Payment issues

This LAP concerns the injection of hydrogen into the high pressure transmission gas grid at the TSO level and the cost allocation, payment and incentives framework covering injection installations and hydrogen gas conveyance via the TSO network

Glossary:

Additional tariff restrictions (positive or negative) relating the transport of hydrogen compared to the regulated transport tariffs for natural gas (e.g. payment issues in connection to the injection of hydrogen or methane into gas network are: connection costs, feed-in tariffs, remunerations).
Is it a barrier?
Yes, Neutral
Type of Barrier
Operational barriers, Economic barriers, Regulatory gap
Assessment Severity
2

Questions:

Question 1 Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion. a) grid connection costs: i. for connection facility ii. for connecting pipe line b) costs for availability of the network connection, maintenance, and operation of the network connection c) feed-in costs d) remuneration for avoided network costs e) tax incentives f) others
– If this question is related to the injection of hydrogen then this issue has not been clarified yet in Austria BUT, following the so far established methodology in the natural gas sector, it is the hydrogen supplier/producer who has to bear the costs of connecting to the distribution or transmission system ii. – not clarified yet BUT, following the so far established methodology it is the hydrogen supplier/producer
Question 1 Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion. a - grid connection costs: i. for connection facility ii. for connecting pipe line
a - not clarified yet BUT, following the so far established methodology it is the hydrogen supplier/producer
Question 1 Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion. b - costs for availability of the network connection, maintenance, and operation of the network connection
b - not clarified yet BUT, following the so far established methodology it is the hydrogen supplier/producer
Question 1 Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion. c - feed-in costs
c - not clarified yet but if any, then such costs will be taken into consideration in the entry exit tariffs. It is difficult to assume avoided network costs at minor volumes respectively small injection capacity. Another important question is how much should the hydrogen producer/supplier pay for because the pipeline is available so that he can feed in and make some money (hopefully). This is the same topic like with gas storage facilities
Question 1 Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion. d - remuneration for avoided network costs
d - if any, then the hydrogen supplier/producer
Question 1 Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion. e - tax incentives
e - Click here to enter free text
Question 2 In case additional costs occur for injection of hydrogen in the grid, e.g. metrology equipment needed for measurement, in your country compared to natural gas injection, who will bear these costs?
not clarified yet BUT, following the so far established methodology in the natural gas sector it has to be the hydrogen supplier/producer
Question 3 Is a hydrogen injection connection point treated in the same way as a natural gas injection point with respect to the (transport) tariffs framework?
not clarified yet BUT, following the so far established methodology yes. The tariffs are based on the transported energy and not on the transported volume.
Question 4 Does the sustainability (hydrogen in the natural gas grid) have additional financially benefits for you as a TSO besides the regular transportation fees?
not clarified yet BUT, following the so far established methodology there are no financial benefits for the TSO – on the contrary the TSO has to take care of a safe and reliable operation of the gas grid, hence in case of deviations of the quality of the injected medium from the specified quality, the TSO has to reject the acceptance
Question 5 Does a TSO have contractual agreement and/or responsibilities with the supplier/shipper regarding injection of hydrogen in the grid that could influence/affect payment issues?
Not clarified yet, BUT following the so far established methodology, the TSO has to take care of a safe and reliable operation of the grid – subsequently in case of deviation of the quality from the specified quality, the TSO has to reject the acceptance of the medium since it is him who is responsible for the quality of the transported gas, hence any deviations would lead to problems in the billing since it is the gross calorific value the consumer has to pay for and not for the transported volumes
Question 6 Are there any benefits from the national tariff-system in relation to “sustainable” / “non (or less)-sustainable” about hydrogen – natural gas blend?
Not clarified yet BUT following the so far established methodology there are no benefits in place currentöly
Question 7 Are there any incentives granted for the hydrogen facility operator/supplier?
According to the established methodology there are no incentives in place for hydrogen facility operators or hydrogen suppliers
Describe the comparable technology and its relevance with regard to hydrogen
Click bio–methane? here to enter free text

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.
  • Commission Regulation (EU) 2017/460 of 16 March 2017 establishing a network code on harmonised transmission tariff structures for gas
    Regulation (EU) 2017/460 establishes a network code setting out the rules on harmonised transmission tariff structures for gas, including rules on the application of a reference price methodology, the associated consultation and publication requirements as well as the calculation of reserve prices for standard capacity products.

    The network code on harmonised transmission tariff structures for gas enhances tariff transparency and tariff coherency by harmonising basic principles and definitions used in tariff calculation, and via a mandatory comparison of national tariff–setting methodologies against a benchmark methodology. It also stipulates publication requirements for information on tariffs and revenues of transmission system operators.