Resort: Security of Supply

FNB Gas expressly welcomes the federal government’s plans to establish a gas reserve as a key instrument for crisis preparedness. It ensures that, in crisis situations—such as the failure of a major import pipeline—infrastructure operators can maintain grid stability at short notice and transition to crisis mode in a controlled manner. We view the reintroduction of a levy to finance the gas reserve critically and consider it inappropriate. Government crisis preparedness should also be financed by the government.

FNB Gas expressly welcomes the planned extension of the “VOLKER” regulation by the Federal Network Agency. This regulation has played a key role in enabling the transport of odorized gas from France to Germany without increasing the liability risk for network operators, thereby making an important contribution to security of supply.

FNB Gas generally welcomes the Federal Network Agency’s initiative to prepare a national efficiency comparison for transmission system operators in the fifth regulatory period. At the same time, the TSOs point out that both European and national efficiency comparisons are only suitable to a limited extent for deriving reliable and appropriate efficiency targets in view of the increasing structural differences and the ongoing transformation of the networks.

On behalf of its members, FNB Gas fully welcomes the provisions of the “MARGIT 2027” draft regulation, in particular the unchanged determination of the multipliers, which increases planning certainty for all market participants and provides incentives for long-term capacity bookings.

FNB Gas welcomes the Federal Network Agency’s draft specification on the publication modalities in accordance with the Gas Directive as an important step towards greater transparency and clarity.

FNB Gas welcomes the Federal Network Agency’s draft regulationon the publication modalities in accordance with the Gas Regulation as an important step towards greater transparency and clarity.

FNB Gas welcomes the draft legislation to implement the NIS 2 Directive (NIS2UmsuCG) and to strengthen the resilience of critical facilities (KRITIS-DachG), but points out the need for adjustments to ensure security of supply and data security.

FNB Gas thanks for the opportunity to comment on the EU Energy Security Framework and points out the need for tailor-made models for the individual Member States.

FNB Gas welcomes the efforts to create a national transparency platform within the framework of the stipulation on the publication of energy market data for disclosure and information in accordance with Section 111g EnWG (HEDWIG), but refers to the once-only principle to avoid multiple data collection and advocates the consistent use of existing data sources.

FNB Gas welcomes in principle the draft bill of the Federal Ministry of the Interior for the implementation of Directive (EU) 2022/2557 and to strengthen the resilience of critical facilities (KRITIS-DachG) of August 27, 2025 as an important step towards a uniform federal legal framework to increase the analogous protection and resilience of critical infrastructures.

On behalf of its members, FNB Gas has submitted a statement on the “Draft Fourth Act to Amend the Energy Industry Act”.

FNB Gas welcomes the draft amendment of the Energy Industry Act to strengthen consumer protection in the energy sector, to amend other energy law provisions and to harmonise the legal form of the Energy Industry Act.

FNB Gas proposes amendments to some of the regulatory content due to the impact on its members.

The position is available in the downloads.

FNB Gas welcomes the Federal Ministry of Economics and Climate Action’s draft bill on the Regulation on the Adjustment of the Filling Level Specifications for Gas Storage Facilities (GasSpFüllstV) of 28.04.2025 as an important step towards a market-oriented and at the same time secure gas supply.

According to the transmission system operators, the draft legislation is suitable for maintaining security of supply under the current framework conditions and at the same time gradually handing responsibility back to the market. The proposed time frame and the regional differentiation of the filling level requirements will enable preparation for the coming winter. The still important function of pore storage facilities is only partially taken into account in the draft, but their high capacity and withdrawal rate remain central to security of supply.

Overall, the draft sends a clear signal for the priority of market-based storage filling and lays the foundation for rapid refilling in the winter of 2025.

The statement is available in the downloads.

FNB Gas is grateful for the opportunity to comment on the planned Power Plant Safety Act (KWSG), which was presented by the Federal Government as part of the growth package for the economy. The two consultation documents of the Federal Ministry of Economics and Climate Protection (BMWK) on the promotion of hydrogen-capable gas-fired power plants and controllable capacities provide an important impetus for the implementation of Germany’s climate targets.

FNB Gas welcomes the opportunity to comment on the consultation launched on June 24, 2024 to determine the amendment to resolution BK9-18/608 of 23.03.2019 regarding the requirements for the conversion of annual performance prices into performance prices for capacity rights during the year and requirements for the appropriate determination of network tariffs pursuant to Section 15 para. 2 to 7 GasNEV (BEATE 2.0.) and for the repeal of resolution BK9-20/608 of 16.10.2020 (“BEATE 2.1”).

The transmission system operators (TSOs) thank you for the opportunity to comment on an extension of the determination of volatile costs for various aspects of natural gas transportation (“VOLKER” – Ref. Bund BK9-22/606-1).

FNB Gas welcomes the opportunity to comment in the consultation launched on March 12, 2024 to determine the calculation of multipliers, discounts for interruptible capacities, discounts at LNG terminals and seasonal factors.

In principle, FNB Gas welcomes the draft bill of the Federal Ministry of the Interior and Homeland for the implementation of Directive (EU) 2022/2557 and to strengthen the resilience of operators of critical facilities (KRITIS-DachG) of December 21, 2023 as an important step towards a uniform federal legal framework to increase the analogous protection and resilience of critical infrastructures.

The past year and a half has brought to light that the protection of Critical Infrastructure (CIP), especially gas infrastructure, is essential for maintaining economic and social life as well as national security.

In principle, FNB Gas supports the proposal of the Federal Ministry of the Interior and for Home Affairs regarding the draft law on the implementation of the CER Directive and on strengthening the resilience of critical facilities (KRITIS-Dachgesetz – KRITIS-DachG).

In accordance with the requirements of Section 78 para. 1 No. 1 in conjunction with. § 79 para. 1 No. 1 TKG, transmission system operators (TSOs) are required to provide data on the telecommunications structure they operate to the Federal Network Agency’s (BNetzA) Central Information Service (CIS). This data is then published in the Infrastructure Atlas (ISA).

The TSO Gas considers it necessary to avoid the publication of sensitive infrastructure data, which exposes Germany’s critical infrastructure to unnecessary risks, or at least to be more sparing with the publication of such data, unless there is an overriding public interest in the publication of such data.

A corresponding provision could be made by exempting the aforementioned critical infrastructures from the publication requirement under the TKG by reference in the KRITIS-DachG.

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