REA Response:
Enabling or requiring hydrogen-ready industrial boiler equipment 

1.	If you are responding on behalf of an organisation, please confirm the name and type of organisation you represent?
The Association for Renewable Energy & Clean Technologies (REA), the UK’s largest renewables trade association, is pleased to submit this response to the above call for evidence. 
The REA represents industry stakeholders from across the whole bioenergy sector and includes dedicated member forums focused on green gases including clean hydrogen, biomass heat, biomass power, renewable transport fuels and energy from waste (including advanced conversion technologies). Our members include generators, project developers, fuel and power suppliers, investors, equipment producers and service providers. Members range in size from major multinationals to sole traders. There are over 500 corporate members of the REA, making it the largest renewable energy trade association in the UK. 

2.	What is your main interest in relation to this call for evidence?
The REA’s ‘Strategy for Renewable Energy and Clean Technologies’, published last year, outlines the measures that need to be taken to deliver net zero and support the UK’s economic recovery. It includes a key target for heat: that the majority of energy demand for heat is met from renewable and clean technologies by 2035. The Strategy also highlights our longer- term goal that heat demand is entirely met by renewable and clean technology solutions by 2050 across the economy. This includes heat demand from industry. 
The REA firmly believe that a multi-technology approach needs to be taken to decarbonise heat, focused on adopting the right technology in the right situation. Hydrogen is part of the solution, along with electrification, biomass, biofuels, green gas and other low-carbon heating technologies.  
The REA has an active Hydrogen Working Group representing several members in this fast-moving area. This is a cross cutting group, part of the REA Green Gas Forum, which interacts with all other groups of the REA that have relevance to hydrogen, including our Renewable Transport Fuel Forum, Energy Storage, and Energy from Waste Forum. The group helps pulling together those different strands of work in a coherent way. 
In our position statement on hydrogen, we have stated that hydrogen is likely to play a key role in decarbonising hard-to-abate industrial sectors such as steel, ammonia, refineries and chemical plants, where other decarbonisation options such as electrification or bioenergy are not available. 
3.	What factors would impact the way an industrial site would decarbonise boiler processes?
Based on our members’ feedback, we believe this consultation is slightly premature, as yet there is no government commitment to establishing a hydrogen transmission system that would flow enough hydrogen for such boilers to work. This is a prerequisite for this solution to work. 
The key issue for adopting ‘Hydrogen-ready’ boilers is unlikely to be the actual combustion of hydrogen in a boiler instead of natural gas, but the complexity and cost associated with installing and operating a hydrogen grid and producing significant volumes of hydrogen in order for the industrial sector to access the hydrogen as a fuel and use such boilers. 
In addition to the above, our hydrogen members have said that natural gas flames are very different to hydrogen flames (flame temperature, emissivity, water vapour emitted per MWh of heat produced etc.) so there may be several design changes needed at industrial sites to ensure the required thermal performance is achieved. Some members have said there is little experience within the gas industry to do this, therefore the conversion effort required in practice may well be greater than that for installing alternative solutions.  
With respect to other equipment like furnaces and kilns, the modification challenges are likely to be greater because flame radiation is then critical to the thermal process and radiation from a hydrogen flame is very low compared with a methane flame, so it won’t be as easy as swapping out the burners and control system.
Other issues reported by some members: 
•	Buoyancy difference and how a blend in the boiler fuel deals with this. 
•	Flame detection system need to be updated (natural gas detectors will not work for H2)
•	Materials of construction, specifically H2 embrittlement and junction materials (leakage risk).
4.	Do you think that low carbon hydrogen is a good way to decarbonise industrial boilers? Please give details to explain your view.
Yes, hydrogen is suited to decarbonise industrial boilers as it is capable of reaching the high temperatures needed for certain industrial applications. As the CCC reports, 90 TWh of current industry fossil fuel consumption could be switched to hydrogen by 2040 and for around 15 TWh of this demand it may be the only option available –(e.g. for direct firing, for which biomass and electrification are rarely technically suited). 
However, it is important to ensure hydrogen is not advocated in preference to other options that can be more energy efficient, such as direct use of renewable electricity. When an electric boiler is available that will meet the heat requirement, then low-carbon hydrogen should not be the highest priority solution for industrial heat. For example, electric boilers would be energetically preferable to hydrogen boilers, unless there is some technical reason that prevents the direct use of electricity. Example: 100 kWh of renewable electricity are generated and can be turned into 100 kWh of heat in an electric boiler, but only around 70 kWh of heat can be made if the electricity is first converter to hydrogen and then combusted in a boiler (because the electrolyser conversion efficiency is about 70%). 
Similarly, the characteristics of biomass heat make it particularly suited to decarbonising high heat load situations and biomass heat is also one of a small number of established renewable off-grid heat sectors in the UK with firm supply chains, expertise, and investors. Biopropane and other biofuels have also a role to play to decarbonise hard-to-electrify sectors. 
In addition, it is likely that renewable electricity will continue to get cheaper in the future, with hydrogen likely to be more expensive per MWh than renewable electricity. 
It is imperative that government doesn’t default to the old thinking that ‘gas is cheaper than electricity’ and make decisions on that basis; instead, we encourage Government to be forward looking to a future with a high penetration of renewable electricity, where electricity is used first and hydrogen second, but where they work together in a complementary fashion to enable full decarbonisation. Government needs to look across all the options available. 
5.	Would other low carbon alternatives, including electrification, biofuels or CCUS, also offer a suitable way to decarbonise boiler processes? To what extent would changing energy prices influence your view?
Yes, in creating policy BEIS should take a multi-technology approach. There is no silver bullet or one size fits all approach to decarbonising industrial heat. 
As explained above, it is important to ensure that the low-carbon heating technologies that deliver heat most efficiently from an energy point of view and more cost effectively are prioritised. Hydrogen has a role to play to fill in the gaps when other more energy efficient technologies such direct use of renewable electricity or bioenergy are not possible.  

6.	How should hydrogen-ready be defined for industrial boilers? Do you have any views on the ways we have described hydrogen-ready for industrial boilers?
In our view it is paramount to clearly define ‘Hydrogen ready’. A new product would need to be fully ready not partially ready for hydrogen. If it is a new replacement boiler, the design needs to be capable of working on natural gas or 100% hydrogen (one or the other). 
We believe the phrase ‘hydrogen ready’ should not be applied to a boiler that is capable of working only on natural gas or a hydrogen/natural gas blend. Based on our members’ feedback, we would recommend that an ‘Hydrogen ready’ boiler should be made by two burners fitted into the boiler, where the second one comes alive once the hydrogen supply becomes available, i.e.  a bi-fuel boiler, not a dual fuel boiler. This would achieve a high degree of readiness.
A member of the REA, however, noted that blending is a great way for a site to transition (potentially over years) from natural gas to H2 and that a separate hydrogen burner heads will add costs. 
Other boiler design solutions that offer lower levels of readiness may be more costly and consume lots of time/manpower. This includes on site disassembly of the existing boiler, fitting of new burners, controllers, firebricks etc. There are degrees of readiness and manufacturers should not be allowed to call something hydrogen-ready unless a product offers a high degree of readiness. Furthermore, government should investigate the detailed changes and costs associated with changing over a boiler at an industrial site to hydrogen or to electricity and compare them, because an electric boiler may be a better solution from a point of view of energy efficiency.
7.	Do you agree it would be possible for equipment manufacturers to produce hydrogen-ready boiler equipment at scale and in the ways described above?
NA 

8.	Is the schematic of a typical industrial boiler system accurate? Are there additional subcomponents that should be considered?
We haven’t had comments on this question from our members, but we believe it is critical that Government gains a deep understanding of the subject before taking any decisions. This includes talking with academics and independents, fund an in-depth investigation of what would be required at a small number of specific industrial sites to change to hydrogen combustion, identify the technical challenges and costs, involve the boiler. Further deeper knowledge should be sought before decisions are made.

9.	Are the descriptions of how subcomponents would need to differ to fire hydrogen accurate?
A member commented that the burner heads would also have to be updated from standard natural gas heads, with updated control systems.

10.	How would industrial boiler subcomponents need to be modified to be hydrogen-ready? Would this differ for the various types of industrial boilers, such as high pressure steam boilers, low pressure steam boilers, and hot water boilers?
NA
11.	Do you have any views on how a hydrogen-ready definition for industrial boilers should relate to definitions for other types of equipment, including for other industrial processes, domestic and commercial heating, or electricity generation?
NA

12.	Do you have views or evidence on what the costs of installing hydrogen ready boiler equipment would be in contrast with equivalent costs for conventional equipment?
BEIS should investigate the electric boiler option and other low carbon solutions for industry as well as the hydrogen boiler option. That would help inform a decision based on what is the most cost effective solution. 
For example, a boiler operator investing in a new plant that is going to have a long life of 30 or 40 years, may prefer to buy 70 kWh of cheap electricity for an electric boiler to make 70kWh of heat, rather than buy 70kWh of more expensive hydrogen for a hydrogen boiler (which requires 100kWh of electricity plus an electrolyser plus a hydrogen pipeline infrastructure that needs to be paid for). Therefore, it’s likely that the Capex of a hydrogen boiler will need to be very low when compared with an electric boiler if it’s to compete on economic grounds. BEIS need to unpack those economic considerations, not just analyse hydrogen ready boilers in isolation. 
13.	Do you have views or evidence on what the costs of converting hydrogen ready boiler equipment to use hydrogen would be in contrast with equivalent costs for converting conventional equipment?
NA

14.	Do you have any views or evidence on the time and complexity of installing hydrogen-ready boiler equipment, when compared to installing conventional equipment?
NA
15.	Do you have any views or evidence on the time and complexity of converting hydrogen-ready boiler equipment to use hydrogen, when compared to converting conventional equipment?
NA
16.	How might the risk of not accessing hydrogen impact decisions to deploy hydrogen-ready boiler equipment?
NA
17.	Are there any other commercial, operational, or environmental factors that might affect whether a site installs hydrogen-ready boiler equipment?
See our response to question 3. 

18.	Overall, do you agree it could be beneficial for industrial sites to deploy new boiler equipment that is hydrogen-ready? Please give details to explain your view.
Yes it would be beneficial for industrial sites to deploy boiler equipment that is hydrogen ready when this is the most energy efficient and cost effective route. 

19.	Considering the possible levers available, do you have any views on whether government should enable and/or require industrial boiler equipment to be hydrogen-ready?
Although the regulatory route is the most effective, as explained above it may be premature.  Some members are rightly worried that introducing a regulatory requirement will risk adding costs for industry that turn out to be unnecessary if hydrogen ends up not being delivered to scale. Prior to take any decisions, the following comparisons should be made:
•	With the costs of switching industrial boilers to electricity and other alternative low-carbon heating options that are suitable for industrial applications; and
•	Various levels of hydrogen grid provision for industry should be compared, such as: piping hydrogen to the main industrial clusters only; a “clusters plus” approach for key regions of industry; piping it to a large part of the industrial sector; or piping it to all of industry. Until this type of analysis has been undertaken, we urge the Government to be cautious about introducing a blanket regulatory requirement for hydrogen ready boilers or other gas-fired equipment. 
Some members have said they would support mandating hydrogen ready industrial boilers to support the supply of low (trending to zero) carbon hydrogen, as they believe that this would stimulate an innovative and internationally competitive UK supply chain.

20.	How do you think the market for hydrogen-ready boiler equipment would develop without regulation?
NA
21.	Do you agree with the benefits and risks presented of requiring boiler equipment to be hydrogen-ready? Are there any other factors to consider?
NA
22.	Overall, do you agree that it would be beneficial for government to require boiler equipment to be hydrogen-ready? Please provide details for your views.
NA
23.	If government required industrial boilers to be hydrogen-ready, what would be the implications for other types of equipment used for combustion of fossil fuels? (e.g. domestic and commercial boilers, industrial kilns, furnaces, ovens, dryers, and electricity generating equipment.)
NA
24.	Do you have any views on what kind of regulatory approach might be suitable for requiring the deployment of hydrogen-ready industrial boiler equipment?
Government may want to consider the merit of introducing a “hydrogen zoning approach” similar to the approach being proposed for heat networks. This could for example enable zones to be identified and designated by a relevant authority in conjunction with the relevant local stakeholders (gas networks, developers etc) where the likelihood of hydrogen delivery is high and hydrogen is the only cost effective and technically feasible solution (e.g. delivering the greatest GHG savings at the lowest costs to consumers). Once these zones have been identified, then all the relevant industrial users within the zone would be required to adopt a hydrogen-ready boiler within a prescribed timeframe. Exemptions could be sought where it would not be cost-effective to do this, compared to an alternative low carbon solution. This is an option worth exploring, however, as highlighted above, further work and analysis needs to be done to understand what is the best approach. 

25.	Do you have any views on whether we should consider the potential for regulating hydrogen-ready industrial boiler equipment separately from hydrogen-ready requirements for power generation?

26.	Do you have any views on the possible exemptions presented? Are there other factors that should be considered when assessing potential exemptions?

27.	Do you have any views on the potential timing for introducing any regulation requiring industrial boiler equipment to be hydrogen-ready?
28.	Do you have any views on how potential requirements for boiler equipment might need to evolve, as options for industrial sites to decarbonise change over time?

29.	Do you think these three criteria provide the right framework to assess the merits of hydrogen-ready regulation? Please provide details.

30.	Are there other factors or criteria that should be accounted for?

31.	Are the listed services the supply chain provides for the industrial boiler market accurate?

32.	Do you agree that the existing supply chain would be able to adapt to meet potential regulation requiring industrial boiler equipment to be hydrogenready? Please give details for your views.

33.	How could the government help supply chain participants to support the deployment of hydrogen-ready boiler equipment?

34.	How much time would be needed between the details of regulation being provided and any new requirements coming into effect?
Government must give industry as much time as possible to prepare for any new requirements. We believe a year's notice is enough time to allow industry to prepare for new regulations. 
35.	By what date could supply chains enable industrial sites to meet potential new requirements for boiler equipment to be hydrogen-ready? Please give details for your views

36.	How could hydrogen-ready requirements for industrial boiler equipment support the following objectives and maximise benefits to the UK economy:

37.	Do you have any views or evidence regarding work to develop standards or regulation in other countries which would be relevant if the UK were to require industrial boiler equipment to be hydrogen-ready?

38.	Are there any other final comments you wish to make regarding this call for evidence?