White Paper – Green Hydrogen Standard (MNRE, National Green

Hydrogen Mission, India)

Umagine Hydrogen Private Limited, 19.08.2023

Introduction
The objective of this white paper is to provide a critical review of these Green Hydrogen Standards
published by MNRE. The detailed analysis focusses primarily on the green hydrogen produced via
electrolysis of water using renewable energy. The white paper is divided into the following key
sections,
1. Green Hydrogen Standard for India - MNRE
2. Key areas of concern
3. Greenhouse gas emissions from electrolysis process
4. Conclusions & Recommendations

Green Hydrogen Standard for India - MNRE

The Ministry of New and Renewable Energy published the “Green Hydrogen Standard for India”
vide memorandum No. 353/35/2022-NT on the 18th of August 2023. This entails the following
definitions for green hydrogen.

1. Hydrogen produced through renewable energy, including, but not limited to electrolysis or
conversion of biomass.
2. Renewable energy may be stored in an energy storage system or banked with the grid.
3. The non-biogenic greenhouse gas emissions arising from water treatment, electrolysis, gas
purification, drying, and compression shall not be greater than 2 kg CO2e/kg Hydrogen, taken
as an average over last 12-month period.
4. The non-biogenic greenhouse gas emissions arising from biomass processing, conversion
of biomass to hydrogen, gas purification, drying, and compression shall not be greater than
2 kg CO2e/kg Hydrogen, taken as an average over last 12-month period.
5. Detailed methodology for measurement, reporting, monitoring, on-site verification, and
monitoring and certification of green hydrogen and its derivatives shall be specified by MNRE.
6. The Bureau of Energy Efficiency shall be the nodal authority for accreditation of agencies for
all the monitoring, verification, and certification for green hydrogen production projects.

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Key areas of concern
The following areas are areas of concern according to our analysis,
1. The contribution of the greenhouse gas emission of the electricity used in the electrolysis or
compression process to the 2 kg CO2e/kg Hydrogen definition. Our interpretation of this
definition suggests that this is strictly Scope 1 emissions, which excludes the greenhouse
gas emissions from electricity used. In that case, this cannot be compared with the carbon
intensity standards released by the EU or UK, which includes Scope 1 and Scope 2
emissions.
2. There is no reference to any of the globally accepted green hydrogen definitions around
additionality, geographical, and temporal correlations.
3. There is no restriction or guidelines on the source of biomass that could be used for green
hydrogen production. This could mean that generation 1 biomass (edible energy crops) could
be used for the production of hydrogen.
4. There is no definition of the greenhouse gas intensity of the biomass being used. Without
taking the negative value into account, the carbon intensity targets are very difficult to achieve
without in-situ carbon capture (in case of biogas or gasification route).
5. The definition states that the hydrogen produced is not limited to electrolysis and conversion
of biomass. There is no further elaboration of technologies and standards for other production
methodologies of hydrogen with regards to greenhouse gas emissions.

Greenhouse gas emissions from Electrolysis process

In this section, an overview calculation has been done to estimate the total greenhouse gas
emissions.
Table 1: Key Assumptions
# Description Value Source
1 Greenhouse gas emissions from Solar 50 gCO2e / kWh US DOE (1)
2 Greenhouse gas emissions from Wind 11 g CO2e/kWh US DOE (1)
3 Greenhouse gas emissions of Indian 710 gCO2/kWh CEA (2)
electricity grid including RE generation
4 Greenhouse gas emissions of Indian 810 gCO2/kWh CEA (2)
electricity grid exclusding RE generation
5 Average specific energy consumption of 60 kWh/kg Based of vendor
electrolyzers assessment

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 6 Capacity Utilization Factor Solar 25% Based on installed
plant database
7 Capacity Utilization Factor Wind 32% Based on installed
plant database

The following cases are considered,

Table 2: Cases for calculating green hydrogen emissions.

Case Description Greenhouse gas emissions (kg CO2e/kg Hydrogen)
1 100% Solar with temporal 3
matching
2a 100% Solar with monthly 37 (Real-time emissions)
2b banking 12 (Assuming excess solar generation will result in 80%
reduction in coal due to banking, averaged out over the
month)
3 100% Wind with temporal 0.7
matching
4a 100% Wind with monthly 33 (Real-time emissions)
4b banking 7.8 (Assuming excess wind generation will result in 85%
reduction in coal due to banking, averaged out over the
month)
5 50% Wind + 50% Solar with 1.8
temporal matching
6a 50% Wind + 50% Solar with 20 (Real-time emissions with 60% RE CUF)
6b monthly banking 6.5 (Assuming excess RE generation will result in 90%
reduction in coal due to banking, averaged out over the
month)

7a Oversized solar+wind with 8.8 (Real-time emissions with 85% RE CUF)

7b pumped-hydro/BESS and a 4.0 (Assuming excess RE generation will result in 95%
combined CUF 85% with reduction in coal due to banking, averaged out over the
monthly banking month)

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 Grey Hydrogen 11
Japan 7
France Ordinance 3.38
Canada ITC 4
US IRA 4
UK LCHS 4
EU REDII 3.4
Case 7b 4
Case 7a 8.8
Case 6b 7.5
Case 6a 20
Case 5 1.8
Case 4b 7.8
Case 4a 33
Case 3 0.7
Case 2b 12
Case 2a 37
Case 1 3
MNRE 2

Figure 1: Comparison of carbon intensity (kg CO2e/kg Hydrogen) (3)

Conclusions & Recommendations

On basis of the above analysis, the following can be concluded,
- Case 3 (100% wind with temporal matching) and Case 5 (50% Solar + 50% Wind with
temporal matching) are the only scenarios that have carbon intensity lower than the MNRE
standards of 2 kg CO2e/kg Hydrogen
- The carbon intensity of Cases 2a, 2b, 4a, 6a are higher than that of grey hydrogen produced
by steam methane reforming of natural gas
- Only Cases 1, 3, 5, & 7b have carbon intensity in lines with the international definitions of
green hydrogen, however the conditions around additionality and geographical correlations
are not necessarily considered.

Restricting the definition to Scope 1 only will lead to construction of hydrogen production facilities
with greenhouse gas emissions higher than that of conventional grey hydrogen. This will have severe
and disastrous consequences to the climate and is not in line with any of the principles of the
sustainable development goals.

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Considering this, we would like to strongly recommend reconsideration of this Green Hydrogen
Standard and revise the guidelines according to globally accepted definitions wherein a significant
reduction (>70%) in carbon emissions is mandatory. Additionally, the other areas of concern around
definition of biomass shall be addressed.

References
(1) https://www.energy.gov/eere/wind/articles/how-wind-energy-can-help-us-breathe-easier
(2) https://cea.nic.in/wp-
content/uploads/baseline/2023/01/Approved_report_emission__2021_22.pdf
(3) Green Hydrogen Definitions: Towards hydrogen definitions based on their emissions intensity,
International Energy Agency (IEA), April 2023

Author

Santosh Gurunath, Chemical Engineer from TU Delft,

Netherlands; has worked with Shell, McKinsey and BCG as
a technologist and strategy consultant; and has over 12+
years of experience working with hydrogen. He is currently
the CEO and Co-founder of Umagine Hydrogen Private
Limited, a company focussed on accelerating the low
carbon hydrogen economy globally.

e-mail: santosh@umagine.co.in
Co-Founder, CEO
Umagine Hydrogen
Pvt. Ltd.

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