FNB Gas on the paper “Methodology definition for efficiency comparison – status of the Federal Network Agency’s considerations”

With this statement, the FNB Gas is commenting on behalf of its members on the BNetzA’s paper “Method definition
Efficiency comparison – status of the Federal Network Agency’s considerations”.

The special features of the TSOs’ specific role in the system, which the TSOs describe in their statement on tenor number 1 of RAMEN and which affect the efficiency comparison, have not yet been taken into account, although the BNetzA has derived special rules for regulation for TSOs with a comparable market role (cf. key points for defining a regulatory framework for transmission system operators GBK-25-01-1#2). This urgently needs to be rectified.

The working paper published by the BNetzA on January 16 on the current status of its deliberations on the definition of the methodology contains no indication that the BNetzA has addressed the methodological weaknesses of the previous efficiency procedure. On the contrary, it is considering reducing measures that have so far made it possible to correct misjudgements that were caused by a partly method-inherent underspecification or misspecification of the models. In this paper, it thus also sends out signals that make it difficult or impossible for TSOs to acquire capital for the reliable operation, maintenance and selective expansion of the gas networks (see preliminary remarks in the statement on the tenor of RAMEN).

The position is available in the downloads.