EU members should have more flexibility to scale up the national and regional hydrogen markets

On the 29th of April 2021 at the 35th Madrid Forum, Ralph Bahke, GIE New Gases Area Sponsor, gave a presentation on “GIE Position Paper on the Regulation of Hydrogen Infrastructure“.

Ralph Bahke underlines that the gas infrastructure is able to follow three different pathways for the integration of hydrogen.


a) Enables hydrogen to be blended into natural gas

b) (De)blending to enable quick decarbonisation wins and scale-up of (de)centralised hydrogen production/technologies

c) Cost-effective transitional solution in several EU countries.


a) Using existing gas infrastructure to transport, store and import and export 100% hydrogen

b) Cost- and time savings

c) Cost- and time savings.


a) Connecting hydrogen supply and demand

b) Infrastructure companies have the expertise to build, own and operate hydrogen infrastructure.

Read more: Italy could be a European hydrogen hub thanks to North Africa

Ralph Bahke underlines the fact that single hydrogen pipeline can transport 10-20 times more energy than an electricity cable. Moreover repurposing pipelines at 10-35% of costs that would be required for newly built hydrogen pipeline.

He adds that salt caverns, depleted fields and acquifers in the EU could already today have a theoretical potential of storing 60 TWh hydrogen. He points out that gas storages are at least 100 times cheaper than electricity storage costs in batteries.

Speaker also noted retrofitting and repurposing LNG Terminals at lower costs (compared to investments into new terminals) that contribute to enable the intra-EU trade, non-EU imports and exports of hydrogen and hydrogen carriers.

Ralph Bahke gave the following policy recommendations:

  • Give Member States more flexibility to apply the appropriate regulatory environment to scale up the national and regional hydrogen markets depending on the market developments.
  • Acknowledge and enable the crucial role of infrastructure operators to contribute to the EU climate targets by being allowed to retrofit, repurpose, build and consequently own and operate their infrastructure.
  • Consider the basic principles of the regulation for electricity and natural gas to be extended to the regulation of hydrogen from the outset, including: The principle of unbundling from vertically integrated activities, Third-Party-Access to the hydrogen infrastructure for all market users based on transparent and non-discriminatory access rules, taking into account the specifics of regional hydrogen markets. E.t.c
  • Accounting rules for gas and hydrogen infrastructure should allow a transparent mutualisation of costs between the different parts of the wider energy system – including gas and hydrogen infrastructure – to ensure cost reflective and stable tariffs for using the gas and hydrogen infrastructure in the long run for the benefit of all energy users.
  • Especially when scaling up a hydrogen infrastructure, a coordinated energy system and network planning between electricity, gas and hydrogen infrastructure should be the central mode for identifying the necessary infrastructure needs, allowing for ‘Member States’ to choose on the right remuneration model at national level.
  • In fulfilling the current EU legislation, it is crucial that gas infrastructure operators, including TSOs, should be allowed to participate in decarbonisation activities, supporting the development of innovative technology facilities (including power-to-gas-facilities).
  • Implementation of national regulatory sandboxes in the revised legislation may represent a first application to support innovative initiatives.