Artikelart: Position

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.