ENTSOG says greater consideration of hydrogen required for TEN-E effort

London — The European Network of Transmission System Operator for Gas has called for greater inclusion of hydrogen projects in the proposed revision of EU regulation for Trans-European Energy Networks, or TEN-E.

ENTSOG said it supported the European Commission's approach to decarbonizing the natural gas sector with hydrogen infrastructure, but said it believed other considerations needed to be included within the framework.

"ENTSOG supports the EC's approach to decarbonize the gas sector with a new focus on hydrogen infrastructure, including their recognition of the value of gas grid repurposing," it said in a statement. "Addition of priority thematic areas and the categories for smart gas grids, hydrogen and electrolyzers is also welcomed."

The recommendations proposed by the organization were headed by an advocation of gas and hydrogen blending, with much of Europe's plans currently centering around dedicated hydrogen networks.

"Priority thematic areas [need] to be expanded to address the retrofitting of gas networks for blending of methane and hydrogen," ENTSOG said.

It is widely believed within the industry that existing transmission and distribution infrastructure for natural gas, and indeed end-user appliances, can tolerate a supply mix of 20% hydrogen and 80% methane without requiring any upgrade.

ENTSOG went on to address European Projects of Common Interest, which are key cross-border initiatives that can benefit from enhanced coordination, funding and accelerated permitting.

"The inclusion of hydrogen projects in the sixth PCI list [is] necessary to ensure adequate planning," it said, adding that natural gas projects on the list need to remain there to encourage competition, security of supply and a switch from coal-fired to gas-fired power generation.

The regulation also needs to accommodate 'full-chain' carbon capture and storage technologies, which extends to the transmission of carbon dioxide as well as its disposal, ENTSOG said.

ENTSOG also echoed previous remarks made by the Agency for Cooperation of European Energy Regulators, or ACER, that TEN-E needs to incorporate the offshore sector.

"Consideration of hydrogen pipelines and gas production facilities in the development of offshore networks [is required}," it said.

The final suggestion called for the framework surrounding 10-year network development plans to be clarified "to ensure objectivity, transparency, effectiveness, timeliness, and TSO involvement on energy system wide cost-benefit analysis."

In ACER's response to the TEN-E proposals, the agency sought a greater role in the appraisal of investments, which it said was "necessary to ensure a neutral approach and further discourage ENTSOs from potential biases," while also referring to the current processes as "lengthy" and "cumbersome."

Jan Ingwersen, general director of ENTSOG, summed up ENTSOG's position on the energy transition in a closing comment.

"We believe that gas infrastructure will continue to play an important role in this transition by repurposing/retrofitting existing pipeline systems, gas storages and LNG terminals for the transition to hydrogen and other low-carbon gases," Ingwersen said. "We look forward to further discussions with European Commission on the TEN-E proposal and related activities."

Response to ACER

ENTSOG has responded to claims made by ACER in its assessment of the TEN-E regulations.

"TEN-E regulation tasks ENTSOG to develop a Cost-Benefit Analysis methodology to support the European Commission's PCI selection process," a statement sent to S&P Global Platts said. "The most recently updated version of the CBA methodology was developed based on opinions of both the EC and ACER, as well as other stakeholders, and was approved by EC in 2018."

The statement went on to explain that the CBA methodology is applied to Ten-Year Network Development Plan (TYNDP) process; something which they are mandated to do by the commission, and that ACER provide their opinion on the TYNDP before it is finalized, while being "involved in the process to ensure compliance with regulation."

The eventual selection of PCIs is made by the EC, member states, and National Regulatory Authorities NRA, the latter of whom also contributed to ACER's TEN-E response.

"The methodologies used to identify needs and to rank projects in the PCI process are initially discussed in the so called 'PCI Cooperation Platform' comprised of EC, ACER and ENTSOG," the statement continued.

"Proposals are then made to the Regional Groups... in charge of adopting the methodologies," ENTSOG said. "The EC's proposal for TEN-E Regulation revision reiterates the importance of early stakeholder consultation, the opinion by ACER and the final approval by the Commission in the CBA process. ENTSOG believes that objectivity and transparency in this process is already taking place and should continue, while still allowing the important TSO involvement in the energy systemwide CBA."