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?
No
Type of Barrier
no
Assessment Severity
0

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?
It is regulated in general by ENTSOG Network codes.
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, the network operators may refuse to feed in hydrogen at cross–border interconnection points or may apply more stringent thresholds than apply under the neighbouring country law.
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 - Yes.
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 Germany, with the aim to promote the feeding in of hydrogen and synthetic methane to the grid, both of them are included in the definition of biogas in Energy Industry Act, subject to the condition that they primarily originate from renewable energy sources. This means that privileges for biogases, regulated in part 6 of Gas Network Access Ordinance and in §19(1),§20a and §20b of the Gas Network Charges Ordinance are applicable to the injection of renewable hydrogen and synthetic methane (privileged connection, privileged injection, biogas balancing, elimination of feed–in fees, fixed payment for avoided grid costs, allocation of costs to be borne by gas network operators). There is no difference in connection procedure, but it is possible that the network operators outside Germany may refuse to feed in hydrogen at cross–border interconnection points or may apply more stringent thresholds than apply under German Law.
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. – Networks operators are obliged to connect with priority electrolyser and methanation plants which primarily use renewable energies to the gas supply network. Network operators can only deny connection or injection if this is technically impossible or would be economically unreasonable. Fluctuating feed–in owing to flexible generation of hydrogen or synthetic methane from wind or solar power, for example, will not in itself provide grounds supporting an argument for economic unreasonableness. ii. – According to §33 (2) of Gas Network Access Ordinance the network operator must ensure that the grid connection (injection facility and connection pipe line) is available for the planned injection for at least 96% of the calendar year. iii. – The facility operator must construct the facility by the terms, content and time sequence of the implementation plan, agreed between the facility operator and the network operator by the concluding of the connection contract and bear all costs arising for him .
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. – After receiving a request for connection, the network operator is obliged within two weeks to inform the connecting party wht kind of assessments are necessary to be carried out in order to get a network connection permission and which costs will be incurred by these. (§33 (4) of Gas Network Access Ordinance) Upon receipt of an advance payment by the connecting party, the network operator is obliged to carry out the necessary assessments and communicate the results to the connection party no later than three months after receipt of the advance payment. ii. – As part of the connection assessments, the network operator must in particular calculate the maximum permissible hydrogen content in its network and the permissible feed–in volume or capacity. In order to do this, the network operator must determine the factors in its network and any upstream or downstream networks which might have a limiting impact on the volume of hydrogen which can be injected iii. – The network operator is bound by a positive assessment result for a period of three months. Within this period, the network operator shall submit a binding contract offer to the connecting party. The contract offer includes the assurance of a certain guaranteed minimum feed–in capacity. The effectiveness of the grid connection contract is subject to the condition precedent that the construction of the facility is started within 18 months. (§33(6) of Gas Network Access Ordinance).
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 - According to §34(1) of Gas Network Access Ordinance the network operators must give priority to agreeing feed–in and off–take contracts with the suppliers of hydrogen and synthetic methane from primarily renewable energy sources. The network operators must give priority to injection and transport of hydrogen and synthetic methane. They are entitled to deny access or injection if this is technically impossible or would be economically unreasonable. The network operators can also deny access or injection in the event of lack of grid compliance or compatibility of the gas which would otherwise be fed in. (§36(1) of Gas Network Access Ordinance). The network operator is not required to upgrade the hydrogen compatibility of its network. The rules concerning minimum connection availability and minimum feed–in capacity do not apply in this case. The network operator is only required to increase the capacity of network, not to remedy the lack of compatibility of the network with the gas injected into it. (§34 of Gas Network Access Ordinance)
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 network operator must guarantee to the connecting party a particular minimum feed–in capacity as stipulated in the grid connection contract (§33 (6) of Gas Network Access Ordinance). This will usually be equal to the requested feed in capacity, unless the grid is unable to accommodate the requested capacity and it is not technically possible to carry out capacity–increasing measures or, such measures would be economically unreasonable
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 - All grid users are required to ensure the gas which they feed in is compatible with the grid. This means that the suppliers are required to feed in gas with properties allowing the grid to be operated and the gas to be used safety. The technical requirements for that are always based on the latest version of the DVGW worksheets. For hydrogen and synthetic methane suppliers the referent DVGW worksheets are G 260 and G 262. (§36 of Gas Network Access Ordinance)
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?
The grid connection includes the construction of the connecting line connecting the biogas processing plant (electrolyser, methanation plant) with the existing gas supply system, the link to the connection point of the existing gas supply system, the gas–pressure control–measuring system as well as the means for increasing the pressure and the calibratable measurement of the biogas to be fed. The equipment requirements are set out in DVGW G 265–3 Installations for the feeding of hydrogen into gas supply networks – planning, production, installation, testing, commissioning and operation
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 network operator shall construct (establish) the grid connection on the basis of joint planning.
Question 7b - Who can do the connection work (professional skills requirement)?
b - The network operator or third party assigned by him with relevant competence.
Question 7c - Which party is responsible for carrying out the planning and establishment of the grid connection?
c - The network operator must carry out the planning of the grid connection in cooperation with the facility operator (connecting party). (§33 (7) of Gas Network Access Ordinance)
Question 8 In case of network congestion, is the TSO obliged to prioritise the injection of hydrogen instead of natural gas?
No
Describe the comparable technology and its relevance with regard to hydrogen
Biogas

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.