H2/SNG quality requirements

This LAP is concerned with the measurement, monitoring, metering and billing basis for hydrogen based SNG (via methanation) injected and transported within the gas grid at DSO or TSO level


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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 2-5 are the same as for category 7, application 1: injection of hydrogen in the gas grid and do not have to be answered
	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). However the network is configured for natural gas only. Hydrogen is not covered and there is no billing arrangement for hydrogen network injection / transportation .
What is the basis for the billing of SNG from hydrogen and SNG from Hydrogen Natural Gas Mixtures? Only the energy flow (kWh) or are other properties involved?

What are the legal and administrative requirements and responsibilities with regard to real-time Measurement Technologies for the monitoring and billing of SNG from hydrogen Natural-Gas Mixtures? Do they differ from the requirements for natural gas?

Are there other, SNG from hydrogen quality related, legal and administrative requirements to allow the injection of SNG from 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/DSO 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/SNG quality requirements	Requirements related to the quality of SNG from (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.
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 2-5 are the same as for category 7, application 1: injection of hydrogen in the gas grid and do not have to be answered 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). However the network is configured for natural gas only. Hydrogen is not covered and there is no billing arrangement for hydrogen network injection / transportation . Question 2 What is the basis for the billing of SNG from hydrogen and SNG from Hydrogen Natural Gas Mixtures? Only the energy flow (kWh) or are other properties involved? Question 3 What are the legal and administrative requirements and responsibilities with regard to real-time Measurement Technologies for the monitoring and billing of SNG from hydrogen Natural-Gas Mixtures? Do they differ from the requirements for natural gas? Question 4 Are there other, SNG from hydrogen quality related, legal and administrative requirements to allow the injection of SNG from hydrogen in the grid? Question 5 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/DSO or a third party? Describe the comparable technology and its relevance with regard to hydrogen The natural gas transmission and distribution technology. 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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