Permission to connect/inject

This LAP concerns the permitting framework and processes required to be followed for hydrogen injection into the high pressure transmission gas grid at the TSO level, along with technical requirements for and oversight of local grid connections


Expand all answers
Hide all answers
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?
	DK has gas interconnections with Germany and Sweden by which gas can be accepted for transmission around the high pressure (85 bar) grid – on the basis that the gas quality received via the interconnects meet DK statutory safety, quality and calorific value.
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
b - Can you have a differentiated treatment (i.e.: applying a more stringent threshold than the one applying under your national law?
	b - (a) on quality / safety parameters – where the DK has no defined limit for H2 concentration. A permit/agreement must be obtained from The Danish safety Technology Authority. (b) No – the gas safety / quality threshold dictates a single treatment
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?
	There is no difference – the Gas Regulations apply across the entire network and dictate that a permit/agreement must always be obtained
Connection to the gas grid of a 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 the TSO obliged to connect the facilities; can TSO deny the connection and under which conditions? ii. Are there requirements for TSO to ensure the availability of connection? iii. Which are the requirements
	a - i. – it is the gas DNO who would agree a connection – which would have to meet a gas safety assessment – and move the gas to the TSO for wider high pressure network distribution ii. – No – it’s for the DNO iii. – First of all – To obtain a permit from The Danish Safety Technology Authority. k
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 ii. Assessment of grid compatibility by TSO iii. How much time does it take to conclude a connection agreement
	b - i. – Yes plus permit from Danish Safety Technology Authority, subject to a formal gas safety assessment ii. – Yes plus permit from Danish Safety Technology Authority. iii. – Variable, subject to completion of risk and safety assessments
Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? a - Is a TSO obliged to feed-in the H2; can a TSO deny the injection and under which conditions?
	a - Only on quality / safety grounds
b - Are there requirements for a TSO to ensure a minimum feed- in capacity?
	b - No
c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?
	c - Only quality / safety requirements
Is there a requirement for other or additional equipment compared to a regular connection for natural gas injection in your grid? Which one?
	No – providing the risk / safety assessment is accepted
a - 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 - DNO
b - Who can do the connection work (professional skills requirement)?
	b - This is dictated under risk and safety criteria
c - Which party is responsible for carrying out the planning and establishment of the grid connection?
	c - tDNO
In case of network congestion, is the TSO obliged to prioritise the injection of hydrogen instead of natural gas?
	No
Is it a barrier?	Yes
Type of Barrier	Structural barriers, Regulatory gap
Assessment Severity	1
Show National legislation
Hide National legislation
National Legislation	Gasreglement afsnit C–12 (Gas regulations chapter C–12 Rules for gas Transport Appendix 1 Quality and delivery Specifications
Show EU legislation
Hide EU 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. Other relevant provisions for the injection of hydrogen at transmission level are contained in Article 42 “Regulatory regime for cross–border issues” and Article 43 “Compliance with the guidelines" Article 8 “Technical rules”, Article 25 “Tasks of a distribution system operator”; Article 28 “Closed distribution systems” Article 41 “Duties and powers of the regulatory authorities” Article 35 “Refusal of access”; Article 8 “Technical rules”; ” Regulation 715/2009 on conditions for access to the natural gas transmission networks Regulation 715/2009 sets non-discriminatory rules for access conditions to (a) natural gas transmission systems; (b) LNG facilities and storage facilities taking into account the special characteristics of national and regional markets To achieve this, it sets harmonised principles for tariffs, or the methodologies underlying their calculation, for access to the network, but not to storage facilities, the establishment of third-party access services and harmonised principles for capacity-allocation and congestion-management, the determination of transparency requirements, balancing rules and imbalance charges, and the facilitation of capacity trading. Regulation (EC) No 713/2009 of the European Parliament and of the Council of 13 July 2009 establishing an Agency for the Cooperation of Energy Regulators This Regulation establishes an Agency for the Cooperation of Energy Regulators in order to assist the regulatory authorities in various regulatory tasks. Article 8 sets the Agency’s “Tasks as regards terms and conditions for access to and operational security of cross border infrastructure” thus making it a relevant stakeholder in the regulatory landscape of hydrogen gas transmission and distribution. Commission Regulation (EU) 2015/703 of 30 April 2015 establishing a network code on interoperability and data exchange rules Regulation 2015/703 establishes a network code which sets out rules regarding interoperability and data exchange as well as harmonised rules for the operation of gas transmission systems. The network code on interoperability aligns the complex technical procedures used by network operators within the EU, and possibly with network operators in the Energy Community and other countries neighbouring the EU. This Regulation may also apply at entry points from and exit points to third countries, subject to the decision of the national authorities.
Show Glossary
Hide Glossary
Glossary
Permission to connect/inject	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
Injection of Hydrogen at transmission level (for energy storage and enhancing sustainabily)	Injection of Hydrogen at transmission level (for energy storage and enhancing sustainabily)
Show Pan-European Assessment
Hide Pan-European Assessment
Pan-European Assessment

	View Legislation Table
	PDF Export \| Excel Export
	The information is correct There are errors ... Would you like to give us a comment? Thank you! Submit a suggestion for improvements Questions & Answers Question 1 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? DK has gas interconnections with Germany and Sweden by which gas can be accepted for transmission around the high pressure (85 bar) grid – on the basis that the gas quality received via the interconnects meet DK statutory safety, quality and calorific value. Question 2 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 Question 2 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 - (a) on quality / safety parameters – where the DK has no defined limit for H2 concentration. A permit/agreement must be obtained from The Danish safety Technology Authority. (b) No – the gas safety / quality threshold dictates a single treatment Question 3 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? There is no difference – the Gas Regulations apply across the entire network and dictate that a permit/agreement must always be obtained Question 4 Connection to the gas grid of a 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 the TSO obliged to connect the facilities; can TSO deny the connection and under which conditions? ii. Are there requirements for TSO to ensure the availability of connection? iii. Which are the requirements for facility operator/ h2 supplier? a - i. – it is the gas DNO who would agree a connection – which would have to meet a gas safety assessment – and move the gas to the TSO for wider high pressure network distribution ii. – No – it’s for the DNO iii. – First of all – To obtain a permit from The Danish Safety Technology Authority. k Question 4 Connection to the gas grid of a 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 ii. Assessment of grid compatibility by TSO iii. How much time does it take to conclude a connection agreement b - i. – Yes plus permit from Danish Safety Technology Authority, subject to a formal gas safety assessment ii. – Yes plus permit from Danish Safety Technology Authority. iii. – Variable, subject to completion of risk and safety assessments Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? a - Is a TSO obliged to feed-in the H2; can a TSO deny the injection and under which conditions? a - Only on quality / safety grounds Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? b - Are there requirements for a TSO to ensure a minimum feed- in capacity? b - No Question 5 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO/TSO and H2 supplier? c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)? c - Only quality / safety requirements Question 6 Is there a requirement for other or additional equipment compared to a regular connection for natural gas injection in your grid? Which one? No – providing the risk / safety assessment is accepted Question 7a - 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 - DNO Question 7b - Who can do the connection work (professional skills requirement)? b - This is dictated under risk and safety criteria Question 7c - Which party is responsible for carrying out the planning and establishment of the grid connection? c - tDNO Question 8 In case of network congestion, is the TSO obliged to prioritise the injection of hydrogen instead of natural gas? No Describe the comparable technology and its relevance with regard to hydrogen Injection of Bio–methane LAP data Barrier Type Is it a barrier? Assessment Severity Assessment National Legislations National Legislation #1 Title Gasreglement afsnit C–12 (Gas regulations chapter C–12 Url https://www.retsinformation.dk/Forms/R0710.aspx?id=144715 Relation with EU Legislation Scope of the relevant parts National Legislation #2 Title Rules for gas Transport Appendix 1 Quality and delivery Specifications Url https://en.energinet.dk/-/media/Energinet/Gas-DGK/Dokumenter/Rules-for-Gas-Transport/Appendix/Appendix-1--Quality-and-delivery-specifications--RfG-160.pdf?la=en Relation with EU Legislation Scope of the relevant parts Please give us a summary of your suggestion E-Mail (optional, if we may contact you)

This map depicts the severity of this barrier across the HyLaw Partner countries.

No barrier
Low
Medium
High
Data not available
Selected countries