Short-run marginal emission factors neglect impactful phenomena and are unsuitable for assessing the power sector emissions impacts of hydrogen electrolysis

This comment reacts to Ruhnau and Schiele's (2023) assessment of the cost and emissions impacts of electrolytic hydrogen production operating under different green hydrogen certification requirements in the EU. We critique the paper's use of short-run marginal emissions rates to estimate emissions impacts, a methodology which the literature has shown to be inadequate for assessing the full lifecycle emissions impacts of electricity sector interventions. We hope that our response clarifies the need to consider induced structural change when assessing the greenhouse gas emissions impacts of electricity sector decisions at all scales.