Legal framework: permissions and restrictions (and Ownership constraints (unbundling))

This LAP concerns the legal framework status covering authorised bodies overseeing and involved with the injection of hydrogen and varying hydrogen concentration levels in the TSO high pressure gas transmission system, along with potential changes to the regulatory framework to support enhanced hydrogen injection and utilisation

Glossary:

Legal framework: permissions and restrictions (and Ownership constraints (unbundling)) represent the existing national legal framework for the TSO to carry out hydrogen activities, which is normally restricted to natural gas. Ownership constraints refer to the constraints related to ownership associated with the process of injecting

select country:

Is it a barrier?

Yes

Type of Barrier

Operational barriers

Assessment Severity

Questions:

Question 1 Which is the responsible authority/legal entity for the permission of the connection/injection of hydrogen in the gas grid?

The gas grid operator is responsible for the permission of connection / injection of H2 into the grid. A the the distribution level, it’s the national gas distributor: GrDF. At the transport level, it’s the national gas transporter: GRTgaz.

Question 2 What is permitted or restricted according to national legislation under your responsibility as TSO regarding the transport of pure hydrogen and mixtures of hydrogen and natural gas.

The national gas distributor and transporter are defining there own technical specifications on the characteristics and compositions of the gases other than natural gas that can be injected into the grid. The corresponding technical specifications are published and updated by the Distribution and Tansportation Grid operators.

Question 3 Is there a maximum concentration defined that you are allowed to transport as a TSO? (e.g. are you allowed to transport 100% hydrogen)

Yes there is a maximum H2 concentration allowed The transportation of 100 % is not authorized by the TSO./

Question 4 What is the maximum allowed concentration in your country for injection in the gas grid on transmission level?

The maximum concentration allowed in the injected gas before injection is 6 % (mol.).

Question 5 In case the maximum hydrogen concentration in your transmission grid (system) is less than 100%, is it allowed to inject pure hydrogen- 100%? into gas grid on transmission level (up to the allowed concentration)? If no, who is responsible for the blending with natural gas? Is there an obligation for the TSO to provide the necessary natural gas for blending the hydrogen (with several EU Directives transposed into national legislations the functions of gas grid operator and natural gas supplier are separated)

The injection of pure H2 is not allowed at this stage.. The maximum concentration allowed before injection is 6 % (mol.) The provider who is injecting the gas is legaly responsible for the quality and quality assurance of the gas injected and the blending. The blending can be done by the grid operator through a specific blending unit operated by the grid operator (the costs have to be covered by the “injector”).

Question 6 Are there specific requirements for increasing or decreasing the admissible threshold of hydrogen concentration (upstream and downstream networks, infrastructure elements and appliances with lower tolerance)? If yes: please describe.

At this stage, there are no specific requirements for increasing or decreasing the admissible threshold of H2 concentration upstream and downstream network.

Question 7 Are there specific restrictions/permissions for the transport of hydrogen other than “concentration” and “quality”, if yes which ones?

As the higher heating value of gases other than natural gas can have vide variation spred, the injection operator has to provide to the gas grid operator (transport or distribution grid) the measures that will be taken to avoid this spread, so that he connected costumers will see no impact on there connected equipment or process.

Question 8 If it can be guaranteed that the gas is on the required quality specification (on spec) at the next customer, is it allowed to feed in off-spec gas (read: a higher concentration of Hydrogen)?

No..

Question 9 Which part of the connection facility (the injection installation is part of the connection facility) is owned by or under the responsibility of the TSO?

The injection installation is owned and operated by the TSO. It is rented to the gas injector (on a the basis of a specific supply contract – the renting fee is normaly paid every 3 month).

Question 10 As TSO, do you see legal and administrative restrictions with regard to the ownership of your part of the connection facility (the injection installation is part of the connection facility) of hydrogen into the grid?

Question 11 Is there a difference in legal and administrative restrictions between connections for hydrogen injection into TSO and DSO-networks? If so could you please specify the differences?

The specifications for the injected gas are the same for the TSO and DSO networks. The only difference is in the flow rate of the gas to be injected: – for the transport level, the minimum capacity that is authorised to be injected is 50 Nm3/h of gas other than natural gas; – for the injection of gas into the grid, the demand has first to be made to the DSO, and if the gas flow rate to be injected is to high for the distribution grid, than the demand can be made at the transport level if there is transport pipe–line next to the gas production unit.l

Question 12 Are there specific national (add-on) restrictions for the connection/injection of hydrogen in TSO networks compared to the connection/injection of natural gas? If yes: please name them. Are there other requirements for the injection of H2NG-blends compared to pure Hydrogen?

The specific restrictions are given by the technical specification of the TSO and DSO This restriction are only focusing on the quality of the injected gas, other than natural gas. The direct injection of H2 is actually not generally authorised by the grid operators. A H2 / natural gas blend is treated as a non natural gas. So he has to fulfil the specific prescriptions of the operator to be injected.

Question 13 Is it foreseen to review the current regulation to consider hydrogen injection into natural gas network and if yes on which term?

The technical feasibility of direct H2 injection within the distribution grid and the transportation will be tested in two actually on–going pilot demonstration projects in France. For the injection at the transportation level: JUPITER 1000 project; For the injection at distribution level: GrHYD project. The first relevant results of these projects will be available in the next 2 to 3 years, after 1 to 2 years of operation and analylis of the first REX’s available.

Describe the comparable technology and its relevance with regard to hydrogen

Injection of bio–methane

National legislation:

Décret n°2004–555 du 15 juin 2004 relatif aux prescriptions techniques applicables aux canalisations et raccordements des installations de transport, de distribution et de stockage de gaz – “Technical regulation applicable to gas piping and connections for gas transportion , distribution and storage installations”.
Regulation related to the technical prescriptions applicable to the connections and pipings to the natural gas transport and distributions grids and t natural ga s storage units.
The operators elaborate the technical prescriptions that have to be respected and fulfilled by the operators themselves and the natural gas provider and trading companies and operators.

In particular, the interoperability and the free access to the grids has to be guaranteed. The safety of the persons, of the environment and the safe operation of the grids must be garateed.
Code Acheminement – Pièce A2 – Prescriptions techniques applicables aux canalisations de transport de GRTgaz et aux installations de transport, de distribution et de stockage raccordées au réseau de GRTgaz (GRTgaz document) – Edition 01/04/2017 – “Transportation code – technical prescriptions for the gas transportation and distribution piping and gas storage facilities connected to the GRTgaz grid (GRT gaz = French national gas transporting operator)
Code Acheminement – Pièce A2 – Prescriptions techniques applicables aux canalisations de transport de GRTgaz et aux installations de transport, de distribution et de stockage raccordées au réseau de GRTgaz (GRTgaz document) – Edition 01/04/2017 ("Technical prescriptions applicable to gas transport installations operated by GRTgaz and to the distribution and storage installations connected to the GRTgaz grid").
This document gives all the technical prescription applicable to the gas transporting pipes of the TSO and the prescriptions for the transport installations and the connected gas distribution pipes and the gas storage connected to the transport grid

The GRTgaz (TSO) specitifations on gas composition, the complete applicable legislation and standards are given..
Prescriptions techniques du distributeur GrDF – “Technical prescriptions form the national gas distributor GrDF”
This document gives all the technical prescription applicable to the gas distributing pipes of the DSO and the prescriptions for the distribution installations and the connected gas distribution pipes and the gas storage connected to the distribution grid.

The GrDF (DSO) specitifations on gas composition, the complete applicable legislation and standards are given.

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.

Article 25 establishes the “Tasks of the distribution system operator” which include: ensuring the long-term ability of the system to meet reasonable demands for the distribution of gas […];shall provide any other distribution, transmission, LNG, and/or storage system operator with sufficient information […] as well as to ensure that the system operator does not discriminate between system users or classes of system including, including e.g. when setting rules for the charging of system users, etc

Article 32 sets the rules on “Third party access”: access to the transmission and distribution system, and LNG facilities shall be based on published tariffs, applicable to all eligible customers, including supply undertakings, and applied objectively and without discrimination between system users.
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
Article 1 Project matter and scope
This regulation aims at:
(a) setting non–discriminatory rules for access conditions to natural gas transmission systems taking into account the special characteristics of national and regional markets with a view to ensuring the proper functioning of the internal market in gas;

Article 8 “Tasks as regards terms and conditions for access to and operational security of cross border infrastructure
Commission Regulation (EU) 2015/703 of 30 April 2015 establishing a network code on interoperability and data exchange rules
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.Article 7, Measurement principles for gas quantity and quality. In addition to interconnection points, Article 17 shall apply to other points on transmission network where the gas quality is measured. Article 18 shall apply to transmission systems. This Regulation may also apply at entry points from and exit points to third countries, subject to the decision of the national authorities.