Permission to connect/inject

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


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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?
	NR. TRANSGAZ is the TSO (According to the provisions of Law no. 123/2012 on electricity and natural gas, the transport and system operator is organised and operates according to the independent system operator model (ISO). With the entry into force of the Law no. 117/2014 approving Government Emergency Ordinance no. 6/2014, ANRE approved the certification of the National Gas Transport Company "TRANSGAZ"). However, there is no authority/legal basis that would allow the connection/injection of hydrogen in the gas grid or be accepted as a cross border flow
Connection to the gas grid of 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 DSO obliged to connect the facilities; can DSO deny the connection and under which conditions? ii. Are there requirements for DSO to ensure the availability of connection? iii. Which are the requirements fo
	a - i. – In Romania there is no legislation in this respect ii. – In Romania there is no legislation in this respect iii. – In Romania there is no legislation in this respect
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 DSO ii. Assessment of grid compatibility by DSO iii. How much time does it take to conclude a connection agreement?
	b - i. – In Romania there is no legislation in this respect ii. – In Romania there is no legislation in this respect iii. – In Romania there is no legislation in this respect
Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? a ) Is DSO/TSO obliged to feed-in the H2; can DSO deny the injection and under which conditions? b) Are there requirements for DSO to ensure a minimum feed-in capacity? c) Are there requirements (technical) for the supplier of H2 (or
	In Romania there is no legislation in this respect
a - Is DSO/TSO obliged to feed-in the H2; can DSO deny the injection and under which conditions?
	a - NR
b - Are there requirements for DSO to ensure a minimum feed-in capacity?
	b - NA
c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)?
	c - NA
Will you treat a connection for 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 DSO but also for the supplier with regard to the permission to connect/inject Hydrogen? If yes: please name them.
	In Romania there is no legislation in this respect
Is there a requirement for other or additional equipment compared to a regular connection for natural gas injection in your grid? Which one?

a - Please describe which party is responsible for delivering which part of the connection? For example is the DSO only responsible for delivering a connection point?
	a - NR
b - Who can do the connection work (professional skills requirement)
	b - NR
c - Which party is responsible for carrying out the planning and establishment of the grid connection?
	c - NR
In case of network congestion, is the DSO obliged to prioritise the injection of hydrogen instead of natural gas?
	In Romania there is no legislation in this respect
Is it a barrier?	Yes
Type of Barrier	Structural barriers, Operational barriers, Economic barriers, Regulatory gap
Assessment Severity	3
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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”; ”
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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 distribution level (for energy storage and enhancing sustainability)	Injection of Hydrogen at distribution level (for energy storage and enhancing sustainability)
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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 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? NR. TRANSGAZ is the TSO (According to the provisions of Law no. 123/2012 on electricity and natural gas, the transport and system operator is organised and operates according to the independent system operator model (ISO). With the entry into force of the Law no. 117/2014 approving Government Emergency Ordinance no. 6/2014, ANRE approved the certification of the National Gas Transport Company "TRANSGAZ"). However, there is no authority/legal basis that would allow the connection/injection of hydrogen in the gas grid or be accepted as a cross border flow Question 2 Connection to the gas grid of 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 DSO obliged to connect the facilities; can DSO deny the connection and under which conditions? ii. Are there requirements for DSO to ensure the availability of connection? iii. Which are the requirements for facility operator/ h2 supplier? a - i. – In Romania there is no legislation in this respect ii. – In Romania there is no legislation in this respect iii. – In Romania there is no legislation in this respect Question 2 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 DSO ii. Assessment of grid compatibility by DSO iii. How much time does it take to conclude a connection agreement? b - i. – In Romania there is no legislation in this respect ii. – In Romania there is no legislation in this respect iii. – In Romania there is no legislation in this respect Question 3 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? a) Is DSO/TSO obliged to feed-in the H2; can DSO deny the injection and under which conditions? b) Are there requirements for DSO to ensure a minimum feed-in capacity? c) Are there requirements (technical) for the supplier of H2 (or for the supplied H2)? In Romania there is no legislation in this respect Question 3 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? a - Is DSO/TSO obliged to feed-in the H2; can DSO deny the injection and under which conditions? a - NR Question 3 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? b - Are there requirements for DSO to ensure a minimum feed-in capacity? b - NA Question 3 Grid access (injection into grid) Is it required to conclude a feed-in agreement (grid access contract) between DSO and H2 supplier? c - Are there requirements (technical) for the supplier of H2 (or for the supplied H2)? c - NA Question 4 Will you treat a connection for 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 DSO but also for the supplier with regard to the permission to connect/inject Hydrogen? If yes: please name them. In Romania there is no legislation in this respect Question 5 Is there a requirement for other or additional equipment compared to a regular connection for natural gas injection in your grid? Which one? Question 6a - Please describe which party is responsible for delivering which part of the connection? For example is the DSO only responsible for delivering a connection point? a - NR Question 6b - Who can do the connection work (professional skills requirement) b - NR Question 6c - Which party is responsible for carrying out the planning and establishment of the grid connection? c - NR Question 7 In case of network congestion, is the DSO obliged to prioritise the injection of hydrogen instead of natural gas? In Romania there is no legislation in this respect Describe the comparable technology and its relevance with regard to hydrogen Gas grid connections LAP data Barrier Type Is it a barrier? Assessment Severity Assessment National Legislations Please give us a summary of your suggestion E-Mail (optional, if we may contact you)

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