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
Operational barriers
Assessment Severity
1

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 injection into the gas grid is managed at a national level to guarantee that the available transport capacities used are well allocated through the whole country. If the connection takes place at an isolated network, there could be some restrictions to inject into the grid, if the grid is “over–charged”.
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 is not obliged to connect. It will depend on the distribution capacities of the grid at the injection point ii. – The DSO has to guaranty the access to its grid and it has to guarantee the injection capacity when the injection project has been decided. This is part of the “injection agreement” to be signed between the producer and the DSO iii. – There are no other requirements than those for every operator injecting gases other than natural gas.
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. – An “injection agreement” has to be signed. It defines the terms and condition for the injection and the obligations and responsibilities of each party. For example the injection capacity is defined and the renting conditions by the producer for the injection unit. ii. – The DSO has to check if the capacity of the grid is enough for the injection project and compatible with other up–coming projects. iii. – Depending in the location of the injection point (duration of the feasibility study of the DSO), the duration could be from 6 to 12 month
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)?
An “injection agreement” is concluded between the producer and the DSO.
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 - DSO is not obliged to feed–in. One reason to deny is if the injection point is located at a point of the grid were there will be an over–capacity of gas compared to the consumption in the near aera.
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 - Once the injection capacity has been fixed in the “injection agreement”, the DSO has to guaranty that the produced gas can be injected at any 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? c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?
c - there are no technical requirement other than those given in the technical rules for injecting gases other than natural gas.
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.
The connection will be treated the same way as regular connection as for the injection of gases other than natural gas. This means that the gas producer has to guarantee the quality of the injected gas (the impurities contained must be under a certain maximum concentration limit before injection). If some other impurities not listed in the technical specification are contained in the injected gas, the producer has to declare them to the DSO. The DSO will than verify if these impurities can be accepted and at what concentration. If some additional tests or expertise can than be necessary. The additional costs associated have to paid by the producer.
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?
Normaly there is no additional equipment needed. Possibly, a “blending” equipment can be associated within the injection unit. With this equipment the H2 concentration before injection can be reduced at the maximum acceptable level before injection.
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 - The DSO is responsible for: – delivering the best available connecting point; – the piping and connection of the injection unit to the gas grid; – the delivery and installation of the injection unit; The producer is responsible for: – the piping from the production point to the injection unit; – the safety measures related to the transport of H2 within a specific pipe…. – the quality assurance of the injected gas..
Question 6b - Who can do the connection work (professional skills requirement)
b - the connection work of the injection unit to the gas grid is done under the responsibility of the DSO by it’s own staff or by an approved professional.
Question 6c - Which party is responsible for carrying out the planning and establishment of the grid connection?
c - The DSO is responsible for the planning and the grid connection.
Question 7 In case of network congestion, is the DSO obliged to prioritise the injection of hydrogen instead of natural gas?
The DSO is only obliged to prioritise the different injection projects regarding to the maximum available grid capacity. The projects are prioritised on a “first come – first served” basis. The different injection projects are on a national waiting list to pre–allocate the grid capacities. Once the project has been decided and the complete feasibility study done by the DSO, the allocated capacity is reserved for the project.

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.