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.

select country:

Is it a barrier?

Yes

Type of Barrier

Structural barriers, Operational barriers, Economic barriers, Regulatory gap

Assessment Severity

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?

In principle there would be no difference in arrangements even if it was an isolated regional network. Local injection is a straightforward arrangement for the UK where there are regulated arrangements for injection into the low pressure (DNO) gas network – but hypothetical given the 0.1% H2 concentration limit in the gas stream. A private mini gas grid may be able to obtain a temporary derogation to trial temporary arrangements, as is happening with the ‘HyDeploy programme’ (with Northern Gas Networks, the regional DNO) and OFGEM, the Regulator The UK has a long standing privatisation framework covering unbundling of the gas network to allow separate Distribution Network Operators (DNO), Transmission Network Operations (TNO) and System Operator (SO) roles, responsibilities and activities, to ensure fair access to the gas grid network for transmission and distribution purposes at transparent pricing – but permits only a low concentration of H2 in the gas stream at 0.1%. This was imposed at the time of transition to use of North Sea Gas and is in line with other European networks including AT, CZ, DK, ES, FI, GR, IE, IT, NO, PT, SE based on EN437:2003

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 connection can be denied if the injected gas from the electrolyser does not conform with quality standards reflecting the 0.1% H2 concentration limit ii. – In principle the DNO/DSO should ensure availability of connections and HSE should oversee safety and risk assessments for the connection iii. – injection will be limited by the current 0.1% H2 concentration limit

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. – short and long term access agreements – but limited by the 0.1% H2 concentration limit ii. – Yes iii. – The connection Agreement itself is straightforward and there are standard framework agreements the OFGEM and the DNOs can use so this can be around 3 months – but he overall duration then depends on specific site conditions and timing of the HSE risk and safety assessments

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)?

Not necessarily a FiT

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 no automatic obligation – can be denied based on the 0.1% H2 concentration limit

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 - Yes. These are negotiated under the OFGEM network access framework agreements

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 - Technical requirements are signed off by the HSE; gas quality in accordance with the 0.1% H2 concentration limit is essential

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.

Yes, in principle it is treated in the same way, but this will be subject to the 0.1% H2 concentration limit

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?

No, in principle it should be the same but subject to safe design, construction and use requirements (under HSE oversight)

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 - Supplier (or 3rd party) for injection and monitoring

Question 6b - Who can do the connection work (professional skills requirement)

b - The Supplier (or 3rd party working on behalf of the supplier – or the supplier can request connection work services to be provided by the DNO, to be at the cost of the supplier

Question 6c - Which party is responsible for carrying out the planning and establishment of the grid connection?

c - Supplier

Question 7 In case of network congestion, is the DSO obliged to prioritise the injection of hydrogen instead of natural gas?

Describe the comparable technology and its relevance with regard to hydrogen

Bio–methane

National legislation:

Gas Act 1996
Privatisation and unbundling of the gas industry; limiting the market power of British Gas; extending competition to industrial and domestic markets to obtain benefits of competition in terms of market entry and in benefits to customers
Gas Safety Management Regulations 1996
Pipeline Safety Regulations 1996
Gas pipeline integrity and securing safety in the design, construction, installation, operation, maintenance and decommissioning of pipelines. Establishing a safe operations framework that applies to pipelines in Great Britain and to those in territorial waters and the UK Continental Shelf
Utilities Act 2000
Provided for the establishment and functions of the Gas and Electricity Markets Authority and the Gas and Electricity Consumer Council; to amend the legislation regulating the gas and electricity industries; and for connected purposes – subsequently to become the Office For Gas & Electricity Markets (OFGEM
UK Health & Safety Executive 1996
Creating the UK Statutory Agency legally responsible for applying all relevant EC Directives relating to the design, installation and operation of facilities and their operative workforce personnel

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.