Joint Submissions: Green Hydrogen Commercialisation Strategy

The submission argues that the GHCS was developed without sufficient transparency or civil society participation and warns against over-investing in a speculative green hydrogen export market at the expense of addressing South Africa's urgent electricity crisis. It calls for a strict definition of 'green hydrogen' based on additionality, comprehensive cost-benefit analyses, and robust safety and environmental regulations before public funds are committed.

• The development of the Green Hydrogen Commercialisation Strategy (GHCS) lacked transparency and excluded civil society and academia, with the Panel being "dominated by business and industry representatives."
• The authors express concern that the GHCS was approved by Cabinet and used to draft the Just Energy Transition Investment Plan (JET-IP) before meaningful public participation occurred, potentially rendering the current consultation process ineffective.
• The submission warns against allocating R319.01 billion in government funding (2023-2027) to a "highly speculative" green hydrogen market, arguing that renewable energy should instead be prioritized for the national grid to address the energy crisis.
• Green hydrogen is identified as inferior to direct electrification for many uses due to inefficiency; for example, a hydrogen-powered car uses only 38% of original electricity compared to 80% for an electric vehicle.
• The authors argue that South Africa is at a market disadvantage for exports due to its distance from importers like Europe and Japan and its "lower-quality renewable resources" compared to closer competitors.
• A strict definition of green hydrogen is requested, specifically excluding 'blue hydrogen' (fossil fuels with carbon capture) and requiring 'additionality' to ensure production does not divert renewable energy from the national grid.
• The GHCS is criticized for lacking a cost-benefit analysis, with the authors recommending that techno-economic, financial, and socio-economic impact assessments be completed before investments proceed.
• Significant environmental and safety risks are highlighted, including the high water requirement (estimated at 34.2 million m3 annually for 3.8 Mt of hydrogen), land use (56 GW of solar would require about 1600 km2), and the risk of metal embrittlement in pipelines.

APA

Centre for Environmental Rights (2023). Joint Submissions: Green Hydrogen Commercialisation Strategy. https://cer.org.za/wp-content/uploads/2023/02/GHCS-Comments-3-February-2023.pdf?x21779

Chicago

Centre for Environmental Rights. Joint Submissions: Green Hydrogen Commercialisation Strategy. 2023. https://cer.org.za/wp-content/uploads/2023/02/GHCS-Comments-3-February-2023.pdf?x21779.

Wikipedia

{{cite press release |author=Centre for Environmental Rights |title=Joint Submissions: Green Hydrogen Commercialisation Strategy |date=3 February 2023 |url=https://cer.org.za/wp-content/uploads/2023/02/GHCS-Comments-3-February-2023.pdf?x21779 |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{centreforenvironmentalrights2023joint, author = {{Centre for Environmental Rights}}, title = {{Joint Submissions: Green Hydrogen Commercialisation Strategy}}, publisher = {Centre for Environmental Rights}, year = {2023}, month = feb, url = {https://cer.org.za/wp-content/uploads/2023/02/GHCS-Comments-3-February-2023.pdf?x21779}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }