Leading business representatives including the German Hydrogen and Fuel Cell Association (DWV) and German Technical and Scientific Association for Gas and Water (DVGW) support changing the Gas Market Directive as it is now written by the EU Commission (2021/0425 (COD)).

The directive, which is being coordinated at the European level, might irreparably harm the hydrogen economy, impede the energy transition, and endanger the existence of municipal utilities.

Gas networks that are already in place and are highly developed can be used to carry hydrogen. But a combined network operation of gas and hydrogen would face very difficult obstacles, according to EU proposals. Due to the requirements for vertical unbundling, a transition to hydrogen would not take place at all in the case of municipal utilities, which run a significant portion of the German gas distribution network and are mostly vertically integrated in Germany. As a result, the essential supply of local industrial and residential consumers with climate-neutral hydrogen would not take place, and the network operators’ ability to operate profitably would be constrained. This would have a significant impact on municipal budgets.

Investment roadblocks

The current network operators would have no motivation to spend money converting and expanding the existing gas networks into hydrogen networks.

The portions of the economy that cannot be electrified (industry and SMEs) lose their competitiveness and have no chance of transformation if there is no supply of green H2. No imports are possible without the proper networks.

Associations and businesses have banded together at the initiative of the HyInfrastructure commission of DWV and DVGW to lobby the Federal Chancellor, Economics Minister, and other significant political figures for the following changes:

  • The continuation of hydrogen network operators using the accepted ITO model after 2030
  • Differentiating the “long-distance” and “distribution” network levels for hydrogen, comparable to gas and electricity
  • Applying the DSOs’ current unbundling regulations to hydrogen distribution networks in local and regional areas
  • The use of the current TSO unbundling rules for supra-regional hydrogen transmission networks
  • There is no legal separation of the hydrogen and methane networks to allow for synergy in the best interests of customers.

The following businesses and organizations back the appeal: 2G Energy, B.KWK, BMW Group, DBI, DVGW, DWV, elogen, EnBW, energie schwaben, energie Südbayern, ENETRAG, E.ON, EWE NETZ, FNB Gas, GASAG, GASCADE Gastransport, GELSENWASSER, HYPOS, Nikola, Nowega, ONTRAS, Proton Motor Fuel Cell, RheinEnergie.

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