FNB Gas on the “KOMET” Draft Regulation

FNB Gas fully endorses the statement issued by the German Association of Energy and Water Industries (BDEW). In addition, FNB Gas would like to highlight the following points:

In our view, the proposed limitation to the fourth regulatory period anticipates future developments beyond the base year 2025 that are currently neither foreseeable nor quantifiable. This is because, even in the fifth regulatory period, the costs of implementing the requirements of the Methane Ordinance may fluctuate relative to the base year of 2025.

Even if, as the Decision-Making Chamber explains in paragraph 26, a steady state is expected to be reached by the fifth regulatory period, this steady state is unlikely to have been achieved to the same extent by all network operators by 2025. The corresponding costs may therefore be partially excluded from the base year 2025 and will not be subject to regulation until the fifth regulatory period.

The final assessment of how these costs should be classified beyond the fourth regulatory period should be based on an evaluation of trends in the relevant cost data. Furthermore, any adverse effects on the efficiency comparison that might result solely from the objectively necessary, time-varying implementation of the Methane Regulation must be ruled out.

Our statement is available in the downloads.