Hydrogen law, regulations & strategy in Turkey

The Ministry of Energy and Natural Resources (“MENR”) organised an international conference on 15 January 2020 to discuss the future of hydrogen in Turkiye and to evaluate the development of a national hydrogen-strategy for the Turkish energy market (the “Conference”).

The aim of the Conference was to focus on indigenous energy sources, which includes hydrogen production from local coal mines. MENR sees hydrogen as playing an important role alongside renewables and being key to decarbonising the heating sector through the blending of hydrogen with methane in the gas distribution system. That said, the use of low-carbon hydrogen in industrial and heating processes requires more research in order to be a truly viable option in Turkiye.

On 24 January 2020, MENR published a beyaz belge (or “white paper”) to obtain opinions, proposals, and recommendations from hydrogen stakeholders in Turkiye on the future hydrogen strategy. The questions asked were:

1. What are the areas/technologies where research and development need to be strengthened?
2. What is the future of hydrogen in the transport sector and where are there still gaps?
3. What kind of strategies do you propose with regards to using hydrogen safely, as a fuel?

The deadline for the submission of stakeholder contributions was 22 June 2020 and the contributions were due to be published in an opinion document, a "blue paper”. Following this, the government planned to introduce a further opinion document, known as the "red paper", which was expected to be released in January 2021. It was anticipated that the “red paper” would set out the decisions made by MENR following the consultations. The final phase is an application document, known as the "green paper", which will show the government's method for the application of decisions. It is likely that this will include an approach towards a new legislation for promoting hydrogen developments in Turkiye.

Though no specific timeline has been stated, the short-term goal of MENR approach is to prepare test projects to strengthen the organisational structure and research and development of hydrogen potential in Turkiye. Unfortunately, none of the papers have been published as of October 2021.

That said, the long-term objectives are the improvement of infrastructure and the preparation of necessary legislation that will govern the production, transmission, distribution, and use of green hydrogen, based on renewable energy resources, for use in the Turkish industrial and transport sectors (vehicles, railways, and shipping). The establishment of reliable and long-term storage of hydrogen and the development of local fuel cell technology for the transport sector is also considered one of the most important parts of the planned roadmap.

In addition, the Minister of Energy and Natural Resources (“Minister”) gave a statement on widening the usage of hydrogen in multiple areas, including renewables, heating, and transportation in the Scout Meetings in Energy Workshop. By increasing the use of hydrogen, Turkiye aims to take a step towards using clean resources and consequently becoming less dependent on imported energy. Within this scope, in April 2021, Turkish Natural Gas Distributors Association (“GAZBIR") has established the Clean Energy Technology Centre with its own undertaking Gazmer. Accordingly, the Clean Energy Technology Center is conducting studies and tests for blending natural gas and hydrogen which is aimed to be used in households.

Transportation

The Regulation on Rules and Procedures Regarding Increasing Energy Efficiency in Transportation aims to ensure energy efficiency using environmentally friendly fuels, such as hydrogen. It recognises the importance of using hydrogen in transport as a clean fuel in Turkiye. As such, several projects have been developed by universities and institutions, particularly by the Turkish Council for Scientific and Technological Research (“TÜBİTAK”) and the Turkish International Boron Research Institute (“BOREN”). The majority of hydrogen developments in the Turkish transport sector focus on hydrogen fuel cells.

Two projects, the "Development of Boron-based Hydrogen and Fuel Cell System for Unmanned Aircraft" and "Boron-based Fuel Cell Range Intensifier for Electric Vehicles", were completed by the Competence Centre for Boron and Hydrogen Technologies. In addition, two hydrogen-powered vehicles were developed through a cooperation between BOREN and TÜBİTAK. Bormobil, one of the vehicles, has a top speed of 100km/h and a potential range of 450km, using hydrogen fuel. 1 https://fuelcellsworks.com/news/turkey-tubitak-mam-energy-institute-premiers-hydrogen-vehicle/  The second vehicle, which has a battery capacity of 40kWh, has a hydrogen production system and an integrated fuel cell. The hydrogen production system increases the range of the vehicle from 250 to 400 km.

The Hydrogen Technologies Association (the “Association”) was founded in 2015 with the aim of developing hydrogen technologies through cooperation with a variety of educational institutions and private and public bodies, contributing to research and development projects and providing financial support. The Association stated that, in addition to the above-mentioned electric vehicles, hydrogen-powered private and public vehicles will also be produced.

The use of hydrogen in fuel cells (and other forms) in large road vehicles is currently being considered in Turkiye. MENR is considering producing hydrogen from local coal and using it for transportation purposes. According to MENR, the production of hydrogen is still not cost-effective in Turkiye. However, hydrogen in transportation may be viable and efficient considering that an ordinary bus in Turkiye could travel 1030 km on hydrogen produced from one tonne of local coal.

The use of hydrogen to decarbonise public road transport, especially buses, has gained popularity. The first hydrogen-powered bus project in Turkiye was completed as far back as 2012. This project was designed by ICHET in cooperation with other institutes. The bus was used for two days to test and analyse how the technology could be used to help develop Turkiye’s hydrogen economy. The project was a success, achieving a fuel efficiency of 15%, thus paving the way for future bus projects.

Industry

In 2011, a hydrogen energy production plant was commissioned on the island Bozcaada, as part of the Bozcaada Hydrogen Energy Project. This pilot plant was built in a cooperation between the United Nations Industrial Development Organisation (“UNIDO”) and ICHET, with the support of MENR. The cost of the plant was $1.5 million and was tested for two years.

One year later, the hydrogen production and filling plant, Hidrojen Üretim ve Dolum Tesisi, was built in Halic, Istanbul, with a capacity three times larger than the plant on Bozcaada. The plant in Halic can refuel vehicles that run on hydrogen, i.e. hybrid fuel cell electric vehicles (“FCHEV”) and fuel cell electric vehicles (“FCEV”). Ferries and ships that use hydrogen as fuel can also use the plant. The plant continues to be operational in this capacity.

The hydrogen used in Turkish industry is mainly produced from fossil fuels, i.e. natural gas, oil, and coal. Hydrogen is currently used in the fertiliser industry, in the production of vegetable oil and petrochemicals, and the production of gas and liquid hydrogen in pressure cylinders for various processes in Turkiye.

At the Conference, MENR stated that the development of a local hydrogen industry is one of its priorities and that studies are already underway.

Heating

MENR has stated that decarbonisation of heating is a key aim of Turkiye’s energy strategy. To that end, GAZBIR has carried out blending trials in the Clean Energy Technology Center in the Anatolia region of Konya. 2 https://www.kallanishenergy.com/2020/07/30/turkey-tests-20-hydrogen-gas-blend-for-heating/ This project has trialled a 20% hydrogen blend into the domestic gas network. MENR's goal is to complete the first set of trials by the end of 2021 and to replace 2-6% of methane gas supplied by the grid with hydrogen.

According to MENR's statements during the Conference, its approach to hydrogen production has four main aims:

1. creating more renewable energy for Turkiye;
2. ensuring emission-free production in the heat sector;
3. producing hydrogen from domestic coal; and
4. increasing the use of boron and its use in hydrogen storage.

MENR is determined to increase the use of hydrogen and, as mentioned above, a white paper outlining MENR’s approach was prepared to obtain opinions, proposals, and recommendations from hydrogen stakeholders in Turkiye, regarding the future strategy of hydrogen energy. The main purpose of this paper is to develop a local hydrogen strategy in two phases: short-term and long-term.

The financing of existing projects varies; some projects are funded by the private sector while others are supported by the Turkish government. However, the private sector also needs government assistance to produce hydrogen due to the high costs currently involved. Although many universities and institutions in Turkiye carry out projects using their own funds, support from the State is needed to complete large-scale development and implement projects that use hydrogen as an energy resource.

Lack of legislation

At present, Turkiye has provisions to promote the use of hydrogen, such as the Rules and Procedures Regarding Increasing Energy Efficiency in Transportation, which is discussed below. However, there are no detailed provisions governing the production of hydrogen and the supervision of organisations that carry out hydrogen production. This lack of legislation in Turkiye prevents the development of hydrogen energy and creates uncertainties that need to be removed before the hydrogen economy can develop. Accordingly, MENR has stated that the creation of efficient legislation is considered one of the long-term goals of the government.

Cost effectiveness

At present, hydrogen is three times more expensive than traditional fuels, and its use as a common fuel resource depends on technological developments to reduce the cost of hydrogen production. 

Inadequate infrastructure 

One of the biggest obstacles to the use of hydrogen as energy in Turkiye is inadequate infrastructure regarding the production, transmission, and utilisation of hydrogen in the industrial, transport, and heat sectors. 

Although there are no provisions specifically governing the production of hydrogen (or its associated transport and storage), there are certain provisions that indirectly relate to hydrogen. Various legislation covers the regulation of liquified petroleum gas (“LPG”), electricity, and natural gas markets. However, none specifically define “gas”; as such, it is unclear how hydrogen will be regulated. This lack of legislation is acknowledged by the Turkish government and the preparation of adequate legislation is one of the long-term objectives of the hydrogen strategy being prepared by MENR.  

Legislation

The Regulation on Increasing the Efficiency and Use of Energy Resources sets out rules and procedures to promote the use of clean fuels, such as hydrogen.  Under Article 30(6) of the Regulation, state institutions and organisations that carry out or support research and development projects relating to hydrogen must give priority to projects involving hydrogen production technologies that use renewable energy sources, such as water, wind, solar, and geothermal energy.

The Rules and Procedures Regarding Increasing Energy Efficiency in Transportation came into force on 2^nd May 2019. Its purpose is to promote environmentally friendly alternative fuels; hydrogen is counted among these alternative fuels.

Action plans regulated and published by the government are essential to the deployment of hydrogen in Turkiye. Accordingly, hydrogen energy was mentioned in the National Energy Efficiency Action Plan (the “Action Plan”) that was published in November 2017. With regards to the development of public transport in Turkiye, the Action Plan aims to promote the use of environmentally friendly, lightweight, electric or hybrid, hydrogenated, natural gas-powered vehicles by 2023.

There are no regulatory authorities that regulate the development, construction, and operation of hydrogen projects in Turkiye. Studies on the production of hydrogen energy are carried out by BOREN, an affiliated institution of MENR. 

A supervisory authority to oversee the production of hydrogen or other hydrogen projects has not yet been established in Turkiye and, as such, the licensing requirements for hydrogen have not yet been defined. 

The Hydrogen Technologies Lab, which is managed by BOREN, was founded in 2018. Its aim is to put into operation the necessary technological environment to promote the use of hydrogen as a clean energy resource, as well as the research and development of techniques and methods to increase energy efficiency. Accordingly, a cooperation protocol has been signed between 16 universities and public institutions to carry out research and development in the field of hydrogen energy and to initiate projects that will help to develop this technology. Research and development are on-going, and it is not yet known when results will be publicised.

Feasibility studies for the construction of hydrogen production plants in Zonguldak, Samsun, Sinop, and Giresun are underway. There are also plans to build hydrogen production plants on Turkish waterfronts, however there have been no official statements about when the plants may be operational.

In February 2020, two hydrogen-powered vehicles were developed by BOREN and TÜBİTAK. One of the vehicles, Bormobil, is designed to be a domestic car that uses boron for hydrogen storage. The car operates very quietly and has zero emissions but has a top speed of 100km/h. Currently, it has a range of 300km using electricity, but this could be extended to 450km using hydrogen fuel. 3 https://fuelcellsworks.com/news/turkey-tubitak-mam-energy-institute-premiers-hydrogen-vehicle/  The second vehicle, which has a battery capacity of 40kWh, has a hydrogen production system and an integrated fuel cell. The hydrogen production system increases the range of the vehicle from 250km to 400km.

The upcoming 23^rd World Hydrogen Energy Conference (“WHEC 2022”) will be held in Istanbul between 26 and 30 June 2022. According to Prof. Dr. Ibrahim Dincer, Chairman of WHEC 2022, hosting such a conference in Istanbul will attract researchers from every part of the world to promote hydrogen energy systems and share their innovative ideas and future plans. Also, he has stated that Turkiye is dedicated to increase the share of renewables in its energy supply and considers hydrogen energy systems as a potential solution to this. In conjunction with this intention, Turkiye has expanded its research, innovation, and technology development activities to produce, store, and use hydrogen in an affordable, reliable, safe, clean, and sustainable manner. 4 https://whecistanbul.org/

Potential Steps for Turkiye’s National Hydrogen Strategy

Understanding the opportunities presented by hydrogen energy to reduce dependence on energy imports plays a crucial role in the construction of Turkiye’s National Hydrogen Strategy. According to the green hydrogen potential revealed by an analysis examined in the report “Turkey’s Prioritized Fields for National Hydrogen Strategy” that was published in February 2021 by the Shura Energy Conversion Centre and Bilkent University Energy Policies Research Centre – approximately 5% of Turkiye's total energy consumption can be replaced by hydrogen and this could play an important role in reducing Turkiye's import dependency on natural gas and other imported fossil fuels. In addition, it will appear as an alternative in terms of supplying the energy needs of areas that consume intense energy such as heavy industry and transportation

Hydrogen could also be exported to the EU and other neighbouring countries and regions through the transportation pipelines. According to Cristian Carraretto, Associate Director of Green Economy and Climate Action at the European Bank for Reconstruction and Development (“EBRD”), the notable renewable energy record of Turkiye is of significant importance for developing renewable hydrogen, and there is a window of opportunity for Turkiye to produce green hydrogen with the purpose of exporting to Europe. 5 https://www.aa.com.tr/en/energy/renewable/green-hydrogen-could-be-new-player-in-turkey-s-exports-to-europe/32966

Measuring the costs and social, economic, and environmental benefits of hydrogen production will ensure that the many sectors where green hydrogen can be used are fully addressed. Implementation of market-based mechanisms to reduce energy-related CO2 emissions will increase Turkiye's industrial competitiveness.