Statement of the FNB Gas on the Green Paper Transformation Gas/Hydrogen Distribution Networks of the BMWK

The FNB Gas welcomes the BMWK consultation of 14.03.2024 on the “Green Paper Transformation Gas/Hydrogen Distribution Networks”. The aforementioned challenges of transforming the distribution networks to renewable gases while maintaining the security of supply and affordability of the energy supply in general, and in the natural gas sector in particular, affect not only the distribution networks but also the transmission networks.

For the goal of greenhouse gas neutrality by 2045 and the transformation of the energy system by then, gaseous energy sources are the second main pillar of the energy supply alongside renewable electricity generation. In order to achieve the climate targets, the transformation of the entire gas supply and thus the entire gas infrastructure to climate-neutral gases must therefore be made possible. At the same time, security of supply as part of the provision of natural gas to the public must not be jeopardized under any circumstances, particularly during the transformation phase.

It should be noted at the outset that many of the areas of action addressed in the Green Paper are still subject to considerable uncertainty. As important as it is to deal with issues such as decommissioning or even dismantling at an early stage and therefore with legal certainty, the focus should initially be on the appropriate transformation planning of the distribution grids and their interlinking with the integrated grid planning of the transmission system operators in order to reduce these uncertainties for all stakeholders involved.

The core topics of the Green Paper derived from this, esp. Connection obligations, decommissioning and transformation planning, dismantling obligations and integrated or coordinated grid planning are also key issues in grid transformation at transmission grid level. Accordingly, the points discussed here should also be considered for the transmission grids. The regulations to be made in this context will probably be partially identical for all gas grids, but may also differ due to the different requirements for transmission grids and distribution grids. For this reason, the transmission system operators should definitely be involved in the dialog on these important issues that has now begun.

Our complete statement is available in the downloads.