France Hydrogène’s position on the role of PPA’s intermediaries

In its Q&A document on RFNBOs delegated acts, the European Commission plans to exclude PPAs concluded between a renewable energy producer and a hydrogen producer, if they are concluded through an intermediary that would be a contracting party : “the role of the intermediaries referred to in the RFNBO delegated act is
therefore limited to the role of a facilitator of such contracts but not as a contracting party”. We consider that this position does not represent the market reality, as intermediaries (and not only those acting as facilitators) are crucial to encourage the conclusion of PPAs, and thus stimulate hydrogen production, without jeopardizing the respect of RFNBOs production rules (additionality, temporal and geographical
correlations).

These intermediaries can play an important role for both parties, and do not necessarily imply a breach of the three criteria. In fact, intermediaries manage the asset’s production forecasts and bear the risk of potentialdiscrepancies that the network invoices to the producer. By protecting the parties and assuming responsibility for balancing the transmission and distribution network, they stimulate demand for PPAs. In addition, the
aggregators are licensed to access the wholesale market, acting as an intermediary between the stock exchange and the needs of both parties. Recognition of the role played by intermediaries to speed up PPAs contractualization process and for a better risk coverage of hydrogen producers is needed, as long as the underlying renewable assets providing power are clearly identified within the PPA and respects all RFNBO production rules.

To clarify this point, please refer to the linked document.