Permission to connect/inject

This LAP concerns the injection of hydrogen into the low pressure transmission gas grid at the DSO level and the permitting framework and procedures required to be followed for DSO connection, 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 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 DSO has to accept gas at the specified quality in terms of gross calorific value, pressure, schedules and available transportation capacity and the DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the DSO to refuse feed in of hydrogen if the gas quality, the thereto related cross calorific value and thereto related the Wobbe Index is not met. There is no difference between a transmission and distribution system. Basically injection in an isolated system is not different from the technical point of view regarding the maximum amount of hydrogen to be feed into the system. The difference is that not that many burning devices have to be adapted to the changed gas quality, hence it is easier to realise such a system from the economic perspective.
Question 2 Connection to the gas grid of 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 DSO obliged to connect the facilities; can DSO deny the connection and under which conditions? ii. Are there requirements for DSO to ensure the availability of connection? iii. Which are the requirements for facility operator/ h2 supplier?
a - i. – The DSO has to accept gas at the specified quality and the DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the DSO to refuse feed in of hydrogen if the gas quality, the thereto related cross calorific value and therefore the Wobbe Index is not met. Of course the mixture has to be delivered at the required pressure and the related schedule in terms of time and volume per time unit. In order to connect a facility to the grid there has to be transportation capacity available as well and it has to be ensured that the gas quality will be harmonised within the gas grid. ii. – The DSO has to accept gas at the specified quality and the DSO is responsible for a safe and reliable operation of the grid. In case the injection is not feasible from the economic perspective although technically feasible, the DSO will probably not provide the possibility to connect the facility to the grid iii. – The DSO has to accept gas at the specified quality and the DSO is responsible for a safe and reliable operation of the grid. The obligations for the facility operator /hydrogen supplier are to supply the mixture at the specified quality, at the proper pressure, in line with the scheduled supplies regarding volume per time unit and period. Since the proper mixture can be achieved with the distribution grid, there have to be provisions regarding, ownership, maintenance and allocation of costs in place. Responsibilities issues have to be clarified as well.
Question 2 Connection to the gas grid of 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 DSO ii. Assessment of grid compatibility by DSO iii. How much time does it take to conclude a connection agreement?
b - i. – Not clarified yet but following the currently used approach s connection agreement is a must and will be assessed by the DSO from the technical as well as from the economical perspective. ii. – The DSO has to assess the grid compatibility in terms of mixture quality and of course material requirements in order to enable a safe and reliable operation of the grid iii. – If the transportation capacity is available – which is mostly the case on the distribution level because of the “capacity belongs to the customer principle” the connection agreement can be concluded within a relatively short period of time
Question 3 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? a) Is DSO/TSO obliged to feed-in the H2; can DSO deny the injection and under which conditions? b) Are there requirements for DSO to ensure a minimum feed-in capacity? c) Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?
There is a need to conclude such a feed–in–agreement
Question 3 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? a - Is DSO/TSO obliged to feed-in the H2; can DSO deny the injection and under which conditions?
a - There is a need to conclude such a feed in agreement in order to check whether the required transportation capacity is available and to know whom to bill the quality check costs. The DSO has to deny the injection of the mixture if the preconditions, like mixture quality in terms of gross calorific value, pressure, schedules and availability of transportation capacity etc. are not met
Question 3 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? b - Are there requirements for DSO to ensure a minimum feed-in capacity?
b - No, but if the economic feasibility is given the DSO will provide the capacity,
Question 3 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?
c - Of course there are preconditions to be met. The biggest hurdle is the mixture quality. So the mixture has to meet the specifications. On top, the mixture has to be delivered at the proper pressure and in lice with the announced schedules.
Question 4 Will you treat a connection for hydrogen injection in the same way as a regular connection for natural gas injection? Or are there other legal/administrative responsibilities/requirements for you as DSO but also for the supplier with regard to the permission to connect/inject Hydrogen? If yes: please name them.
Not clarified yet but since the injection of natural gas doesn’t change the quality of the transported medium in terms of gross calorific value and the thereto linked Wobbe index, it is relatively easy to inject natural hgas respectively biomethane into the system. Hydrogen does change the gross calorific value and the Wobbe index and even more important – the mixture can only happen in the grid – at least when taking the thereto associated costs into account – or a therefore foreseen device . This means that such a device has to be implemented in the gas grid. The questions are, who is the owner (it is very likely that the DSO/TSI would be the owner) and who is going to take care of the CAPEX and OPEX and potential reciprocal impacts and who is going to shoulder the responsibilities.
Question 5 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 following the currently used methodology – yes, there is a need for a mixture device which mixes the natural gas and the hydrogen – which can happen only in the grid as such at least when taking the thereto associated costs into consideration.
Question 6a - Please describe which party is responsible for delivering which part of the connection? For example is the DSO only responsible for delivering a connection point?
a - Not clarified yet but following the so far used approach, it will be the DSO who decides on what should be implemented in his infrastructure and the supplier will have to take care about the CAPEX and OPEX
Question 6b - Who can do the connection work (professional skills requirement)
b - Not clarified yet but since it is up to the DSO to take care of a safe and reliable operation of the grid, it will be up to the DSO to decide on this issue.
Question 6c - Which party is responsible for carrying out the planning and establishment of the grid connection?
c - Not clarified yet but since it is up to the DSO to take care of a safe and reliable operation of the grid, it will be up to the DSO to decide on this issue
Question 7 In case of network congestion, is the DSO obliged to prioritise the injection of hydrogen instead of natural gas?
So far not; no regulation available in this regard. In Austria one can assume that on distribution level there is almost never network congestion happening

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.