ENNOH

ENNOH will be the organisation for the cooperation of the EU Hydrogen Transmission Network Operators (HTNOs).

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ID: 189583796325-82

Lobbying Activity

8 Oct 2025

The European Network of Network Operators of Hydrogen (ENNOH) welcomes this Call for Evidence and would like to use the opportunity to provide its contribution. As mentioned in this Call for Evidence, the main issue the EU electrification action plan aims to tackle is the stagnant level of electricity in energy consumption. Negative electricity prices and curtailment of renewable electricity are also rightly pointed out. In ENNOHs view a closer cooperation between the hydrogen and electricity sectors would help to overcome these challenges and would be beneficial for the development of both sectors. It would allow to: 1. maximise the use of renewable by reducing curtailment. Electrolysers can operate flexibly and adjust their production given the right economic signals. This flexibility helps avoid curtailment in cases of excess production compared to demand and/or grid congestion, while also contributing to lower price volatility. Market resilience to supply and demand shocks would also be enhanced. Finally, due to less congestion, there would be more price convergence between bidding zones. 2. reduce or remove redispatching due to congestion on the electricity grid. 3. transport energy over long distances, in a more feasible and cheaper way. 4. store large quantities of energy for a short, medium and long-time at lowest cost. The hydrogen backbone will act as a short-term buffer with underground hydrogen storages allowing for a more long-term system flexibility and resilience. Using batteries and other storage technologies in the electricity system will not be available on sufficient scale. Electricity prices would not anymore be depressed or negative since electrolysers could increase their consumption when wholesale prices are getting depressed due to congestion, hence solving it. Electrolysers can operate flexibly and adjust their production volumes given the right economic signals, acting as additional electricity system load that supports rather than strains the grid. By contributing to resource adequacy, sector coupling between the electricity and hydrogen systems can ensure renewable electricity producers revenues will be more certain than relying on repayment of curtailed production. In periods of low renewable availability, hydrogen-fired CCGTs can provide dispatchable power, supporting short-term flexibility and overcoming prolonged Dunkelflaute events. Electrolysers can also be stopped and their production temporarily replaced by stored hydrogen and hydrogen backbone linepack which would restore (unused) electricity to the grid and help control price peaks. More hydrogen would remove several of the mentioned key reasons explaining the electrification stagnation: limited demand-side flexibility, insufficient storage and grid capacity for distributing renewables to consumers at different times and the lack of electric solution for hard-to-abate sectors. It is important to recognise the interdependence of hydrogen and electricity. That is why hydrogen produced from renewable electricity should also be promoted in the EU electrification plan possibly with a key performance indicator of the same type as the 3233% of share of electricity in final energy consumption in 2030. End-users would have more confidence to electrify their energy consumption if they had more efficient and effective solutions to cope with intermittent production and transport congestion, bypassing it with other coupled carriers and infrastructures. That is why energy system integration should be promoted in the upcoming electrification action plan.

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Response to European grid package

28 Jul 2025

ENNOH, the EU hydrogen transmission operators association, would like to propose three types of amendments to TEN-E. ENNOH would be glad to further elaborate on them at your convenience. 1. On ENNOH establishment: - ENNOH sees the necessity for further amendments (more than the ones provided in Art. 86 of Regulation 1789/2024) to TEN-E to ensure a level playing field between ENNOH, ENTSOG, and ENTSO-E, and thereby facilitating the integration of hydrogen into an interlinked energy system. - Furthermore, article 14 on Offshore Grid Planning Process should be amended to include ENNOH as the leading governing body in the Offshore Network Development Plan (ONDP) for hydrogen infrastructure (today this responsibility of offshore infrastructure planning is explicitly placed on ENTSOE), and also include ENNOH in the ONDP, in general, on equal footing with ENTSO-E. 2. On hydrogen infrastructure funding specific issues: Originally developed for the existing and already mature electricity and gas sectors, the current CBCA methodology is designed for incremental infrastructure developments in mature markets with a large number of existing network users. In the case of hydrogen, however, this is a nascent market. Thus, any estimation of the future distribution of net benefits as a basis for cost allocation is highly uncertain and should be left for later. A tailored approach is needed to ensure its relevance and effectiveness. It is therefore critical to revise the current CBCA framework and its applicability to the early H2 sector to provide necessary flexibility and augment it with additional derisking models. That is why ENNOH proposes: - To have financial guarantees, either by Member States involved in specific import corridor projects, or centrally by a European institution. Such guarantees could be designed in various formats, e.g., in the form of financial guarantees that take effect if the returns from network services are insufficient to meet the network operators allowed or target revenue. Such a de-risking possibility on European level should be included in the TEN-E. - Set up other forms of financial support for the deployment of hydrogen corridors, ensuring long-term binding capacity booking commitments based on identified cross-border needs and provided by either shippers or financial institutions or public bodies, such as centralised entities (e.g. via EU-backed guarantees). - National de-risking tools, such as Intertemporal Cost Allocation (ICA), should be replicated across the EU. These mechanisms, backed by State guarantees, are essential for hydrogen backbones and storage. 3. On simplifying the PCI process: - The current PCI process is excessively lengthy, and the PCI status, valid for only two years, creates uncertainty for promoters and investors while imposing unnecessary administrative burdens. To address this, a simplified procedure could be considered for maintaining PCI/PMI status when no significant changes occur. - The project promoters need a CBCA agreement before they are eligible to apply for funds or grants. The process could be accelerated by at least a year by: o permitting project promoters to apply for funding and receive grants for works based on a conditional CBCA agreement, or o opening the possibility of avoiding the CBCA step for projects providing net benefits to all affected national systems (i.e. CBCA = 0). - The last TEN-E revision introduced lengthy opinion/approval periods totalling up to 20 months. This can be made more efficient by reducing the regulatory approval periods by ACER, EC and Member States for TYNDP deliverables to no longer than 4-6 weeks. - Clear procedural steps and indicative timelines for the Investment Request process should be defined. - National permitting manuals should follow a standardised format, be made available in English, and be published on a centralised platform managed by the European Commission.

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Meeting with Teresa Ribera Rodríguez (Executive Vice-President) and

16 Apr 2025 · Hydrogen infrastructure

Meeting with Dan Jørgensen (Commissioner) and

14 Mar 2025 · hydrogen

Meeting with Mechthild Woersdoerfer (Deputy Director-General Energy)

5 Mar 2025 · Exchange views on the establishment of ENNOH

Meeting with Dan Jørgensen (Commissioner) and

30 Jan 2025 · Affordable Energy action Plan