Storage Level Law

FNB Gas Statement on the introduction of level specifications for gas storage facilities

The current geopolitical situation poses major new challenges for the German energy industry. Transmission system operators (TSOs) look on Russia’s war against Ukraine with dismay.

It is right and important to make provisions for next winter’s gas supply in the current situation. We can understand the political intentions to fill the German underground storage facilities as completely and securely as possible. The reservoir level law can make a decisive contribution to this.

However, the proposed legislation gives rise to significant financing risks for the market area manager Trading Hub Europe (THE). These must be secured by the federal government. Even if the costs are ultimately to be counter-financed via a levy, the additional financial burden on gas customers (households and industry) and THE’s liquidity situation must remain within a calculable and also sustainable framework.

The TSOs expressly welcome the planned evaluation of the law. The political situation is associated with considerable uncertainties. In addition, no one can currently predict how the proposed regulations will affect the gas market and the behavior of the individual players, and what specific financial obligations will arise for THE as a result. The evaluation should look particularly at whether the goal desired by procuring the strategic options – to achieve high storage levels – will also be achieved at a reasonable cost, or whether THE will need to procure a significant amount of gas. It is also important that in future traders and gas suppliers will also be obliged to store at least part of their portfolio for the winter so that they can continue to supply their customers in the event of supply shortfalls in the winter.


FNB Gas Statement Storage Act
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