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.
Is it a barrier?
Yes
Type of Barrier
Structural barriers, Operational barriers, Economic barriers, Regulatory gap
Assessment Severity
3

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.
Our understanding of the question is that methane – generated by methanation from hydrogen – will be upgraded to the prevailing gross calorific value – so to 11,3 kWh/Nm3 by add on of LPG. Since pure methane has got a gross calorific value of 10 kWh/Nm3 the add–on has to be undertaken. If so, there is no difference in the legislative basis regarding injection of SNG.
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?
As long as upgraded SNG matches the specifications of natural gas regarding gross calorific value (and of course purity requirements but this is not that difficult to be fulfilled), there is no restriction regarding import of SNG to Austria or exporting from Austria
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 - First of all, the question is not clear at all. Do you mean feed in of a gas mixture where the hydrogen was injected upstream or do you mean an injection of hydrogen at cross–border interconnection points from facilities which are located in the neighbouring country directly at the interconnection point. The TSO/DSO has to accept gas at the specified quality and the TSO/DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO/DSO to refuse feed in of hydrogen from neighbouring countries if the gas quality, the thereto related cross calorific value and the Wobbe Index is not met
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 - Of course there can be varying thresholds regarding percentage of hydrogen in the gas grid. So far, the approach is that hydrogen is injected on national level – which consequently means on distribution system level otherwise the hydrogen fed into the gas grid on transmission level would be transported (transit) to neighbouring countries or even further. The TSO/DSO has to accept gas at the specified quality and the TSO/DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO/DSO to refuse feed in of hydrogen from neighbouring countries if the gas quality, the thereto related cross calorific value and the Wobbe Index is not me
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?
In Austria it is allowed to feed in upgraded SNG as much as possible (precondition that then required transportation capacity is available). There is no difference if the injection takes place in an isolated (regional) network without international interconnections. Hydrogen can be fed into the system at max. 4% (Mol); this amount results from technical restrictions regarding the pipeline material and the material of other infrastructure equipment. So in case one would really inject 4% (mol) hydrogen into the gas grid there is a need to adapt the specified gas quality – having an impact on the gross calorific value and the Wobbe Index. So the question is not whether the injection takes place in an isolated region or not. Of course, if one injects on a regional level “only” this could have positive impacts on the appliance of the devices (not so many devices have to be adapted to the changed gross calorific value and the out of it resulting Wobbe Index) but on the other hand the consumptions usually fluctuates on a regional level much stronger than on an international level, thus storage possibilities for hydrogen have to be given otherwise the gas quality (de facto a mixture of natural gas and hydrogen) fluctuates too strongly
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. – The TSO/DSO has to accept gas at the specified quality as long as transportation capacity (down stream) is available. The TSO/DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO/DSO to refuse feed in of methane which doesn’t match the specifications. The TSO/DOS is not obliged to allow connection of the facility to the grid and he will not do so if the feasibility from the economic perspective is not given. If the question is meant, whether there are legal requirements to accept SNG because these volumes were generated by using RES, then the answer is no. So far there is an obligation for electricity generated via RES–plants to be accepted but not for gas regardless whether it is biomethane or SNG.. ii. – The TSO/DSO has to accept gas at the specified quality as long as transportation capacity (down stream) is available. The TSO/DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO/DSO to refuse feed in of methane/SNG/biomethane which doesn’t match the specifications. The TSO/DOS is not obliged to allow connection of the facility to the grid and he will not do so if the feasibility from the economic perspective is not given iii. – The TSO/DSO has to accept gas at the specified quality as long as transportation capacity (down stream) is available. The TSO/DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO/DSO to refuse feed in of methane which doesn’t match the specifications. The TSO/DOS is not obliged to allow connection of the facility to the grid and he will not do so if the feasibility from the economic perspective is not given
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. – The TSO/DSO has to accept gas at the specified quality as long as transportation capacity (down stream) is available. The TSO/DSO is responsible for a safe and reliable operation of the grid. The TSO/DSO is not obliged to allow connection of the facility to the grid and he will not do so if the feasibility from the economic perspective is not given and the specifications of the gas quality are not met (see ÖVGW 31 and ÖVGW 33). Of course there is a need for a connection agreement ii. – The TSO/DSO has to accept gas at the specified quality as long as transportation capacity (down stream) is available. Specified quality means in terms of gross calorific value, the out of it resulting Wobbe Index, pressure, time schedules etc. The TSO/DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO/DSO to refuse feed in of methane which doesn’t match the specifications. The TSO/DOS is not obliged to allow connection of the facility to the grid and he will not do so if the feasibility from the economic perspective is not given as well iii. – Not exactly determined but an agreement can be concluded within a very short period of time; assessment often on a case by case basis
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 - Of course there is a need for a feed–in agreement/grid access contract because it has to be clarified whether there is sufficient down–stream transportation capacity available and whether the economic feasibility is given as well. The TSO/DSO has to accept gas at the specified quality and the TSO/DSO is responsible for a safe and reliable operation of the grid. So it is the obligation of the TSO/DSO to refuse feed in of methane which doesn’t match the specifications The quality of the gas has to meet the specifications regarding gross calorific value, the out of it resulting Wobbe Index, pressure requirements, time schedules eventually balancing energy etc..
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 - No, The TSO/DSO will assess whether it is possible – from the technical and economical point of view to provide capacity to the supplier in case the quality of the mixture matches the specifications
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 - Yes, the specifications of natural gas have to be met in terms of gross calorific value, out of it resulting Wobbe Index, pressure requirements, time schedules etc.
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 - as long as SNG meets the quality specifications of natural gas, there will not be a difference in comparison to a regular natural gas connection
Question 7b - Are there other requirements for the injection of SNG from hydrogen-NG blends compared to SNG from hydrogen ?
b - as long as SNG meets the quality specifications of natural gas, there will not be a difference in comparison to a regular natural gas connection; blending has to be done before feed in or a mixture device has to be integrated into the natural gas grid – which makes more sense
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?
as long as upgraded SNG meets the quality specifications of natural gas, there will not be a difference in comparison to a regular natural gas connection; blending has to be done before feed in or a mixture device has to be integrated into the natural gas grid – which makes more sense
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 - not clarified yet BUT following the approach used so far, the metering devices and the gas–phase chromatographs can be either owned by the TSO/DSO (in such a case the supplier will be charged for the metering and the quality control) or by the supplier
Question 9b - Who can do the connection work (professional skills requirement)
b - Since it is the TSO/DSO who is responsible for the safe an d reliable operation of the grid it is up to the TSO/DSO to decide on these issues
Question 9c - Which party is responsible for carrying out the planning and establishment of the grid connection?
c - Since it is the TSO/DSO who is responsible for the safe an d reliable operation of the grid it is up to the TSO/DSO to decide on these issues
Question 10 In case of network congestion, is the TSO/DSO obliged to prioritise the injection of SNG from hydrogen instead of natural gas?
No – so far not BUT not clarified yet. One can assume that there is almost no network congestion on distribution grid level in Austria.

National legislation: