Resort: Energy Future

FNB Gas, together with national and international industry and trade associations, has signed an appeal to the European Commission calling for a practical revision of the production criteria for renewable hydrogen. The goal is to remove regulatory barriers, facilitate investment, and create better framework conditions for the ramp-up of hydrogen in Germany and Europe.

FNB Gas, together with other associations, has signed an appeal to the German Bundestag calling for hydrogen CfDs to be included in the 2027 federal budget under a separate budget line item.

Transmission system operators welcome the retention of the existing transmission network tariff structure. The current tariff system has proven its worth in the market and ensures planning certainty and reliable framework conditions for all market participants.

FNB Gas expressly welcomes the Federal Network Agency’s initiation of the “KONNI 2.1” determination procedure. The analysis by Trading Hub Europe GmbH (THE) confirms that, while the measures taken to date to curb conspicuous market behavior were appropriate and necessary, they alone are not sufficient to counteract high conversion costs in a sustainable and efficient manner.

The grid connection package is intended to expedite grid connection procedures and ensure that scarce grid connection capacity is prioritized more transparently and efficiently in the future. FNB Gas welcomes this goal but sees a need for further measures: The construction of the core hydrogen network should be explicitly included in the Energy Industry Act as a prioritization criterion for grid connection requests.

The proposed amendment to the 2025 Land Use Development Plan (FEP) sets the course for future offshore hydrogen production in Germany. FNB Gas advocates for the retention of the “Other Energy Production Area” (SEN-1), as it is of central importance as the first specifically designated entry point for offshore hydrogen in Germany’s Exclusive Economic Zone (EEZ).

FNB Gas welcomes the draft regulation in the “BRÜCKEN” procedure as an important step towards greater planning certainty in dealing with provisions for the decommissioning and dismantling of gas network infrastructure. In particular, it is noted positively that the draft avoids the hasty introduction of incentive mechanisms based on provisions and that no system adjustments will be made for the fourth regulatory period. The existing regulatory framework should remain unchanged for gas network operators that have already established provisions prior to 2025—particularly in the base year 2020.

FNB Gas welcomes the Federal Network Agency’s approach of considering additions to and reversals of provisions for the decommissioning and unavoidable dismantling of gas network infrastructure as cost shares outside the efficiency comparison (KAnEu) from the fifth regulatory period onwards.

On behalf of its members, FNB Gas comments on the following current determination procedures of the Enlarged Ruling Chamber for Energy (GBK) of the Federal Network Agency:

The working paper published by the BNetzA on January 16 on the current status of its deliberations on defining the methodology contains no indication that the BNetzA has addressed the methodological weaknesses of the previous efficiency procedure.

The TSOs welcome the draft determination of Decision Chamber 9 regarding the non-application of discounts for renewable and low-carbon gas at storage points and interconnection points between Member States (interconnection points).

The EU Agency for the Cooperation of Energy Regulators (ACER) carried out a consultation on the efficiency comparison for transmission system operators on July 17.

With this statement, FNB Gas comments on individual points of the draft GasNEF determination.

FNB Gas welcomes the Federal Network Agency’s (BNetzA) consideration of an exemption for price discounts at storage and cross-border interconnection points for the injection and withdrawal of renewable or low-carbon gases in accordance with Art. 18 Gas Regulation.

The German transmission system operators are once again actively participating in the Federal Network Agency’s second consultation on the “WaKandA” and “WasABi” specifications with their own positions.

The TSOs welcome the so-called N.E.S.T. process for the further development of the regulatory system. However, the BNetzA’s considerations submitted for consultation are not yet sufficient to make the regulatory framework fit for the challenges of the transformation.