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.
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FNB Gas welcomes the BMWE’s draft bill to amend the Energy Industry Act and other energy legislation to implement the European Gas and Hydrogen Single Market Package as a decisive step towards transforming the gas market into a climate-neutral energy system. Hydrogen plays a key role in this – for security of supply, resilience and the decarbonization of entire industries.
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The Economic and Energy Committee in the Bundestag is holding an expert hearing on the Hydrogen Acceleration Act today. Our Managing Director Barbara Fischer presents the perspective of the transmission system operators and shows how we can really pick up the pace.
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FNB Gas welcomes the BNetzA’s approach of using the KOSMO draft specification to provide early clarity on the design of the charging system for the hydrogen core network, even if the planned product differentiation has not yet taken place.
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FNB Gas welcomes the Federal Government’s cabinet resolution on the Hydrogen Acceleration Act of October 1, 2025. However, the transmission system operators also see a need for targeted adjustments in order to effectively accelerate the development of the hydrogen core network.
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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.
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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.
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On August 6, the German government launched the draft bill for an amendment to the Energy Industry Act. Consultations are currently taking place in the German Bundestag. Among other things, this concerns the acceleration of planning and approval procedures in the context of grid expansion. FNB Gas supports the planned amendment to the Energy Industry Act to speed up planning and approval procedures, but points out the need for further improvement.
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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.
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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.
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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:
Continue reading → 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.
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On behalf of its members, FNB Gas has submitted a statement on the “Draft Fourth Act to Amend the Energy Industry Act”.
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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).
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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.
Continue reading → With this statement, FNB Gas comments on individual points of the draft GasNEF determination.
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TSOs welcome legislative will to speed up planning and approval procedures
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TSOs welcome legislative will to speed up planning and approval procedures
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The European Commission wants to revise the legal framework for energy networks – an important step towards establishing an integrated European energy system.
Continue reading → 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.
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FNB Gas welcomes the fact that the Federal Network Agency is taking important steps with the current consultations on the ramp-up tariff for the hydrogen core network and on the key issues paper to supplement the WANDA regulation in order to clarify central questions regarding the design of the tariff system for the hydrogen core network.
In their statement on the ramp-up tariff, the transmission system operators support the methodology and assumptions of the underlying expert opinion and consider the proposed tariff of €25.00/kWh/h/a to be necessary in order to ensure the full refinancing of the hydrogen core network by 2055. However, in view of the uncertainties surrounding the market ramp-up, they emphasize the importance of a regular review and dynamic adjustment of the tariff. Anchor customers from industry and power generation as well as targeted funding instruments are crucial to ensure a successful market ramp-up.
The consultation on the definition of WANDA is also an important building block for the further development of the regulatory framework. The differentiated product design envisaged therein creates a basis for pricing that is fair to the source and efficient network use. At the same time, it must be ensured that discounts and multipliers do not jeopardize the refinancing of the hydrogen core network.
Both consultations are closely related and must therefore also be considered in conjunction with each other. The interaction of multipliers and discounts must therefore also be taken into account when determining the ramp-up tariff in order to avoid a structural deficit in the amortization account.
The statements are available in the download area.
Continue reading → 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.
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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.
Continue reading → 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.
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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.
Continue reading → Ruling Chamber 9 of the Federal Network Agency will consult on the specifications from 13.12.2024 to 13.02.2025:
and from 29.01. to 13.02.2025 for determination:
was carried out. FNB Gas participated in this process by submitting comments on behalf of its members:
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FNB Gas supports the objective formulated in the SES 2024 to better coordinate individual planning processes and comprehensively drive forward the transformation in Germany. The strategy is an important step towards integrated energy infrastructure planning. A successful transformation of the energy system requires a cross-sector strategy that takes into account the ramp-up of the hydrogen economy and the further development of the gas grids.
Continue reading → As many transmission system operators are affected by electromagnetic interference as a result of increased utilization of the electricity grids, FNB Gas e.V. has commented on the draft specification on behalf of its member companies as follows:
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With today’s vote of confidence in the German Bundestag, Chancellor Scholz has paved the way for early elections on February 23, 2025. It is therefore clear that the elections to the German Bundestag on February 23, 2025 will also provide an opportunity to set the course for a secure, affordable and climate-neutral energy future.
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FNB Gas welcomes the German government’s “Import Strategy for Hydrogen and Hydrogen Derivatives” (July 2024) on this fundamental aspect of the hydrogen ramp-up. It will not be possible to meet the demand for hydrogen in Germany without imports. In this respect, the import strategy contains many important aspects that we as an association support.
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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.
Continue reading → In our statement, we support the position of the German Association of Energy and Water Industries (BDEW) and also make points that reflect the special features of natural gas grids.
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As part of the hearing on the Hydrogen Acceleration Act (WassBG) in the Committee for Climate Protection and Energy in the German Bundestag, Barbara Fischer, Managing Director of FNB Gas, emphasized the importance of acceleration measures for the rapid development of the hydrogen infrastructure.
Continue reading → FNB Gas welcomes the efforts made by politicians as part of the 2024 EnWG amendment to strengthen the secure operation of the electricity transmission grid and security of supply.
The amendments, particularly in Section 49a EnWG, provide clear regulations on the reimbursement of costs for protection and security measures in the event of increased network capacity utilization.
The TSOs criticize the fact that their role in the redesign of the regulatory system has not yet been sufficiently taken into account. They are calling for all aspects of the NEST process to be considered in context and brought together in a coherent overall concept.
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The hydrogen market design is taking shape: In their statement, the transmission system operators expressly welcome the Federal Network Agency’s (BNetzA) move to establish a basic model for grid access and the balancing model at an early stage.
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The TSOs believe that the main objective of this regulation, to ensure the complete refinancing of gas grid investments and to enable flexibility, has been implemented in principle in the draft.
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”).
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Tomorrow, the Bundestag will discuss the Hydrogen Acceleration Act (WassBG) at first reading. The law is crucial for the start and success of the hydrogen economy, because without infrastructure, an essential foundation for the hydrogen market is missing.
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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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The TSOs expressly welcome and support the BNetzA’s approach of creating the necessary regulatory provisions for implementing the financing model of the EnWG draft for the hydrogen core network with the WANDA specification at this point in time.
Continue reading → 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.
Continue reading → 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).
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For the goal of greenhouse gas neutrality by 2045 and the transformation of the energy system by then, gaseous energy sources are the second main pillar of the energy supply alongside renewable electricity generation. In order to achieve the climate targets, the transformation of the entire gas supply and thus the entire gas infrastructure to climate-neutral gases must therefore be made possible.
Continue reading → 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.
Continue reading → The aim of this regulation must be to ensure the complete refinancing of gas grid investments and to allow sufficient flexibility to allow the imputed useful lives to end before 2045.
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For the transmission system operators, the transformation of the infrastructure has already begun with the planning of the hydrogen core network. In regulatory terms, their implementation will be in full swing by the middle of the 4th regulatory period and the next base year (2025).
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In order not to jeopardize the success of core network planning to date, a few decisive changes to the draft legislation are necessary from an investor’s perspective. The main aim is to improve the risk assessment for investors.
Continue reading → 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.
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The financing framework already contains many good and important elements. However, as future core network operators, the transmission system operators consider a few but decisive changes to the proposed regulatory framework to be necessary in order to ensure capital market viability
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