Business Day

Private sector working with state would give hydrogen the green light

SA is now almost at the point where the transition from grey hydrogen to blue and green can begin

- Claire Tucker ● Tucker is head of public law & regulatory practice at Bowmans SA.

The government has ambitious plans for SA to become a global player in hydrogen production, particular­ly in the blue and green end of the hydrogen spectrum, while decarbonis­ing the economy. These plans are spelt out in the Hydrogen Society Roadmap published by the department of science & innovation in February as a national co-ordinating framework for the country’s hydrogen economy. Global hydrogen usage will more than double by 2030 and increase six-fold by 2050, according to the road map. It also says the dominance of grey hydrogen, the least environmen­tally friendly form of hydrogen, will give way to blue (where much of the carbon emitted in production is captured and stored) and green (the cleanest form of hydrogen, made using renewable energy sources and with zero carbon emissions).

With countries like Japan signalling their intentions to import significan­t volumes of carbon-free hydrogen and Europe racing to reduce its reliance on fossil fuels, the blue and green hydrogen export market is an opportunit­y ripe for the picking.

How far is SA on the road to becoming a global player in the blue and green hydrogen market (bearing in mind that the country, through Sasol, supplies 2% of the world’s hydrogen, all of it grey)? And how realistic is it for the country to set its sights on such an ambitious goal?

According to the road map, SA has a competitiv­e edge. In its favour are an abundance of renewable energy sources for green hydrogen production, ample reserves of the platinum group metals used in the production process, five active hydrogen research & developmen­t (R&D) programmes at universiti­es and scientific councils, and patented technologi­es such as Sasol’s Fischer-Tropsch process.

SA has been preparing to enter the hydrogen economy for more than 15 years. As far back as 2007, the cabinet approved the Hydrogen SA Strategy, which has been steadily unfolding since. Pilot projects and feasibilit­y studies are under way.

Capturing carbon is a key component of blue hydrogen production, and two pilot projects have been lined up for carbon capture, usage and storage (CCUS). One project focuses on creating a CCUS site in an identified priority area in Mpumalanga. The second aims to create CCSU sites on a national scale.

Other pilot projects are planned to determine the feasibilit­y of green hydrogen in different sectors. For example, the Hydrogen Valley or Platinum Valley Project, which is investigat­ing the feasibilit­y of developing catalytic green hydrogen hubs in Johannesbu­rg, Durban/Richards Bay and Mogalakwen­a/Limpopo.

Another such example is the CoalCO2-X Project, which aims to use green hydrogen and pollutants found in flue gas from coal-fired boilers to make value-added products. Then there is the Boegoebaai study in the Northern Cape, which started in June 2021 and is expected to take 24 months to complete. The project will involve Sasol and aims to determine whether an export hub for green hydrogen and ammonia is feasible.

It seems we are now almost at the point where the transition from grey hydrogen to blue and then green can begin. From a regulatory point of view, there is little standing in the way of SA starting its clean hydrogen journey.

Most of the green hydrogen SA will produce is likely to be exported. As such, the regulatory regime for measuring and certifying whether the hydrogen is indeed “green” would lie in the country to which it is being exported. The EU has adopted definition­s, but these are focused on local production at this stage and not yet on imports.

In SA, the only developmen­t area for regulation is a framework to incentivis­e developmen­t of the sector and the fast-tracking of the approval processes for what may be large-scale industrial processes in underdevel­oped areas of the country.

In this regard, the power generation needs of large-scale green hydrogen plants are likely to exceed the 100MW registrati­on threshold allowed under the Electricit­y Regulation Act. The developmen­t of significan­t power resources in most areas of the country is also constraine­d by the transmissi­on network.

The Integrated Resource Plan therefore needs to be updated to specifical­ly encourage the developmen­t of large-scale private power generation plants and transmissi­on networks necessary for green hydrogen production.

The private sector and public-private partnershi­ps have an important role to play in developing the hydrogen economy, so incentives should be an important focus.

Though there are now no direct incentive mechanisms or business models that support hydrogen production, the road map recognises existing incentive opportunit­ies, such as tax incentives, that could support hydrogen production. For example, section 11D of the Income Tax Act may be used to advance R&D relating to hydrogen production as it does not circumscri­be the categories of R&D.

Special economic zones (SEZs) in those areas of the country best suited to green hydrogen production are under considerat­ion in a number of provinces. Companies operating in SEZs may have a reduced corporate tax rate of 15% and an accelerate­d 10% tax allowance on buildings (as per sections 12S and 12R of the Income Tax Act).

In addition, the Support Programme for Industrial Innovation, which is particular­ly focused on the developmen­t phase of innovative products or processes, may be used to promote the developmen­t of hydrogen technologi­es.

While there are no government grants or funding directly relating to and available for hydrogen projects, the Critical Infrastruc­ture Programme (CIP), run by the department of trade, industry & competitio­n, provides financial support to projects that alleviate dependency on the national grid. In the revised guideline to the CIP published in November 2021, support for clean or green energy infrastruc­ture was included.

Neither the Protection of Investment Act nor sectoral regulation­s restrict foreign investment­s in the energy and infrastruc­ture sectors. However, the ownership requiremen­ts in the Broad-Based BEE Act must be considered. These do not create compulsory investment thresholds, but such thresholds may be a requiremen­t for participat­ion in any government investment support scheme.

The outlook for the developmen­t of green hydrogen projects in SA seems relatively clear. The existing regulatory framework is sufficient and, while we might see further measures to incentivis­e the developmen­t of the sector and unlock approval processes, these are not needed for projects to commence.

Also important is that the private sector has already been playing a prominent role in the hydrogen strategy developmen­t. Close to 100 stakeholde­rs from the government, academia, non-government organisati­ons, and business and industry, including business associatio­ns and organisati­ons, were involved in the road map consultati­on process.

Just as crucial given the need for a unified government position is the involvemen­t of all relevant government department­s and public enterprise­s, including science & innovation; forestry, fisheries & the environmen­t; mineral resources & energy; public works & infrastruc­ture; trade, industry & competitio­n; transport; Transnet; and Eskom.

If sustained, this level of co-operation and collaborat­ion could bode well for SA’s efforts to actualise its aspiration­s as a global player in the green hydrogen market.

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