Resort: Energy Future

Network operators set up coordination office for integrated network development planning for gas and hydrogen

The newly established Coordination Office for Integrated Gas and Hydrogen Network Development Planning (KO.NEP) officially starts work today.

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FNB Gas statement on the BMWK’s draft bill for the Hydrogen Acceleration Act (WassBG)

FNB Gas welcomes the BMWK’s consultation on the “Draft law to accelerate the availability of hydrogen and to amend further legal framework conditions for the hydrogen ramp-up”. The draft is aimed at a large number of facilities for the import, production and storage of hydrogen and underlines the public interest in the accelerated implementation of this important part of the hydrogen infrastructure.

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Statement of the FNB Gas on the Green Paper Transformation Gas/Hydrogen Distribution Networks of the BMWK

The FNB Gas has commented on the BMWK consultation of 14.03.2024 on the “Green Paper Transformation Gas/Hydrogen Distribution Networks”. The aforementioned challenges of transforming the distribution networks to renewable gases while maintaining the security of supply and affordability of the energy supply in general, and in the natural gas sector in particular, affect not only the distribution networks but also the transmission networks.

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Statement of the FNB Gas on the key points of the depreciation modalities for the gas network transformation

The transmission system operators welcome the fact that the BNetzA is now taking into account the challenges for the useful life of the network infrastructure with the KANU 2.0 specification.

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A total of 1724 project applications received

Thank you for your interest in the Germany-wide survey of infrastructure requirements for the electricity and hydrogen grid. The market survey for hydrogen projects (WEB) received a total of 1724 project notifications. On expiry of the deadline on 22.03.2024, the reported data was write-protected and is considered reported. The registered projects remain in the associated database and can still be viewed – but not changed or deleted – by project registrants after March 22, 2024.

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Brief statement by the FNB Gas on the BNetzA’s consultation on the further development of the regulatory framework for electricity and gas networks (NEST)

On 25.01. the Federal Network Agency published a key issues paper on the further development of the regulatory framework for electricity and gas network operators in the 5th regulatory period. As a result of the ECJ ruling and the recent amendments to the EnWG, the BNetzA has been given extended powers to lay down regulations. The title of the paper is “NEST: Networks, Efficient, Secure, Transformed”.

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Integrated network planning for the energy system of the future: TSOs launch first joint market survey

The first joint survey of infrastructure requirements by the transmission system operators (TSOs) for the preparation of the scenario framework drafts for the electricity, gas and hydrogen network development plans starts today.

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Integrated network planning for the energy system of the future: First joint market survey by TSOs starts on February 7, 2024

The electricity and gas TSOs are now setting a milestone for sector coupling with the first joint survey of infrastructure requirements for electricity and hydrogen. The network operators will use specially developed web applications to ask existing and potential customers about their future needs. Based on this information, the grid operators can develop the corresponding infrastructure in line with demand and thus ensure a reliable energy supply for the future.

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Transmission system operators on the path towards the hydrogen future

FNB Gas e.V. is celebrating its tenth anniversary this year. On this occasion, the association discussed with guests from politics, the energy sector and industry at the hydrogen infrastructure conference how the market ramp-up of hydrogen can be further accelerated together.

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Comments on the draft bill to extend the provisions of Part 3a and to amend Section 49b (1) sentence 1 of the Energy Industry Act (EnWG)

The regulations of Part 3a of the EnWG with the requirements on gas storage levels are to be extended until April 2027. This is based in particular on the fact that the onshore LNG terminals are expected to come on stream in mid-2027, from which point a further easing of the supply situation can be expected. The transmission system operators expressly support this approach. It has been shown that the legal regulations are suitable for the safe filling of gas storage facilities in Germany.

The intended amendment to Section 49b (1) Sentence 1 of the German Energy Industry Act (EnWG), which is intended to allow an extension of the temporary higher utilization of the electricity grid until the end of March 2027, is to be expressly welcomed as a measure that makes sense in terms of energy and the economy. Nevertheless, the temporary increase in capacity utilization associated with an acquiescence obligation represents a considerable expense for the TSO, which is not adequately taken into account by law. In the absence of concrete legal regulations, the contractual arrangements between the transmission system operator and the TSO are still subject to various uncertainties (e.g., the extent of the obligation to bear costs). In addition, the short-term approval of the necessary protection and safeguard measures also represents an additional burden for the TSO in the absence of legally manifested acceleration regulations. Therefore, the consequences for the affected operators of technical infrastructures must be given greater focus. The TSOs made concrete proposals for this in the course of the hearing with the associations.

The complete statement of the FNB Gas is available in the downloads.

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FNB Gas welcomes the German government’s initiative to create the conditions for the hydrogen core network with the amendment to the EnWG

As part of the adaptation of energy law to EU requirements, the BMWK also intends to make changes to the EnWG to supplement the regulatory regime for hydrogen as an energy carrier. The goal of the new regulations is to rapidly ramp up the hydrogen market to ensure decarbonization, particularly in the highest greenhouse gas emitting sectors of the economy where more energy and cost efficient alternatives to hydrogen are not available.

The TSOs welcome the German government’s initiative to now lay the regulatory, antitrust and network planning foundations for the development of an efficient and expandable hydrogen core network. The regulations are a key step in the development of a Germany-wide hydrogen infrastructure, which should provide market participants with planning and investment security.

The draft bill provides a clear political mandate for the TSOs to develop the supra-regional hydrogen core network, taking into account other infrastructure operators and other infrastructure suitable for transporting hydrogen (at the transmission level) safely. The TSOs have the necessary expertise and are guarantors for the fastest possible development of the German hydrogen network from mainly convertible lines and in the existing private-sector structures.

The German government’s amendment to the Energy Industry Act (EnWG) creates the conditions under antitrust law and planning law for planning the hydrogen core network. For their part, the FNB will do everything in its power to ensure that implementation can begin this year.

However, the draft bill leaves open and unresolved issues such as the financing of the hydrogen core network, which are crucial for the realization of the investments. The corresponding solutions must be developed promptly and introduced into the legislative process in order to ensure the necessary investment security.

The FNB sees a solution to the refinancing problem essentially based on the concept of advance financing of the hydrogen core network by the FNB combined with state risk insurance in the event of failure of the hydrogen ramp-up, which the German Energy Agency (Dena) had already proposed in the summer of 2022. In addition to the dena model, it would be possible to flank the mechanism with a levy or financial transfers from the natural gas system, as is also envisaged in the amendment to the EU gas market package currently being negotiated.

The complete statement of FNB Gas is available in the downloads.

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Statement of FNB Gas on the proposed amendments to the REMIT Regulation

The European Commission presented a reform of the European electricity market on March 14, 2023. As part of the reform, EU legislation such as the Electricity Regulation, the Electricity Directive and the REMIT Regulation are to be revised. In the interest of competitive markets and transparent pricing, the Agency for the Cooperation of Energy Regulators (the ACER) and national regulators should be able to better monitor the integrity and transparency of the energy market in the future. The proposed amendments to the REMIT Regulation are intended in particular to ensure greater data quality and to strengthen ACER’s ability to investigate potential market abuse in cross-border cases.

FNB Gas welcomes in principle the Commission’s intention to better protect consumers and industry from market abuse. In its statement on the proposed amendments to the REMIT Regulation, however, FNB Gas takes a critical view of the planned transfer of competences to the European level and calls for a clearer demarcation between the powers of ACER and the national regulatory authorities. In addition, more transparency in the establishment of new market rules through implementing acts of the European Commission and guidelines and recommendations of ACER is suggested. Market participants should be given the opportunity to participate in the adoption of the aforementioned legal acts through public consultations. Furthermore, for data protection reasons, the proposed expansion of the definition for inside information is critically questioned.

The complete statement of FNB Gas on the amendment of the REMIT Regulation in German and English version is available in the downloads.

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Statement of the FNB Gas on the draft of the BMWK for the adaptation of the energy industry law to the requirements of EU law

The German Federal Ministry of Economics and Climate Protection has published a draft bill to amend the Energy Industry Act. The reason for this is a ruling by the European Court of Justice in September 2021, according to which the Federal Republic of Germany, by enacting a series of more specific normative regulatory provisions, has violated, among other things, the requirements of Union law on the independence of the regulatory authority under EU law. At the same time, the Act is intended to make other necessary changes to energy law, such as adapting the regulations on the security and reliability of energy supply.

Despite the short consultation period, FNB Gas is pleased to comment on the proposed amendments to the Energy Industry Act. However, due to time constraints, our comments are limited to individually selected regulations that directly affect transmission system operators (TSOs). The FNB also agrees with the statement of the German Association of Energy and Water Industries (BDEW). This addresses other key points in the current bill where urgent changes are also needed. This relates in particular to the draft’s policy guidance on regulation and requirements for regulatory agency decisions.

The TSOs generally support the political objective of accelerating measures to increase the capacity utilization of the extra-high voltage grid (electricity). However, these new regulations must not be at the expense of other infrastructure operators, such as TSOs, and their protection and safeguarding measures. For this reason, the TSOs welcome the current draft bill on the adaptation of energy industry law to EU requirements, as it represents an important building block for ensuring environmentally compatible energy supply security and for restoring the best possible safety of operating personnel and third parties as quickly as possible. However, in the view of the FNB, the proposed new introduction of Section 49c, in particular the provision in Section 49c(6), is inadequate.

The complete statement is available in the downloads.

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FNB Gas statement on EU methane legislation

The Association of German Transmission System Operators and its members support the recommendation paper of ENTSOG, Eurogas, GERG, GIE, MARCOGAZ on the proposals of the European Commission on the reduction of methane emissions in the energy sector. In addition, the present statement adds some partly technical notes to the draft regulation.

According to the DVGW, the share of methane emissions from the oil and gas industry (including extraction) in Germany-wide GHG emissions is 0.5 %. Grid operators have significantly reduced their methane emissions since 1990 thanks to the implementation of various emission reduction measures. German transmission system operators are determined to continue and intensify their contribution to reducing emissions.

We understand the need for a regulatory framework to reduce methane emissions and welcome the European Commission’s proposal. FNB will support the implementation of an appropriate and cost-effective action plan.

In recent years, a number of reports have been produced by the gas industry at the national and international levels highlighting the actions taken by gas system operators to reduce their methane emissions. The documents contain up-to-date data, facts and figures as well as concrete definitions and demonstrate the industry’s commitment to the path to climate neutrality.

To accelerate the transition process to carbon neutrality, it is critical to develop an abatement plan based on updated data. This will ensure that the transformation process is as effective and sustainable as possible.

The most important principles for a successful approach

  1. Maintain proportionality: Measures must not result in the imposition of costly measures on gas consumers that have little or no mitigation effect.
  2. Differentiated approach: not all measures to avoid methane emissions are equally suitable for all parts of the gas value chain (production, extraction, transport, storage, distribution, LNG). Fundamental flexibility is needed to prioritize actions and ensure that the optimal, cost-effective approach to mitigation is applied.
  3. Introduction of a transparent and robust MRV system (monitoring, reporting, validation): To enable consistent reporting and proper monitoring of reduction programs and measures, an MRV system aligned with the demanding OGMP 2.0 reporting standard should be implemented at the European level (applying the reporting framework, technical guidance documents and relevant concepts, definitions and requirements, such as materiality, representative sampling, etc. of the OGMP 2.0 program)
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TSOs present hydrogen report: This is what we need to successfully develop the hydrogen infrastructure

Germany must accelerate the ramp-up of hydrogen in order to secure supplies and promote climate protection. The hydrogen report submitted today by the transmission system operators in accordance with Section 28q of the German Energy Act (EnWG) shows how the necessary transport infrastructure can be built efficiently, quickly and in a targeted manner by integrating hydrogen network planning into the tried-and-tested gas network planning.

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Statement by FNB Gas on the determination of imputed useful lives of natural gas pipeline structures (“KANU”)

FNB Gas expressly welcomes the fact that the Federal Network Agency intends to create the possibility of reducing the useful lives of gas network investments or making them more flexible by means of the “KANU” definition put out for consultation.

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FNB Gas statement on the German government’s concept for implementing the 65 percent target for renewable energies in the installation of new heating systems as of 2024

FNB Gas welcomes early stakeholder engagement to design the implementation of the 65 percent renewable energy target for the installation of new heating systems beginning in 2024. Against the backdrop of the war in Ukraine, but also with a view to security of supply and ambitious climate protection targets, there is no time to lose now in driving forward the heat transition.

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National Hydrogen Council: Framework conditions for H2 transport and storage must be created this year

Since the publication of the National Hydrogen Strategy last year, the energy industry framework has changed fundamentally. This is what the National Hydrogen Council writes in a new key points paper. The existing high dependence of the German energy supply on fossil energy imports from Russia clearly shows the urgency of a sustainable diversification with regard to energy sources and suppliers. The importance of hydrogen has also increased once again as a result of the climate targets being brought forward.

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FNB Gas Statement on the introduction of level specifications for gas storage facilities

Excerpt: Text for the overview pages

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FNB Gas Position on the EU Hydrogen and Decarbonised Gas Market Package

The transmission system operators welcome in principle that the European Commission, within the framework of its proposals on common rules for the internal markets for renewable gases and natural gas as well as hydrogen, wants to create the mandatory and timely necessary regulatory framework for the ramp-up of the hydrogen market in the EU.

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Transformation of transmission networks: arteries of the climate-neutral future

“Gaseous CO2-free or CO2-neutral energy sources are an integral part of the energy transition.” This is the conclusion reached by the German Federal Ministry of Economics and Technology as a result of the “Dialogue Process Gas 2030”. energate spoke with Håvard Nymoen, Managing Director of Nymoen Strategieberatung, about what the commitment means for the gas industry and what steps will result from it.

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Call for cooperation for the initial preparation of the hydrogen report in accordance with Section 28q EnWG

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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Development of the future German hydrogen network within the framework of the hydrogen variant of the Gas NDP 2022-2032.

  • Invitation to further process participation until 31.01.2022
  • Extension of the possibility to report pipeline network infrastructures until 18.03.2022
  • Publication of the results of the call 05.10.2021
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Transmission system operators see private investment in hydrogen infrastructure development in jeopardy: new EU legislation must not create hurdles to decarbonization

  • Unbundling: All gas network operators should also be allowed to own and operate hydrogen networks
  • Regulation: Common rules for natural gas and hydrogen networks would enable synergies and economically efficient development of energy infrastructures
  • Methane emissions: EU regulation should lay foundations for harmonized recording
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Transmission system operators welcome the desire for a new departure in energy policy in the coalition agreement presented

The transmission system operators welcome the declared goal of the coalition partners to make hydrogen an essential building block of the energy transition and to initiate the necessary steps to this end. As announced in the coalition agreement, this includes creating the necessary framework conditions, including efficiently designed funding programs, for the committed development of the hydrogen infrastructure, as well as accelerating the planning and approval processes for faster realization of hydrogen networks. “We can fully endorse the coalition partners’ clear commitment to ‘electricity and hydrogen networks as the backbone of the energy system’,” makes Inga Posch, FNB Gas Managing Director, clear.

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First international agreement to significantly reduce methane emissions is a major step forward

  • Energy associations welcome pledge by over 100 nations to reduce methane emissions at Glasgow climate conference (COP26)
  • The gas industry is working continuously to effectively reduce its share of methane emissions through ongoing infrastructure upgrades
  • Improved and transparent measurement and detection methods are important basis for reduction measures
  • Methane emissions from the German gas industry have fallen by 40 percent since 1990
  • Where natural gas flows today, renewable and decarbonized gases can be used in the future
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European Commission’s consultations on the Hydrogen and Gas Markets Decarbonisation Package

Excerpt: Text for the overview pages

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Adoption of the climate protection report

Commenting on the adoption of the Climate Protection Report 2017 by the Federal Cabinet today, Wednesday, Ralph Bahke, Chairman of the Board of the Association of Transmission System Operators (FNB Gas) states:

“The German government is falling woefully short of the climate protection target it set itself for 2020 – the climate protection report adopted today is bad news for German energy and environmental policy.

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