Statement of the FNB Gas on the H2 Regulation

The transmission system operators submitted comments on the draft ordinance on costs and charges for access to hydrogen networks as part of the associations’ consultation process.

In their statement, the TSOs welcome the attempt to launch the principles of network charging methods for the future regulated operators of hydrogen networks before the end of this legislative period. The regulation is an important (although not the only) basis for the entrepreneurial decision of network operators on the so-called “opt-in” into regulation pursuant to § 28j para. 3 EnWG. Parameters of the regulation, such as the level of the EC interest rate or the depreciation periods/useful lives, are central here. In addition, H2NEV will also have a special significance in the context of public funding (e.g. IPCEI).

In view of the fact that the network operators are entering new territory in the development of the H2 infrastructure and that there are numerous revenue shortfall, operator and fundamental regulatory risks, the TSOs have determined a value of at least 9.25% (before corporation tax, after trade tax) as a risk-appropriate rate of return. This value is also supported by an expert opinion commissioned by FNB Gas from NERA. In addition, the TSOs urge an appropriate period of validity for this H2 EC rate.

The FNB expressly welcomes the provision to make the useful lives more flexible.