We organise the gas transport. With a length of approximately 40,000 km, the German transmission networks form the backbone of the gas transport system in Germany.
Large quantities of gas are transported at high pressures of up to 100 bar through the pipes of the transmission system operators, which have diameters of up to 140 centimetres. Added to this is the transit of natural gas through Germany to neighbouring EU states. Compressor stations at intervals of between 100 and 200 kilometres ensure that the pressure remains stable over these long distances. Transmission system operators receive the gas at an entry point at the German border. This could be, for example, a border crossing point (BCP) on the border between Germany and Poland or the Netherlands. From there, the gas is fed into the German transport network and transported through underground pipelines to the respective region where it is needed.
For historical reasons, the structure of the German gas transport network differs from other European transport networks. The networks were not primarily organised by the state, but have grown together over many decades on a regional private-sector basis. While 16 transmission system operators currently organise gas transport in Germany, there are seven in Austria, two in France, and only one each in the Netherlands and the UK.
The legal framework for gas transport is provided by the EnWG and a number of ordinances
Transmission system operators shall grant non-discriminatory access to their transmission systems to all gas suppliers. Thereby, they create the conditions for functioning competition in German gas trading. With the second amendment to the Energy Industry Act (EnWG), the model of regulated grid access came into force in 2005. Network access is regulated by the cooperation agreements of the German gas suppliers (KoV) and the terms and conditions of the transmission system operators. In addition to the EnWG, the legal framework is provided by the Gas Network Access Ordinance (GasNZV) and the Gas Network Charges Ordinance (GasNEV).
Access to the transmission system is organised via the “entry-exit model”. The system operates in Germany based on the merging of the supply areas of several transmission system operators into one market area. Gas suppliers conclude contracts with the respective entry and exit network operators in which the respective capacities at the entry and exit points are specified. This automatically provides a virtual trading point. There, gas quantities can be transferred or taken over virtually. A fee is charged for both feeding in and withdrawing gas. Since there is no physical path underlying the feed-in and withdrawal, the charge is independent of the transport path and distance. Only the energy quantity of the contractually agreed entry and exit capacities counts.
The basis for the network charges for gas transmission is the individual revenue caps for transmission system operators set by the BNetzA as part of incentive regulation. In the revenue cap, the BNetzA recognises those costs which the network operator incurs to fulfill its statutory tasks. These costs are included in an efficiency comparison and are the starting point for determining the appropriate revenues.
A large number of the regulatory provisions applicable in Germany have their origin at the European level. In 2009, the third internal energy market package to “accelerate the liberalisation of the gas market” brought fundamental changes for the gas industry through the separation of network operation from the other stages of the value chain (generation, trading, and sales), the so-called “unbundling”. In addition, a reorganisation of the conditions for access to the natural gas transmission networks (Natural Gas Access Regulation: Regulation 715/2009) was initiated by instructing the European Commission to issue binding network codes. The network codes set technical rules for non-discriminatory network access and for strengthening the European internal market. In addition, an “association” of the European transmission system operators ENTSOG (European network of transmission system operators for gas) was established. ENTSOG’s task is to monitor the implementation of the network codes and to prepare a European Ten-Year Network Development Plan (TYNDP).
The next gas market package is already around the corner. In 2021 the European Commission proposed adaptation of the legal regulations for the gas market against the backdrop of the challenges of the energy transition and climate protection.
