H2 quality requirements

This LAP is concerned with the gas quality issues for hydrogen injection and transport in the low pressure DSO local gas grid, including gas quality monitoring and metering in relation to payment terms and responsibilities for monitoring and metering


Requirements related to the quality of hydrogen (in relation to the composition of the gas(blend) as well as its physical property
Hydrogen quality is a term to describe the gas quality for use in the natural gas grid.
Is it a barrier?
Type of Barrier
Structural barriers, Operational barriers, Economic barriers, Regulatory gap
Assessment Severity
The UK system is based on a clear set of charges and arrangements between injection / off–take of gas and local transport and transmission – but it is the concentration of H2 that limits H2 input to the gas grid . If the concentration was allowed at up to 10% or 20% then the operational framework would accommodate H2 in the similar manner to bio–methane


Question 1 What is the basis for the billing of Hydrogen and Hydrogen Natural Gas Mixtures? Only the energy flow (kWh) or are other properties involved?
It is kWh. LDZ – ‘local gas distribution zone transportation charges’ are derived in relation to a price control formula set by the Regulator, OFGEM, for the transportation of gas. This formula dictates the maximum revenue that can be earned from the transportation of gas. Where the LDZ charges are based on functions, these functions use Supply Point Offtake Quantity (SOQ) in kWh either per annum or /and at peak load points in kWh /day. However for bio–methane there are ‘system entry commodity charges’ that can apply at a fixed entry point where the energy flow is designated in kWh and this could in principle be applied for H2 injection at the DNO level
Question 2 What are the legal and administrative requirements and responsibilities with regard to real-time Measurement Technologies for the monitoring and billing of Hydrogen Natural-Gas Mixtures? Do they differ from the requirements for natural gas?
Hypothetical for the UK given H2 concentration limits – but. the gas quality and characteristics are translated to kWh
Question 3 Are there other hydrogen quality related legal and administrative requirements to allow the injection of hydrogen in the grid?
Hypothetical given the UK limits on H2 concentration
Question 4 How is the responsibility in your country organized with regard to the measurement and other injection related quality requirements? Is this the responsibility of the producer, the DSO or a third party?
Producer – but a third party can be used to verify quality readings and flow measurement
Describe the comparable technology and its relevance with regard to hydrogen

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
    Created 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.