Energy Industry Act

Statement of FNB Gas on the Federal Government’s draft bill on the third law to amend the EnWG (additions to regulations on financing the hydrogen core network)

FNB Gas welcomes the submission of a draft bill for a legal and regulatory framework for financing the hydrogen core network.

First of all, the transmission system operators support the German government’s fundamental decision to realize the development of the hydrogen infrastructure via private-sector investors. The transmission system operators have been planning the hydrogen core network over the past weeks and months and could start implementing the core network once approval has been granted by the Federal Network Agency. The prerequisite remains the legal anchoring of a financing model suitable for the capital market.

The draft regulation contains numerous financing elements that are positive:

  • Introduction of an intertemporal cost allocation mechanism
  • Determination of a uniform nationwide ramp-up fee that can be dynamically adjusted to market developments (revision mechanism)
  • Creation of an amortization account in which the shortfalls and surpluses of the hydrogen core network are booked and earn interest
  • Interim financing of the amortization account by an account-holding agency to be commissioned by the federal government
  • Settlement of the amortization account by the state in 2055

The TSOs are prepared to bear an appropriate risk with regard to the financing of the core network. Against the background of a hydrogen market that does not yet exist and a new technology being used, these risks are considerable for the network operators. In addition, the core grid was planned on the basis of political scenarios and it is exclusively in the hands of politicians and not the grid operators to promote a market ramp-up through political framework conditions and thus lead to success.

However, many questions remain unanswered or are to be settled by the Federal Network Agency. The TSOs have always emphasized that the legal anchoring of a financing model suitable for the capital market is a prerequisite for the rapid implementation of the core network. Ultimately, a final assessment of capital market eligibility by the investors can only be made in the knowledge of the interplay between statutory regulations, determinations by the Federal Network Agency and contractual regulations with the account-holding government agency, among others.

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


FNB Gas STN EnWG Amendment Financing H2 core network
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