Pursuant to Section 28q EnWG, transmission system operators (TSOs), together with hydrogen network operators who have submitted a declaration pursuant to Section 28j (3) EnWG (opt-in H2 network operators), have the obligation to submit a report to the Federal Network Agency by September 1, 2022 at the latest on the current state of expansion of the hydrogen network and on the development of future network planning for hydrogen with the target year 2035 (hydrogen report).
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With the hydrogen network for a climate-neutral Germany (H2 network 2050), the transmission system operators (TSOs) are demonstrating that they can construct such a network efficiently and reliably at moderate investment costs. The H2 network 2050 has been further developed by the TSOs from the “Visionary Hydrogen Network” published in January 2020. This first vision of the future included many considerations, but without a network simulation for future hydrogen transport needs. The H2 network 2050 now presented, on the other hand, is based on detailed grid planning.
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With the Hydrogen Network 2030 (in short: H2 Net 2030), the transmission system operators (TSOs) show solutions how transport needs can be met promptly on a supra-regional basis in the case of dynamic development of the hydrogen market.
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The transmission system operators submitted comments on the draft ordinance on costs and charges for access to hydrogen networks as part of the associations’ consultation process.
In their statement, the TSOs welcome the attempt to launch the principles of network charging methods for the future regulated operators of hydrogen networks before the end of this legislative period. The regulation is an important (although not the only) basis for the entrepreneurial decision of network operators on the so-called “opt-in” into regulation pursuant to § 28j para. 3 EnWG. Parameters of the regulation, such as the level of the EC interest rate or the depreciation periods/useful lives, are central here. In addition, H2NEV will also have a special significance in the context of public funding (e.g. IPCEI).
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On February 10, 2021, the German cabinet approved a draft law to implement EU requirements and regulate pure hydrogen networks in energy law. Contrary to the view held by the majority of the energy sector and industry that the natural gas network and the hydrogen network to be developed from it should be regarded as a single entity in terms of network planning and finances, the draft law provides for a strict separation of natural gas and hydrogen networks. The German government rejects joint financing of the development of the hydrogen infrastructure by natural gas and hydrogen customers with reference to EU law, without concrete proof.
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On February 10, 2021, the German government presented draft legislation to regulate pure hydrogen networks in the German Energy Industry Act (EnWG). The transmission system operators (TSOs) very much welcome the fact that the urgency to create a regulatory framework for hydrogen networks has been recognized and that the first legal foundations for pure hydrogen networks are being laid.
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The transmission system operators (TSOs) welcome the fact that the German government has recognized the urgency of creating a regulatory framework for hydrogen networks and has submitted a draft bill for consultation. First of all, it should be noted that the consultation period was very short in view of the high complexity and importance, in particular, of the regulations concerning hydrogen networks for our members. Therefore, we reserve the right to provide further comments on some aspects, if necessary.
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