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BDEW-Feedback on ACER’s note „Transporting Pure Hydrogen by Repurposing Existing Gas Infrastructure“

„Overview of existing studies and reflections on the conditions for repurposing.“

BDEW supports the goal of EU climate neutrality by 2050 and the Commission's proposal for a net GHG reduction target for 2030 of at least 55 % compared to 1990. The EU cli-mate targets can only be achieved if all available decarbonization options are used in all sectors. Amongst them hydrogen will play a key role, already with regard to the 2030 targets as described in the EU Hydrogen Strategy. A harmonized legal framework for the European hydrogen market must be established without delay – otherwise the market uptake and the related development of hydrogen infrastructure at the necessary scale is likely to be jeopardized.

It is against this backdrop that the BDEW highly welcomes that ACER dedicates a com-prehensive review of existing studies on conditions for repurposing existing natural gas (NG) pipelines for the transport of climate-neutral hydrogen. The transformation of the NG networks must be taken into account when repurposing. The NG market should re-main liquid as long as possible without hindering the development towards a liquid hy-drogen market also with a view to the security of supply (cf. conditions mentioned in section 4.1. of the ACER paper). The BDEW would like to provide a first and non-exhaus-tive feedback regarding the reflections on repurposing existing pipelines and the devel-opment of the hydrogen market in general which are both subject of this feedback.

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