Payment issues
This LAP concerns the injection of hydrogen into the low pressure transmission gas grid at the local DSO level and the cost allocation, payment and incentives framework covering injection installations and hydrogen gas conveyance via the DSO network
Glossary:
Additional tariff restrictions (positive or negative) relating the transport of hydrogen compared to the regulated transport tariffs for natural gas (e.g. payment issues in connection to the injection of hydrogen or methane into gas network are: connection costs, feed-in tariffs, remunerations).
Is it a barrier?
Yes
Type of Barrier
Structural barriers, Regulatory gap
Assessment Severity
3
Questions:
Question 1
Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion.
a) grid connection costs:
i. for connection facility
ii. for connecting pipe line
b) costs for availability of the network connection, maintenance and operation of the network connection
c) feed-in costs
d) remuneration for avoided network costs
e) tax incentives
f) others
a -
i. – See SNG group.
ii. – NA
Question 1
Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion.
a - grid connection costs:
i. for connection facility
ii. for connecting pipe line
b - NA
Question 1
Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion.
b - costs for availability of the network connection, maintenance and operation of the network connection
c - NA
Question 1
Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion.
c - feed-in costs
d - NA
Question 1
Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion.
d - remuneration for avoided network costs
e - NA
Question 1
Who bears the following costs and if they are shared between the DSO/TSO and the hydrogen facility operator/ supplier – in which proportion.
e - tax incentives
f - NA
National legislation:
-
Law 34/1998, of 7 October, of the hydrocarbons sector.
In title IV "Management of the supply of combustible gases by pipeline" is explained the gas grid system and its regulation processes.”
- Resolution of 22 of September of 2011, of the Directorate General of Energy Policy and mines, by which modifies the protocol of detail PD–01 «Measurement» of the norms of technical management of the gas system.
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.