Payment issues

This LAP concerns the injection of hydrogen based SNG (via methanation) into the gas grid at TSO or DSO level and the cost allocation, payment and incentives framework covering injection installations and hydrogen gas conveyance via the gas grid


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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
	There isn’t any methanation from hydrogen and injection of Methane (SNG) in the grid as any injection of hydrogen, therefore there is not regulation on these matters and related payment issues. At present there is no legal basis (law or regulation) for injection of hydrogen in the gas grid. The only regulation available is Gas Grid Code of Snam Rete Gas, submitted to the Authority for the electricity, gas and water market on 14 November 2002 and continuously updated ever since, where is only foreseen the presence of hydrogen with reference to bio–methane. Therefore, there is no regulation on Payment Issues, related to the injection of hydrogen into gas network as for example connection costs, feed–in tariffs and remunerations
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 connecting 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 avoi
	a - i. – n/a ii. – n/a
a - grid connection costs: i. for connecting facility ii. for connecting pipe line
	b - n/a
b - costs for availability of the network connection, maintenance and operation of the network connection
	c - n/a
c - feed-in costs
	d - n/a
d - remuneration for avoided network costs
	e - n/a
e - tax incentives
	f - n/a
In case additional costs occur for injection of SNG from hydrogen in the grid, e.g. metrology, in your country compared to natural gas injection, who will bear these costs? Please indicate which additional costs and who will bear these costs.

Is a SNG from hydrogen injection connection point treated in the same way as a natural gas injection point with respect to the (transport) tariffs framework?

Does the sustainability (SNG from hydrogen in the natural gas grid) have additional financially benefits for you as a TSO/DSO besides the regular transportation fees?

Does a TSO/DSO have contractual agreement and/or responsibilities with the supplier/shipper with regard to injection of SNG from hydrogen in the grid that could influence/affect payment issues?

Are there any benefits from the national tariff-system in relation to “sustainable” / “non (or less)-sustainable” with regard to SNG from hydrogen – natural gas blend?

Are there any incentives granted for the SNG from hydrogen facility operator/supplier?

Does a TSO/DSO have contractual agreement(s)/responsibilities related to the national regulation with regard to injection of SNG from hydrogen in the grid that could influence/affect fees/taxes .

Is it a barrier?	Yes
Type of Barrier	Regulatory gap
Assessment Severity	3
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National Legislation	Gas Network Code of Snam Rete Gas Gas network regulation of SNAM Rete Gas defines the role of each party involved in gas transmission and distribution activities.
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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.
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Glossary
Payment issues	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).
Methanation and injection of Methane (SNG) via methanation from hydrogen at transmission / distribution level	Methanisation and injection of SNG at transmission / distribution level
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	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 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 There isn’t any methanation from hydrogen and injection of Methane (SNG) in the grid as any injection of hydrogen, therefore there is not regulation on these matters and related payment issues. At present there is no legal basis (law or regulation) for injection of hydrogen in the gas grid. The only regulation available is Gas Grid Code of Snam Rete Gas, submitted to the Authority for the electricity, gas and water market on 14 November 2002 and continuously updated ever since, where is only foreseen the presence of hydrogen with reference to bio–methane. Therefore, there is no regulation on Payment Issues, related to the injection of hydrogen into gas network as for example connection costs, feed–in tariffs and remunerations Question 2 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 connecting 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. – n/a ii. – n/a Question 2 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 connecting facility ii. for connecting pipe line b - n/a Question 2 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 - n/a Question 2 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 - n/a Question 2 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 - n/a Question 2 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 - n/a Question 3 In case additional costs occur for injection of SNG from hydrogen in the grid, e.g. metrology, in your country compared to natural gas injection, who will bear these costs? Please indicate which additional costs and who will bear these costs. Question 4 Is a SNG from hydrogen injection connection point treated in the same way as a natural gas injection point with respect to the (transport) tariffs framework? Question 5 Does the sustainability (SNG from hydrogen in the natural gas grid) have additional financially benefits for you as a TSO/DSO besides the regular transportation fees? Question 6 Does a TSO/DSO have contractual agreement and/or responsibilities with the supplier/shipper with regard to injection of SNG from hydrogen in the grid that could influence/affect payment issues? Question 7 Are there any benefits from the national tariff-system in relation to “sustainable” / “non (or less)-sustainable” with regard to SNG from hydrogen – natural gas blend? Question 8 Are there any incentives granted for the SNG from hydrogen facility operator/supplier? Question 9 Does a TSO/DSO have contractual agreement(s)/responsibilities related to the national regulation with regard to injection of SNG from hydrogen in the grid that could influence/affect fees/taxes . Describe the comparable technology and its relevance with regard to hydrogen Bio–gas LAP data Barrier Type Is it a barrier? Assessment Severity Assessment National Legislations National Legislation #1 Title Gas Network Code of Snam Rete Gas Url http://www.snamretegas.it/export/sites/snamretegas/it/business-servizi/codice-rete-tariffe/Codice_di_rete/Aree/Codice_rete/63.Codice_di_Rete_RevLXIII.pdf Relation with EU Legislation Scope of the relevant parts Gas network regulation of SNAM Rete Gas defines the role of each party involved in gas transmission and distribution activities. Please give us a summary of your suggestion E-Mail (optional, if we may contact you)

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