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


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?
Assessment Severity


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?
No, uniform rules for the whole country (for the DSO) otherwise the DSO discriminates.
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. – As long as the max. level of 0,5% at the end user is not exceeded (as part of methane injection), there are no extra requirements. ii. – Similar to biomethane: the DSO can never guarantee gas demand so availability can never be ensured. iii. – Comply with current rules (for injection in a DSO grid).
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. – Yes, is required. ii. – Yes, is required. iii. – Depends on local circumstances.
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 - As long as feed–in requirements are met for DSO grid (max. 0,5% H2 in natural gas mixture).
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, not for DSO (in real life this results in difficult discussions).
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 - Meet the current requirements for feed–in at DSO level, of which 0,5% H2 is the end user limit.l
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.
It is the same, since we do not have exclusive H2 injections.
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 for DSO.
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 - Correct.
Question 6b - Who can do the connection work (professional skills requirement)
b - Until transfer point: DSO. After that: responsibility of producer.
Question 6c - Which party is responsible for carrying out the planning and establishment of the grid connection?
c - DSO
Question 7 In case of network congestion, is the DSO obliged to prioritise the injection of hydrogen instead of natural gas?
How do you foresee this? The pressure of the local injector is already higher. What more is possible? Laws of nature give the higher pressure flow automatically priority.
Describe the comparable technology and its relevance with regard to hydrogen

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.