Request for Comments on Draft Guidelines for Emission Calculation from Offsite Water Drawal and Treatment under the Green Hydrogen Certification Scheme of India – EQ

Summary:

**Objective:** This document provides the operational and accounting rules for green hydrogen producers to include “upstream” water treatment emissions in their overall carbon intensity calculations. This is critical for compliance, certification, and the marketability of their hydrogen as “green.”

**Key Business Implications:**
1. **Compliance Burden:** Producers must now meticulously track not just their own electricity use, but also the energy source and efficiency of their water supply chain, whether it’s a municipal line or a remote desalination plant.
2. **Standardized Accounting:** The guidelines introduce specific scenarios (from municipal supply to captive plants) and default benchmarks to ensure all producers calculate these emissions uniformly, creating a level playing field for certification.
3. **Cost of Carbon:** The emissions from water treatment will directly impact the producer’s total GHG intensity (kgCO2e/kgH2). A higher intensity could affect the “green” premium pricing or eligibility for certain incentives.
4. **Data Management:** Producers must implement robust monitoring and verification (MRV) systems for water consumption and related energy use, as these will be audited annually.
5. **Opportunity for Optimization:** The framework encourages investment in dedicated renewable energy for water treatment and the use of waste heat or recycled water, offering pathways to lower the default emission factors and improve the project’s carbon footprint.

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### Detailed Technical Summary

These draft guidelines operationalize Section 7.4 of the GHCI, providing a mandatory framework for calculating GHG emissions from water drawn and treated offsite. The fundamental principle is that the physical act of drawing water from a source (e.g., a river) is zero-emission, but all treatment and transport emissions up to the plant gate must be accounted for within a “Well-to-Gate” boundary.

The document outlines five distinct scenarios for water sourcing and prescribes the methodology for each:

**1. Scenario A: Captive Offsite Treatment (Self-Operated)**
– **Applicability:** The producer owns and operates a dedicated treatment plant (e.g., desalination) at a different location.
– **Methodology:** Emissions are calculated using **primary data** on actual energy and chemical consumption.
– **Key Requirements:**
– Metered electricity for all stages (pre-treatment, RO, pumping).
– Use of CEA Grid Emission Factor and T&D losses if grid power is used.
– Inclusion of emissions from chemical inputs.
– If powered by renewable energy (dedicated line/PPA), load dispatch certificates are required for verification.

**2. Scenario B: State Agency or Municipal Supply**
– **Applicability:** Water is purchased from a public utility (e.g., Jal Board).
– **Methodology:** Uses a **default benchmark** defined by MNRE, as the producer has no control or insight into the utility’s operations.
– **Key Requirements:**
– Apply the “Municipal Water Supply Benchmark” from Schedule 1.
– Primary documentation is the water utility bill showing volume consumed.
– **Exemption:** If the utility can certify that the specific supply line is 100% renewable-powered, the producer can apply for a lower, verified emission factor.

**3. Scenario C: Jointly Owned or Common Infrastructure**
– **Applicability:** Water is sourced from a common facility in an industrial cluster, run by a third party or SPV.
– **Methodology:** Emissions are allocated based on the producer’s share of the total water volume.
– **Formula:** `Emission_attributable = (Q_H2 / Q_total) * E_common`
– Where `Q_H2` is the volume used for hydrogen, `Q_total` is the total volume treated, and `E_common` is the total verified emissions of the common plant.
– **Key Requirements:**
– If the common plant operator won’t share primary energy data, a “Common Desalination Benchmark” must be used.
– If the plant uses waste heat, no emissions are attributed to that heat.

**4. Scenario D: Tertiary Effluent / Recycled Water**
– **Applicability:** Using treated municipal wastewater that requires further “polishing” to meet electrolysis quality.
– **Methodology:** Emissions are counted only for the **incremental treatment** (polishing) performed after receiving the water. The initial municipal treatment is outside the system boundary.
– **Key Requirements:**
– Apply the “Recycled Water (Polishing) Benchmark” or calculate using primary data from the onsite polishing unit (as per Scenario A).

**5. Scenario E: Hybrid Supply Chains**
– **Applicability:** Using a mix of two or more of the above sources.
– **Methodology:** A **weighted average** emission factor is calculated based on the volume and emission factor of each source.
– **Formula:** `EF_weighted_avg = Σ(Qi * EFi) / ΣQi`
– **Key Requirements:** Disaggregated daily records of consumption from each source must be maintained for verification.

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