Power-to-gas plants and their role in the electricity balancing market

This LAP is concerned with the status of, and legal coverage for, Power to Gas systems operating to provide ancillary services and specifically for demand side load balancing services


Balancing and Ancillary Services Markets. Balancing refers to the situation after markets have closed (gate closure) in which a TSO acts to ensure that demand is equal to supply, in and near real time.
An important aspect of balancing is the approach to procuring ancillary services.
Is it a barrier?
Assessment Severity
Industrial load size electrolysers are allowed to work as an ancillary service from the load point of view.


Question 1 Are electrolysers able to participate in the 3 ancillary services? If yes, please specify.
No. In Spain the 3 different ancillary services are regulated just for electricity producers. The electrolysers are allowed to balance the network under the interruptibility service which is a Demand Side Response type of ancillary service for power balance. As requirement, the electrolyser has to be connected to the High Voltage Network. Due to it, the hydrogen production falls under this service. Ancillary services for frequency balance are, nowadays, based on the generation side. There are expectations from the DSO that in the future, this ancillary service for frequency will be also available from the demand side, but there is no regulation about the topic in Spain right now.
Describe the comparable technology and its relevance with regard to hydrogen
Industrial loads.

National legislation:

EU Legislation:

  • Directive 2012/27/EU of the European Parliament and of the Council of 25 October 2012 on energy efficiency
    This Directive establishes a common framework of measures for the promotion of energy efficiency within the Union in order to ensure the achievement of the Union’s 2020 20 % headline target on energy efficiency and to pave the way for further energy efficiency improvements beyond that date.

    It lays down rules designed to remove barriers in the energy market and overcome market failures that impede efficiency in the supply and use of energy and provides for the establishment of indicative national energy efficiency targets for 2020.
  • Commission Regulation (EU) 2017/2195 establishing a guideline on electricity balancing
    This Regulation lays down a detailed guideline on electricity balancing including the establishment of common principles for the procurement and the settlement of frequency containment reserves, frequency restoration reserves and replacement reserves and a common methodology for the activation of frequency restoration reserves and replacement reserves.