H2 quality requirements

This LAP is concerned with the gas quality issues for hydrogen injection and transport in the high pressure TSO transmission gas grid, including gas quality monitoring and metering in relation to payment terms and responsibilities for monitoring and metering


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What is the basis for the billing of Hydrogen and Hydrogen Natural Gas Mixtures? Only the energy flow (kWh) or are other properties involved?
	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. Billing arrangements do not exist.
What are the legal and administrative requirements and responsibilities with regard to real-time Measurement Technologies for the monitoring and billing of Hydrogen Natural-Gas Mixtures? Do they differ from the requirements for natural gas?

Are there other hydrogen quality related legal and administrative requirements to allow the injection of hydrogen in the grid?

How is the responsibility in your country organized with regard to the measurement and other injection related quality requirements? Is this the responsibility of the producer, the TSO or a third party?

Is it a barrier?	Yes
Type of Barrier	Structural barriers, Operational barriers, Economic barriers, Regulatory gap
Assessment Severity	3
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National Legislation	The Romanian Energy Regulatory Authority is responsible under Romanian Primary Law for creating a modern energy sector, corresponding to the major principles and objectives of the European Union energy policy of electricity and natural gas market liberalization and capable of meeting consumer demand, ANRE has developed and issued in recent years approx. 986 orders, decisions and opinions in accordance with the obligations deriving from the primary national law and the European legislation
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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
H2 quality requirements	H2 quality requirements are requirements related to the quality of hydrogen (in relation to the composition of the gas(blend) as well as its physical property Hydrogen quality is a term to describe the gas quality for use in the natural gas grid.
Injection of Hydrogen at transmission level (for energy storage and enhancing sustainabily)	Injection of Hydrogen at transmission level (for energy storage and enhancing sustainabily)
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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 the basis for the billing of Hydrogen and Hydrogen Natural Gas Mixtures? Only the energy flow (kWh) or are other properties involved? 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. Billing arrangements do not exist. Question 2 What are the legal and administrative requirements and responsibilities with regard to real-time Measurement Technologies for the monitoring and billing of Hydrogen Natural-Gas Mixtures? Do they differ from the requirements for natural gas? Question 3 Are there other hydrogen quality related legal and administrative requirements to allow the injection of hydrogen in the grid? Question 4 How is the responsibility in your country organized with regard to the measurement and other injection related quality requirements? Is this the responsibility of the producer, the TSO or a third party? Describe the comparable technology and its relevance with regard to hydrogen Natural gas grid injection. LAP data Barrier Type Is it a barrier? Assessment Severity Assessment National Legislations National Legislation #1 Title The Romanian Energy Regulatory Authority is responsible under Romanian Primary Law for creating a modern energy sector, corresponding to the major principles and objectives of the European Union energy policy of electricity and natural gas market liberalization and capable of meeting consumer demand, ANRE has developed and issued in recent years approx. 986 orders, decisions and opinions in accordance with the obligations deriving from the primary national law and the European legislation Url http://www.electrificarecfr.ro/elegi/legi/L123.pdf Relation with EU Legislation In accordance to the provisions of Law no. 160/2012 on the organization and functioning of ANRE, respectively Article 9(1)(w), ANRE complies with and implements all relevant and legally binding decisions of the Agency for the Cooperation of Energy Regulators – ACER – and the European Commission; the decisions of the European Commission issued under Article 39(8) of Directive 2009/72/EC of the European Parliament and of the Council of 13 July 2009 Scope of the relevant parts Please give us a summary of your suggestion E-Mail (optional, if we may contact you)

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