Permission to connect/inject

This LAP concerns the permitting framework and processes required to be followed for hydrogen injection into the high pressure transmission gas grid at the TSO level, along with technical requirements for and oversight of local grid connections

Glossary:

Permission and additional restrictions regarding connection points for hydrogen compared to natural gas connection points.
Connection: “Network connection” refers to the connection of the hydrogen generating plant to the existing gas supply network, the link to the connection point of the existing gas supply network, the gas pressure control measuring system, the means for increasing the pressure and the verifiable measurement of the hydrogen to be fed.
Injection: Gas grid access (injection) is the system under which market players are allowed to use capacity in a pipeline, network, gas store or other gas facility.
The injection installation is part of the connection facility
Is it a barrier?
Yes
Type of Barrier
Structural barriers, Operational barriers, Economic barriers, Regulatory gap
Assessment Severity
3

Questions:

Question 1 What is your legal situation (requirement from legislation and administrative procedures) with regard to international interconnection for the injection in the gas grid with neighbouring countries?
There are provisions, dealt with on transmission level, regarding gas quality, gas pressure range, capacity usage and balancing energy and of course scheduling. These rules have been developed by ENTSOG and are determined in the so called network codes – based on the framework guidelines developed by ACER in line with the requirements of Regulation 715/2009. Additional requirements can be found in the Interconnection Agreements (see guideline below)
Question 2 Is it possible for a TSO to refuse to feed in hydrogen from neighbouring countries at cross-border interconnection points? a - If yes, under which conditions?
a - The question is not clear. Does it mean that hydrogen is produced in the neighbouring country and then the hydrogen is injected directly at the cross border interconnection point with another country into the grid? The TSO has to accept gas at the specified quality in terms of gross calorific value, pressure, capacity schedules etc. and the TSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO to refuse gas at the interconnection point if the gas quality doesn’t match the specifications.
Question 2 Is it possible for a TSO to refuse to feed in hydrogen from neighbouring countries at cross-border interconnection points? b - Can you have a differentiated treatment (i.e.: applying a more stringent threshold than the one applying under your national law?
b - The TSO has to accept gas at the specified quality in terms of gross calorific value, pressure, capacity schedules etc. and the TSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO to refuse gas at the interconnection point if the gas quality doesn’t match the specifications. Since gas can cross several borders on its way to the final customer, the thereto related quality has to be more or less the same on the entire route. This is exactly the aim of Regulation 715/2009. In case of countries which are not EU–MS or not Contracting Parties to the Energy Community, the conditions have to be agreed on in Intergovernmental Agreements (IGAs)
Question 3 What is your legal situation (requirement form legislation and administrative procedures) with regard to a national connection for the injection in the gas grid? Is there a difference if injection takes place in an isolated (regional) network without international interconnections?
In Austria the gas quality is more or less everywhere the same, regardless whether the connection is given to a transmission– or distribution grid. It is allowed to feed in hydrogen at max. 4% (Mol); from the technical perspective. This amount results from technical restrictions regarding the pipeline material and the material of other infrastructure equipment. So in case one would really inject 4% (mol) hydrogen into the gas grid there is a need to adapt the specified gas quality – having an impact on the gross calorific value and the Wobbe Index. So the question is not whether the injection takes place in an isolated region or not. Of course, if one injects on a regional level “only” this could have positive impacts on the appliance of the devices (not so many devices have to be adapted to the changed Wobbe Index) but on the other hand the consumptions usually fluctuates on a regional level much stronger than on an international level, thus storage possibilities for hydrogen have to be given otherwise the gas quality (de facto a mixture of natural gas and hydrogen) might fluctuate too strongly
Question 4 Connection to the gas grid of a hydrogen producing facility a - What are the requirements for connection of electrolyser plants which primarily use renewable energies to the gas supply network: i. Is the TSO obliged to connect the facilities; can TSO deny the connection and under which conditions? ii. Are there requirements for TSO to ensure the availability of connection? iii. Which are the requirements for facility operator/ h2 supplier?
a - i. – no, so far not; the TSO has to take care of a safe and reliable operation of the grid and accept gas at the specified quality – in terms of gross calorific value, pressure, capacity and schedules – only ii. – not yet; such a provision has to be implemented in the Austrian gas law respectively the thereto related secondary legislation– which is of course in line with the provisions of the 3rd package iii. – to supply gas at the specified quality at the specified pressure and according to the supply schedules
Question 4 Connection to the gas grid of a hydrogen producing facility b - Is required to conclude a connection agreement and if yes, what are the requirements for conclusion of a gas grid connection agreement: i. Connection assessment by the TSO ii. Assessment of grid compatibility by TSO iii. How much time does it take to conclude a connection agreement
b - i. – It is up to the TSO to decide on the connection requirements since it is the TSO who is responsible for the safe and reliable operation of the grids. In case the TSO agrees then a connection agreement has to be concluded ii. – yes, the TSO has to assess the grid compatibility t iii. – as long as thereto related regulations (connection of hydrogen generation facilities) have not been put in place in Austria, the question cann’t be answered
Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? a - Is a TSO obliged to feed-in the H2; can a TSO deny the injection and under which conditions?
a - not regulated yet but as mentioned above, the TSO/DSO has to take care of the safe and reliable operation of the grid, thus a feed–in agreement has to be concluded (from a reasonable perspective
Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? b - Are there requirements for a TSO to ensure a minimum feed- in capacity?
b - no, so far not. Regulations , like the regulations for the feed in of biomethane, have to be put in place
Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?
c - the supplier has to ensure that the medium transported to and injected into the grid is in line with the specifications, regarding gross calorific value, purity, pressure, temperature and time schedules
Question 6 Is there a requirement for other or additional equipment compared to a regular connection for natural gas injection in your grid? Which one?
Not clarified yet but basically one can assume that a mixture device would be needed, hence it has to be clarified who would be the owner, the operator and who would take care of the out of it resulting costs and the responsibilities
Question 7a - Please describe which party is responsible for delivering which part of the connection? For example is the TSO only responsible for delivering a connection point?
a - Not clarified yet
Question 7b - Who can do the connection work (professional skills requirement)?
b - Not regulated yet
Question 7c - Which party is responsible for carrying out the planning and establishment of the grid connection?
c - Not regulated yet
Question 8 In case of network congestion, is the TSO obliged to prioritise the injection of hydrogen instead of natural gas?
Not clarified yet
Describe the comparable technology and its relevance with regard to hydrogen
Bio methane

National legislation:

EU Legislation:

  • Directive 2009/73/EC concerning common rules for the internal market in natural gas
    Directive 2009/73/EC establishes common rules for the transmission, distribution, supply and storage of natural gas.

    Its provisions and obligations apply to Hydrogen Gas by virtue of Article 1 (2), which states that the rules established by this Directive for natural gas, including LNG, shall also apply in a non–discriminatory way to biogas and gas from biomass or other types of gas in so far as such gases can technically and safely be injected into, and transported through, the natural gas system.

    Article 25 establishes the “Tasks of the distribution system operator” which include: ensuring the long-term ability of the system to meet reasonable demands for the distribution of gas […];shall provide any other distribution, transmission, LNG, and/or storage system operator with sufficient information […] as well as to ensure that the system operator does not discriminate between system users or classes of system including, including e.g. when setting rules for the charging of system users, etc

    Article 32 sets the rules on “Third party access”: access to the transmission and distribution system, and LNG facilities shall be based on published tariffs, applicable to all eligible customers, including supply undertakings, and applied objectively and without discrimination between system users.
  • Regulation 715/2009 on conditions for access to the natural gas transmission networks
    Regulation 715/2009 sets non-discriminatory rules for access conditions to (a) natural gas transmission systems; (b) LNG facilities and storage facilities taking into account the special characteristics of national and regional markets

    To achieve this, it sets harmonised principles for tariffs, or the methodologies underlying their calculation, for access to the network, but not to storage facilities, the establishment of third-party access services and harmonised principles for capacity-allocation and congestion-management, the determination of transparency requirements, balancing rules and imbalance charges, and the facilitation of capacity trading.
  • Regulation (EC) No 713/2009 of the European Parliament and of the Council of 13 July 2009 establishing an Agency for the Cooperation of Energy Regulators
    Article 1 Project matter and scope
    This regulation aims at:
    (a) setting non–discriminatory rules for access conditions to natural gas transmission systems taking into account the special characteristics of national and regional markets with a view to ensuring the proper functioning of the internal market in gas;

    Article 8 “Tasks as regards terms and conditions for access to and operational security of cross border infrastructure
  • Commission Regulation (EU) 2015/703 of 30 April 2015 establishing a network code on interoperability and data exchange rules
    The network code on interoperability aligns the complex technical procedures used by network operators within the EU, and possibly with network operators in the Energy Community and other countries neighbouring the EU.Article 7, Measurement principles for gas quantity and quality. In addition to interconnection points, Article 17 shall apply to other points on transmission network where the gas quality is measured. Article 18 shall apply to transmission systems. This Regulation may also apply at entry points from and exit points to third countries, subject to the decision of the national authorities.