Document bBnVByGqDo99ODdDNmX9bNbb0

Consultation on PFAS Restriction: Public Response This paper will discuss the wider implications of excluding electrochemical energy storage technologies which are dependent on PFAS from the European market. is currently developing iron-air batteries for multi-day energy storage at grid scale. Our product can discharge energy for 100 hours through an innovative reversible rusting process, and is based on iron, air and water as our key materials. is B2B, and will deliver batteries to industrial customers, energy developers and other businesses. Our first projects will be deployed in the United States in 2024, with European projects expected in 2026. Our European operations are currently supported by a small team within Europe, with an expectation to grow rapidly over the coming years. 's technology aims to bring solutions to several key challenges for Europe's electricity markets; solutions which would be severely impacted by a PFAS restriction. Two key areas are resilience and the integration of renewable energy. Regarding resilience, in the coming decades, electricity demand in Europe is expected to climb between 40-50%, with enormous seasonal variation in the shape and type of generation.1 As a result, policymakers must consider the volume of carbon-free generation resources that must be added to meet growing electricity demand, and the types of resources that will maintain that electricity supply reliably during all hours of the year. Offshore wind resources, for example, produce higher generation output due to increased wind speeds, but they also experience lull periods with reduced output that can last for up to 5 days. During such events, the grid requires resources that can deliver energy when it is needed, without increasing carbon emissions. Today, thermal generation in the form of open-cycle gas turbine and coal generation is largely not used to provide system reliability. However, many of these will be retired by the early-2030s, straining a system which will become increasingly dependent on variable wind and solar generation. ENTSO-E estimates that 60GW of thermal generation is at risk of becoming economically unviable by 2030, which they underline as a material challenge for Europe's energy security.2 While governments may take action to extend the lifetime of some plants through targeted supports, such investments are best made into technologies fully aligned with a decarbonized power system. Multi-day energy storage (MDS), such as that provided by 's technology, is critical to providing resilience in a fully decarbonized system. As stated in the European Commission's Staff Working Document on Energy Storage, long-duration energy storage "becomes more 1ENTSO-E & ENTSOG, TYNDP 2022 Scenario report https://2022.entsos-tyndp-scenarios.eu/wp-content/uploads/2022/04/TYNDP2022 Joint Scenario Full-Report-April-2022.pdf 2 ENTSO-E, European Resource Adequacy Assessment 2022 https://www.entsoe.eu/outlooks/eraa/2022/ a. Cost effectiveness of hydrogen for long duration storage relies on geological (as opposed to tanked) storage due to the scaling costs of longer durations. However, Gas Infrastructure Europe's 2021 study, in collaboration with Guidehouse, finds that Europe's potential for hydrogen storage (264.7TWh) falls well short of needs (466.4TWH).13 b. While there are some pilot projects underway for cavernous hydrogen storage, they remain relatively small, with just 4TWh announced.14 This is compounded by the long lead times of projects, meaning delivery will fall well short of requirements pre-2030 and compounding the need for alternatives. c. There are no commercially available gas turbines currently able to combust hydrogen at high purities. 13 Guidehouse, Picturing the value of underground gas storage to the European hydrogen system, https://www.gie.eu/wp-content/uploads/filr/3517/Picturing%20the%20value%20of%20gas%20storage%20 to%20the%20European%20hydrogen%20system_FINAL_140621.pdf 14 Remarks of Michael Kohl, Commercial Managing Director, RWE Gas Storage West GmbH at Hydrogen Horizons: Empowering the Power System with long-term seasonal storage, https://hydrogeneurope.eu/events/?he event=R8kjbKL9mnD3XGr