Germany must speed up its development of the hydrogen infrastructure in order to secure supplies and promote climate protection. The hydrogen report presented by the transmission system operators shows how the necessary transport infrastructure can be developed efficiently, quickly and in a targeted manner by integrating hydrogen network planning into established gas network planning measures.

With 12 recommendations, the transmission system operators are providing the Federal Network Agency and the legislature with proposals that should be implemented this year. At the heart of the hydrogen report is a concept for a binding and integrated network development planning process for gas (hydrogen and methane).

1. Introducing a binding and integrated network development planning process for gas (hydrogen and methane), as has been successfully implemented for many years in both the gas and electricity sectors. The network development planning process replaces the system of needs-based assessment currently provided for in § 28p of the Energy Industry Act (EnWG) by the Federal Network Agency (BNetzA) with regard to individual hydrogen network infrastructures. A hydrogen report in accordance with § 28q EnWG is no longer needed owing to the introduction of integrated network development planning for gas (hydrogen and methane). The obligation to produce it should therefore be lifted. 
2. Confirming a starting network derived from strategic generation and consumption focal points without further delay even before the introduction of the described control process. 
3. Creating a regulatory framework that provides for uniform and mandatory regulation for all hydrogen network operators operating a hydrogen network for public supply, in order to make cooperation in the area of hydrogen network planning and the exchange of information necessary for this possible. This regulatory framework must grant rights and set out obligations comparable to those which apply to transmission system operators in the natural gas sector. These include: 
   1. the comprehensive duty of cooperation on the part of the network operators concerned in the preparation of the network development plan (NEP), including the exchange of all information required for this purpose, 
   2. the obligation of all relevant network operators to agree on coordinated network planning in a joint NEP, and 
   3. ensuring the implementation of the network development measures – after confirmation by the BNetzA, which at the same time confirms that they are in line with requirements – by placing corresponding investment obligations on the network operators. 
4. Creating a regulatory framework which, on the one hand, allows the refinancing of the investments made by the network operators and, on the other hand, leads to economically viable network charges, especially in the market ramp-up phase. It is important to address risks appropriately and to build the confidence of both investors and transport and hydrogen customers during the hydrogen ramp-up. 
5. Rejecting unbundling between natural gas and hydrogen network operations in European regulation and retaining the proven unbundling between the competitive activities of production and supply on the one hand and the non-competitive activities of transport on the other. 
6. Continued independent network development plans and scenario frameworks for electricity and gas (hydrogen and methane) with closer integration of both processes to meet the challenges of the transformation of the energy system. 
7. Temporal harmonization between the NEP Electricity and NEP Gas (hydrogen and methane) to take into account interactions, so that coordination is possible in the process between the transfer system operators on the one hand and the transmission system operators and hydrogen network operators on the other, and the confirmations by the BNetzA can be consistent and coordinated in terms of content. 
8. Introducing an upstream energy scenario process that provides a common scenario basis in the form of uniform assumptions (e.g. regarding demand forecasts) and targets, and thus consistent input parameters for electricity and gas (hydrogen and methane) network planning. The relevant scenario framework for the NEP Electricity and NEP Gas (hydrogen and methane) should then be derived from these energy scenarios. The network operators must be heavily involved in this process. 
9. Introducing tools for optimizing sites for power-to-gas (PtG) plants as well as gas-fired power plants, e.g. in the form of incentives (among others within the network charging systems, the approval processes or financial support measures). 
10. Establishing the legal and regulatory prerequisites for the conversion to hydrogen in the area of transmission and distribution system operators, in particular by introducing legal authority for the conversion of network areas including the network customers connected there. 
11. Taking into account planned conversion areas of transmission and distribution system operators in the network development planning for gas (hydrogen and methane). The basic conversion of areas is confirmed via the NEP Gas (hydrogen and methane). This should be done as early as possible in order to provide a high degree of commitment with an appropriate lead time for all customers involved. 
12. Introducing a legal obligation to use hydrogen or conversion-capable appliances when replacing or installing a new gas heating system as soon as these are available nationwide in order to simplify future conversion processes as much as possible at an early stage.

You can find out more about the hydrogen report and its relevance on the pages of FNB Gas.

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