Even with an energy mix where nuclear has a strong footprint, in France there is still good ground for further deployment of Fuel Cell micro-Cogeneration units, especially if fuelled by green gas. Nevertheless, without a fair valorisation of the technology and an adequate recognition of its benefits in the upcoming national building code Réglementation Environnementale, coming into force in 2019 and replacing the current Réglementation Thermique 2012 (RT2012), the large-scale uptake of Fuel Cell micro-Cogeneration technologies in France is endangered. In this context, the adoption of the following recommendations would be beneficial for the Fuel Cell micro-Cogeneration market development, even more with regards to the implementation of the new building code:
- Concerning the definition of the perimeter, optimisation is made at a building level rather than at a territory level, and this is a burden for cogeneration. Optimisation at territory level would fully and fairly into account energy savings from decentralised power production instead.
- In the existing Réglementation Thermique 2012, ICE and Stirling micro-Cogeneration technologies are relatively well integrated, being considered as an alternative to renewables, as they achieve significant energy savings. On the other hand, for Fuel Cell micro-Cogeneration, which has just entered the market, an application will be sent to the authorities under the RT2012, in order for fuel cell units to become eligible as of 2017 under the current building code. Nevertheless, the assumptions around the CO2 intensity of electricity from the grid (based on an average calculation of CO2 content for the different energy uses within the building), as well as the system boundaries to be included in the new building code, could undermine the position of Fuel Cell micro-Cogeneration and might even lead to their exclusion from the list of eligible technologies. In this context, a marginal or seasonal calculation of CO2 intensity of power would more fairly account for benefits deriving from Fuel Cell micro-Cogeneration instead and the introduction of a carbon bonus would better reflect CO2 savings.
- In the process of adoption of the new building code, an experimentation phase is ongoing, called Label Energie Carbone, and because of the bad positioning of Fuel Cell micro-Cogeneration, mainly due to the calculation of CO2 intensity on an average base, Fuel Cell micro-Cogeneration might be even excluded from the experimentation phase.
- Partnerships between industry, policymakers and customers are essential for the promotion of Fuel Cells micro-Cogeneration in France. At this stage, as the new building code proposal might represent a major barrier for kick-starting the French market of Fuel Cell micro-Cogeneration, the key actors to target in the process of drafting and implementing the Réglementation Environnementale, are the French Government on one hand – and namely the Direction générale de l’Énergie et du Climat (DGEC) and the Direction de l’habitat, de l’urbanisme et des paysages (DHUP) – and the industry on the other hand – i.e. the Club Cogénération of the ATEE, Engie and GRDF, and the nuclear lobby, promoting a lower CO2
To conclude, high-level and fair recognition of the environmental and energy security contribution of Fuel Cell micro-Cogeneration technologies towards the French energy transition is key for the successful mass commercialisation of these products in France. The ultimate aim is to show France that the European Union is supportive of Fuel Cell micro-Cogeneration technology, and that even with an energy mix where nuclear has a strong footprint, there is still good ground for further deployment of fuel cell units, especially if fuelled by green gas.
 In France, nuclear energy accounts for 78% of the energy mix (International Energy Agency. France – Energy System Overview. 2016. https://www.iea.org/media/countries/France.pdf Accessed 31/10/2017).