Statement on the EnWG amendment

FNB Gas welcomes the German government’s initiative to create the conditions for the hydrogen core network with the amendment to the EnWG

As part of the adaptation of energy law to EU requirements, the BMWK also intends to make changes to the EnWG to supplement the regulatory regime for hydrogen as an energy carrier. The goal of the new regulations is to rapidly ramp up the hydrogen market to ensure decarbonization, particularly in the highest greenhouse gas emitting sectors of the economy where more energy and cost efficient alternatives to hydrogen are not available.

The TSOs welcome the German government’s initiative to now lay the regulatory, antitrust and network planning foundations for the development of an efficient and expandable hydrogen core network. The regulations are a key step in the development of a Germany-wide hydrogen infrastructure, which should provide market participants with planning and investment security.

The draft bill provides a clear political mandate for the TSOs to develop the supra-regional hydrogen core network, taking into account other infrastructure operators and other infrastructure suitable for transporting hydrogen (at the transmission level) safely. The TSOs have the necessary expertise and are guarantors for the fastest possible development of the German hydrogen network from mainly convertible lines and in the existing private-sector structures.

The German government’s amendment to the Energy Industry Act (EnWG) creates the conditions under antitrust law and planning law for planning the hydrogen core network. For their part, the FNB will do everything in its power to ensure that implementation can begin this year.

However, the draft bill leaves open and unresolved issues such as the financing of the hydrogen core network, which are crucial for the realization of the investments. The corresponding solutions must be developed promptly and introduced into the legislative process in order to ensure the necessary investment security.

The FNB sees a solution to the refinancing problem essentially based on the concept of advance financing of the hydrogen core network by the FNB combined with state risk insurance in the event of failure of the hydrogen ramp-up, which the German Energy Agency (Dena) had already proposed in the summer of 2022. In addition to the dena model, it would be possible to flank the mechanism with a levy or financial transfers from the natural gas system, as is also envisaged in the amendment to the EU gas market package currently being negotiated.

The complete statement of FNB Gas is available in the downloads.


FNB Gas STN EnWG Amendment H2 core network
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