Permission to connect/inject

This LAP concerns the permitting framework and processes (or restrictions) for hydrogen based SNG (via methanation) and injection into the gas grid at TSO or DSO level, along with technical requirements for and oversight of local grid connection facilities

Glossary:

Permission and additional restrictions regarding connection points for SNG from 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 related to the connection facility.

select country:

Is it a barrier?

Neutral

Assessment Severity

Questions:

Question 1 Is the legislation with regard to injection of Methane (SNG) via methanation from hydrogen the same as for hydrogen? If yes, question 2-9 are the same as for category 7, application 1: injection of hydrogen in the gas grid and do not have to be answered.

No. The injection of H2 directly to the gas grid is not allowed in Spain while the SNG is allowed under specific constraints.

Question 2 What is your legal situation (requirement from legislation and administrative procedures) with regard to international interconnection for the injection in the gas grid with neighbouring countries?

The Technical System Manager is the responsible of legal and administrative procedures, having the National Energy Committee as link with the other European gas grids operators. This entity is the responsible of the procedures to interconnection; however the planning is done by the Energy, Tourism and Digital Agenda Ministry.

Question 3 Is it possible for a TSO to refuse to feed in hydrogen from neighbouring countries at cross-border interconnection points? a - If yes, under which conditions?

a - Yes, under capacity constraints based on the Law 34/1998, or quality constraints explained in the PD–01.

Question 3 Is it possible for a TSO to refuse to feed in hydrogen from neighbouring countries at cross-border interconnection points? b - Can you have a differentiated treatment (i.e.: applying a more stringent threshold than the one applying under your national law?

b - No.

Question 4 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?

The administrative process is regulated by law. It is required a demonstration of the supply capacity, the technical capacity and also the economical one.

Question 5 Connection to the gas grid of hydrogen producing facility a - What are the requirements for connection of the methanation plants which primarily use renewable energies to the gas supply network: i. Is TSO/DSO obliged to connect the facilities; can TSO/DSO deny the connection and under which conditions? ii. Are there requirements for TSO/DSO to ensure the availability of connection? iii. Which are the requirements for facility operator/ SNG from hydrogen supplier?

a - i. – TSO is forced to facilitate the injection. ii. – No. iii. – The SNG from hydrogen supplier has to produce a gas which will be covered by the scope of the PD–01.

Question 5 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 TSO/DSO ii. Assessment of grid compatibility by TSO/DSO iii. How much time does it take to conclude a connection agreement

b - i. – Connections are realised under a connection contract, which has to have been approved earlier. ii. – NA iii. – NA

Question 6 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and SNG from hydrogen supplier? a) Is DSO/TSO obliged to feed-in the H2; can DSO/TSO deny the injection and under which conditions? b) Are there requirements for DSO/TSO to ensure a minimum feed- in capacity? c) Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?

Yes

Question 6 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and SNG from hydrogen supplier? a - Is DSO/TSO obliged to feed-in the H2; can DSO/TSO deny the injection and under which conditions?

a - No. TSO can deny injection if the gas is out of the boundary limits.

Question 6 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and SNG from hydrogen supplier? b - Are there requirements for DSO/TSO to ensure a minimum feed- in capacity?

b - Yes. There is a capacity of SNG that is required by contract, and due to its composition, there is also a limit in the hydrogen.

Question 6 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and SNG from hydrogen supplier? c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?

c - No.

Question 7a - Will you treat a connection for SNG from 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 TSO/DSO but also for the supplier with regard to the permission to connect/inject Hydrogen? If yes: please name them.

a - They are treated in the same way.

Question 7b - Are there other requirements for the injection of SNG from hydrogen-NG blends compared to SNG from hydrogen ?

b - No

Question 8 Is there a requirement for other or additional equipment compared to a regular connection for natural gas injection in your grid? Which one?

Question 9a - Please describe which party is responsible for delivering which part of the connection? For example is the TSO only responsible for delivering a connection point?

a - TSO owns the connection and is covered under their expenses. The owner of the facility is the one that has to deliver the rest of the components.

Question 9b - Who can do the connection work (professional skills requirement)

b - The project is done by consultancy companies.

Question 9c - Which party is responsible for carrying out the planning and establishment of the grid connection?

c - The Energy, Industry and Digital Agenda Ministry.

Question 10 In case of network congestion, is the TSO/DSO obliged to prioritise the injection of SNG from hydrogen instead of natural gas?

Describe the comparable technology and its relevance with regard to hydrogen

Natural Gas

National legislation:

Law 34/1998, of 7 October, of the hydrocarbons sector
In title IV "Regulation of the supply of combustible gases by canalization" is explained the gas grid system and its regulation processes.”.
Royal Decree 1434/2002, of 27 of December, by which regulate the activities of transport, distribution, commercialization, supply and procedures of authorization of installations of natural gas.