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
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?
A system user agreement must be concluded in order to establish the connection and to inject in the gas grid. There is no difference about the place where the injection will happen.
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 law does not specify the way of hydrogen production for the gas grid injection. As long as the system user agreement is established and the mixture does not exceed 0,1%Mol of hydrogen it is allowed. ii. – see answer i. iii. – to establish the connection and to install all the safety equipment as well as the monitoring system.
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 form case-to-case and the local charectaristics.
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)?
a)if the H2 quantity is exceeded, or the safety requirements are not concluded, it is possible that DSO can deny the injection. B) not enough information. C) the supplier of H2 must ensure the safety equipment is installed.
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)if the H2 quantity is exceeded, or the safety requirements are not concluded, it is possible that DSO can deny the injection.
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) not enough information.
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 requirements of 0,1% Mol hydrogen. Also to establish the connection point and to install all the safety equipment.
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
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.
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- DSO to set the connection point, thus the system user (h2 provider) must establish the connection.
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?
DSO together with the system user.
Question 7 In case of network congestion, is the DSO obliged to prioritise the injection of hydrogen instead of natural gas?
No.
Describe the comparable technology and its relevance with regard to hydrogen
biomethane

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.