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Specification BK8-24-020-A

FNB Gas on the draft of the “Determination of FSV higher utilization”

On 19.12.2024, Ruling Chamber 8 of the Federal Network Agency published a draft determination on the procedural regulation of costs pursuant to Section 49a and Section 49b EnWG (“Determination FSV Higher Utilization”, BK8-24-020-A) for consultation. 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:

FNB Gas welcomes the Federal Network Agency’s intention to specify the assumption of costs by transmission system operators (TSOs) in the event of electromagnetic interference. The use of procedural regulation in accordance with Section 11 (2) sentences 2 and 4 ARegV expands the catalog of permanently non-influenceable costs and thus creates the possibility of prompt reimbursement and recognition of the costs incurred.

However, it must be made clear in principle that all costs caused by the higher capacity utilization are fully reimbursed and allocated to the transmission grids in accordance with the principle of causation. The current FSV does not formulate this clearly.

The FNB therefore clearly reject the FSV in its current version. In accordance with the principle of causation, costs must be borne by the influencer – i.e. the TSO – until there is no more interference and no more protective and associated maintenance and repair measures are required. The provision in section “III. Cost reimbursement”, according to which regulated infrastructure managers are only reimbursed for costs if they cannot be rolled over themselves, is contrary to applicable law and blatantly violates the principle of fair causation. The demands placed on the electricity transmission grid as a result of the energy transition must not be at the expense of gas grid customers.

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Statement “Determination of FSV higher utilization”
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