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
Operational barriers
Assessment Severity
2

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?
The answer to this question is not clearly available now from a regulation point of view. It has to be discussed with GRTgaz, the national TSO. Rules to facilitate the entry of new gas providers on the market and the access to the transport capacities available have been proposed at a European level. Since the 1 january 2016 these HAR (Harmonized Allocation Rules) are under application at the national interconnection points with the grids of the bordering countries. These rules focuses essentially on the exchange capacities exchanged internationally.
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 - Yes it could be possible, if the national rules for the specifications of the injected gas are not fulfilled (see LAP 7.1.2.).
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 - As the national law is the umbrella legislation related to the gas quality prescription, the treatment could not be more stringent than under the national law.
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?
The only limits to injection into the gas transport grid are – the acceptable capacity at the injection point (if the injection will take place at a point where the average flow rate is very high, it will probably be easier to connect than at points where the flow rate is low –for example at “delivering point near the distribution grid or near direct end–users); – the distance from the production point to the injection point (if the distance is over a few km, the costs of investment will probably be too high); – for isolated (regional) network, it will depend on the overall acceptable gas capacity, and the possibility to bypass the normally transported gas to other transport sections. Connection at the transport level generally can be done for capacities ranging between 150 and 800 Nm3/h of injected gas. Higher flow rates are possible on a case by case basis.
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. – There is no specific obligation of connection for the TSO. It will depend on the fulfilling of the normal / standard technical prescription for injection of other gas than natural gas. As pure H2 can not be injected directly, a blending unit with natural gas will have to be build to ensure the right entry composition of the gas. Perhaps there will also be a need of an odorising unit (depending on the obtained final odorant composition after mixing). ii. – The TSO has the guarantee the access to transport grid if it’s technically feasible iii. – the legal requirements are to make an official connecting demand to the TSO. Than the TSO is conducting a feasibility study to make a technical and financial proposal. After acceptation of the conditions, the TSO can begin the construction of the injection unit and the gas transport piping form the production point to the injection point.
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. – A connection assessment is done by the TSO ii. – A capacity assessment at the possible injection point is done by the TSO iii. – It can take between 9 to 24 month depending on the installations and distances to be covered from the production point to the injection point. The time to obtain the administrative agreements to transport the gas form the production point to the injection point can be long
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 - In practice 2 agreements have to be conclude: – an injection agreement where the conditions for both sides are specified; – a commercial contract with the buyer of the injected gas (as for biomethane for example). the injection can be denied if the maximum injection capacity is attained at the injection point to guaranty the normal and safe operation of the transport grid;
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 - The injection capacities have been defined and allocated before the beginning of the project. This is the aim of the “injection contract”.
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 technical requirements of the injected gas are those applicable for other gases than natural gas (see LAP 7.1.1.)
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?
One additional equipment can be required, depending on the quantities of H2 injected and if there will be a blending with natural before injection: it is the “odorising equipment” to ensure that the transported gas has an odorant at right level of concentration (to avoid dilution of the odorant in the transport grid.
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 - The TSO is responsible for the following equipment: – direct connection pipes with the grid; – injection equipment (owned and operated by the TSO and rented to the gas / H2 producer); – the odorising equipment, if there is one. The H2 / gas producer is responsible for all other equipment’s located or connected to the equipment’s of the TSO
Question 7b - Who can do the connection work (professional skills requirement)?
b - The connection work can be done by professionals witch have the professional qualification approved by the TSO.
Question 7c - Which party is responsible for carrying out the planning and establishment of the grid connection?
c - The TSO is responsible for the planning and the establishment of the grid connection
Question 8 In case of network congestion, is the TSO obliged to prioritise the injection of hydrogen instead of natural gas?
No there is no obligation to prioritise the injection of H2. The injection projects will probably be realised on a “first to come – first to be served” basis. This means that the grid capacities will be allocated to the different projects by a certain order and if the maximum transport capacities in an area are attained, no new project will be allowed to connect, until it has been assured by the TSO that the gas can be transported. This is in particular the case for bio–methane injection projects where the transport trough the grid is the only way to valorise the produced gas.
Describe the comparable technology and its relevance with regard to hydrogen
Bio–methane, SNG injection

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.