, back-
ground information
Design Element
3.1
Competitiveness of the pro-
cess
Denmark welcomes the focus on competitive-
ness and non-discriminatory aspects.
10
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0011.png
No.
Design Element
Specific implementation in Innovation Fund renewable hydrogen
Auction
Multiple-items
Feedback
Substantiating evidence, data sources, back-
ground information
3.2
Single vs. multiple-item auc-
tion
One-stage or two-stage auc-
tion
Auction type
Pricing rules
Minimum prices
Ceiling prices
3.3
One-stage.
3.4
3.5
3.6
3.7
Static auction.
Pay-as-bid.
No minimum price.
Disclosed ceiling price: 3.50 €/kg of hydrogen produced as a maxi-
mum bid for the fixed premium. The same ceiling price would apply
to both the general basket and the maritime basket of the auction.
rounds.
Denmark acknowledges the reduced disclosed
ceiling price, as the clearing price of the first
auction was considerably below the ceiling
price.
3.8
Clearing mechanism and mar-
ginal bid
Bids are awarded based on the bid price until the total budget avail-
able for the auction is allocated.
Proposals whose requested grant amount fits within the Innovation
Fund call budget will be also assessed against operational capacity
and the relevance and quality award criteria, on a pass/fail basis.
The last bid that exceeds the total budget available will be added to
the reserve list.
The European Commission may decide to make use of a flexibility
rule of up to an additional 20% of the total budget available.
The maritime basket will be cleared first. If a portion of the budget
remains unawarded in the maritime basket, that amount will be
transferred to the general basket.
If a portion of the budget remains unawarded in the general basket,
that amount will be transferred to the maritime basket and the
clearance of the latter revised with the additional available budget.
Any remaining budget afterwards will be transferred to the next
auction.
11
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0012.png
No.
Design Element
Specific implementation in Innovation Fund renewable hydrogen
Auction
For proposals with the same bid price, a priority order will be deter-
mined according to the following approach:
Successively for every group of ex-aequo proposals, starting with the
lowest bid price group, and continuing in descending order:
1)
2)
Proposals with the overall smaller maximum grant require-
ment will be considered to have higher priority.
If this doesn’t allow to determine the priority, proposals lo-
cated in a country
2
with fewer funds awarded previously
under the Innovation Fund will be considered to have
higher priority.
If this also doesn’t allow to determine the priority, then
proposal with a shorter time until entry into operation are
considered to have higher priority.
Feedback
Substantiating evidence, data sources, back-
ground information
As an example - if there is 10 mio. funding left and
there is projects for
Under the current scheme, you get
1.
2.
3.
1 million
–
9 million remains
2 million
–
7 million remains
5 million
–
2 million remains
3.9
Tiebreaker rule
A design where tiebreaker rule 1 favors the
larger maximum grant would ensure that more
of the total allocated auction budget is utilized.
This rule would only apply to the final bids, with
an additional condition that if the remaining
budget after the last bid is larger than the next
highest maximum grant, that grant is skipped in
favor of the next one in line.
Furthermore, this approach would encourage
producers to bid their maximum amounts in-
stead of smaller ones if they think they are
among the last winning bids. This optimizes in-
centives in the auction.
For a total of 1+2+5 = 8 million in funding
With the alternative you get
1.
2.
3.
4.
7 million
–
3 million remains
5 million is skipped since 5 million > 3
million
2 million
–
1 million remains
1 million
–
0 million remains
3)
For a total of 7+3+1 = 10 million allocated in fund-
ing.
This is 2 million more than under the previous
scheme.
3.10
Minimum volume of bidders
All conditions are set ex ante; the auction volume will not be
adapted to the observed participation, except for the possibility of
applying of a budget flexibility rule of up to 20% of additional
budget.
2
From the EEA.
12
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0013.png
IV.
No.
Design elements defining rights and obligations
Specific implementation in Innovation Fund renewable hydrogen
Auction
3 years.
The maximum time to entry into operation is defined as the period
between signature of the grant agreement and entry into operation.
Feedback
Substantiating evidence, data sources, back-
ground information
1)
Access to RE is considered a crucial factor in
the bidding. I.e. many Danish actors are ex-
pected to utilise RE from the offshore wind
tenders with a deadline for entry into oper-
ation in 2030.
Data from the pilot auction indicates that
several projects are expecting to use EU
electrolyser technology. If the entry into op-
eration deadline is reduced, it should be
considered whether EU manufacturers
have enough production capacity to meet
the demand.
A three-year period to obtain the correct
approvals and complete a plant project
could pressure the authorities' processing
time. If the commissioning time is changed,
it should be considered whether there is
enough time for informed processing of
projects, particularly to ensure the safety of
both people and the environment.
If the maximum time to entry into operation
is reduced, it could be considered to intro-
duce differentiated timelines depending on
the plant’s end product.
A reduced period
for commissioning could impact projects
aimed at producing PtX fuels such as ammo-
nia and methanol. These projects are more
advanced and likely require more time for
commissioning.
Design Element
4.1
Maximum time to entry into
operation
Denmark is hesitant to reduce the maximum
time to entry into operation from 5 to 3 years.
2)
3)
4)
4.2
Sanctions in case of non-com-
pliance with support require-
ments
If the maximum time to entry into operation is exceeded, the grant
agreement will be terminated, and the granting authority will call the
completion guarantee described in point 2.2
A project entering into operation should be able to demonstrate as
operational a nameplate capacity of at least 100% of that expressed
Unclear wording on the termination of grant
agreement. Could be beneficial to outline what
“may be terminated” implies.
13
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0014.png
No.
Design Element
Specific implementation in Innovation Fund renewable hydrogen
Auction
in the bid. The entry into operation needs to be approved by the
granting authority.
Further, the grant agreement may be terminated and the grant re-
duced if the verified and certified RFNBO hydrogen production falls
on average below 30% of the expected yearly average volume as
stated in the bid for three consecutive years. This average will be cal-
culated over a rolling 3 year period.
If the project cannot certify that the overall total amount of hydrogen
produced achieves at least 70% GHG savings (see point 2.10), the
grant may be reduced.
If a project was awarded under the maritime basket, it will have to
demonstrate during implementation that at least 60% of the total vol-
ume of hydrogen production as stated in the bid will be directed to a
maritime off-taker. If the project is not able to demonstrate signed
contracts for 60% of the production volumes with a maritime off-
taker at the moment of reaching Financial Close, it will be terminated.
At the end of the implementation period, the project will have to
demonstrate the compliance with this requirement. Non-compliance
will result in proportional reduction of the maximum grant.
Feedback
Substantiating evidence, data sources, back-
ground information
4.3
4.4
Payment schedules
Reporting requirements
Semi-annual (every 6 months after entry into of operation)
Until entry into operation, projects will have to report annually on
their progress and on key milestones such as reaching financial close
and entry into operation.
After entry into operation, projects will report periodically alongside
their requests for payment. Reports will concern the verification and
certification of the produced volume of RFNBO hydrogen.
The beneficiaries will need to provide certification that the total vol-
ume of hydrogen produced during the support period achieves at
least 70% GHG savings according to the rules set out in the Delegated
Act C(2023) 1086 supplementing Directive (EU) 2018/2001 (calcu-
lated and certified at the end of the support period of the scheme).
Certification can be provided by a third party or through audited re-
ports.
Beneficiaries awarded under the maritime basket will report periodi-
cally, alongside their request for payment, on the status of off-takers
14
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0015.png
No.
Design Element
Specific implementation in Innovation Fund renewable hydrogen
Auction
and the sectors towards which the production of hydrogen is being
directed.
The beneficiaries will report periodically, alongside their request for
payment, on the absence of cumulation as stipulated in the section
4.
To fulfil the call objective of price discovery and contribution to mar-
ket formation, the bid components of successful applicants
3
, will be
published. Bid prices of non-successful applicants will be published in
an anonymized way. Off-take prices of all proposals will be published
in an anonymized and aggregated way to avoid identification of ap-
plicants or their customers.
Feedback
Substantiating evidence, data sources, back-
ground information
V.
No.
Design elements defining the auction and framework conditions
Specific implementation in Innovation Fund renewable hydrogen
auction
To be defined based on participation received in previous auctions.
Feedback
Substantiating evidence, data sources, back-
ground information
Design Element
5.1
Scheduling/auction frequency
Clarity on frequency would be useful for mar-
ket actors, and could further efficiency and pre-
dictability.
The developers face uncertainty due to spo-
radic planning. This potentially forces less ma-
ture projects to participate in an auction before
they are truly ready. This increases the risk of
immature projects receiving support, which
could lead to wasted funds or potentially re-
duce the effectiveness of the support.
5.2
Timing of the auction (early
stage or late-stage auction)
Late-stage auction.
3
Namely bid price, volume and capacity as well as the name of the applicant, anonymized and aggregated off-take prices as stated in the financial information file.
15
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0016.png
No.
Design Element
Specific implementation in Innovation Fund renewable hydrogen
auction
Climate, Infrastructure and Environment Executive Agency (CINEA)
Feedback
Substantiating evidence, data sources, back-
ground information
5.3
Granting authority
VI.
No.
6.1
6.2
6.3
Qualification Requirements
Feedback
Substantiating evidence, data sources, background information
Design Element
Admissibility
Eligibility
Assessment of renewable elec-
tricity sourcing strategy
Assessment of the hydrogen
off-take and price hedging
strategy
Assessment of electrolyser
procurement strategy
Assessment of environmental
permits
Completion guarantee letter
of intent
Assessment of maturity
6.4
6.5
6.6
6.7
6.8
VII.
No.
Rules for cumulation of support
Feedback
Substantiating evidence, data sources, background information
Design Element
16
 EUU, Alm.del - 2023-24 - Bilag 572: Notat samt høringssvar vedr. opdaterede vilkår og betingelser for Innovationsfondens 2024 auktion for RFNBO-brintproduktion
2880025_0017.png
7.1
Cumulation Rules
VIII. Other Comments
No.
8.1
Design Element
Feedback
Substantiating evidence, data sources, background information
17