Stakeholder comments on the BNetzA consultation about the regulatory framework for hydrogen networks

I dealt a lot with biomethane in September. It started more by chance. As part of a presentation, I argued that there is a future for biomethane as part of the energy transition, even though the present is a bit gloomy. But gas industry associations advocate for a better consideration of the contribution biomethane can make to a carbon-free energy system. After some twists and turns, the new Energy in Buildings Act contains improvements for the use of biomethane for heating. For Biomethane as a fuel, there is currently a special boom anyway. With regard to the planned revision of the Renewable Energies Act (EEG), on which the first draft bills were circulating, I had only remarked that it would not bring about any improvement.

I had sent the presentation to some representatives from the biomethane industry and got the feedback that I should take a closer look at the draft of the revised EEG. The concern was that it would make the framework for biomethane even worse. So I looked at the draft more closely and started to write the story. The main line of reasoning was that the cap of 225 MW/y for the annual biomass capacity that is tendered plus the new “south quota” will lead to a lower demand for biomethane in the CHP sector over the coming years. Only days later, the final draft of the cabinet was approved and the picture changed. The cap was lifted to 350 MW and some more improvements for biomass were included into the final draft. I had to rewrite the story in this issue – you might notice this, and I apologise. But this is the current fate of the sector. 

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TOPIC OF THE MONTH Stakeholder comments on the BNetzA consultation about the regulatory framework for hydrogen networks

In July, BNetzA launched a market consultation on the proper regulatory framework for hydrogen networks (ener|gate Gasmarkt 08- 09/20). Until September 4, stakeholders had the opportunity to submit comments on the status quo survey and to answer the detailed questionnaire the authority had published. BNetzA has not yet published the statements. However, a number of stakeholders have already published the statements or provided the usually extensive statements on request. ener|gate Gasmarkt has statements from the following associations:

- Bundesverband der Energie- und Wasserwirtschaft (BDEW)

- the main federation of the German energy industry

- Bundesverband der deutschen Industrie (BDI)

- the general industry federation

- Bundesverband neue Energiewirtschaft (bne)

- an association of independent suppliers and service providers for energy and renewables,

- Deutsche Umwelthilfe (DUH), an environmental lobbying group,

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Framework conditions

Renewable Energies Act (EEG) 2021

The process for a profound amendment of the Renewable Energies Act was kicked off. On September 14, the Ministry of Economics and Energy (BMWi) published a first draft for consultation. The associations had three (!) days to provide written comments. On September 23, the cabinet approved the final government draft. Now the Bundestag will deal with the amended law. The EEG is not really in the focus of this publication, but some aspects are important for gas (biomethane) and hydrogen (the not-so-new favourite of the author of this publication). In the market rumours section, it was mentioned that the derogation of the power for electrolysis from the EEG levy (at least from most of the burden) is to be stipulated in the “special compensation regulation (BesAR)” in the EEG. But work on the concrete wording is not yet finished. Within BMWi, the responsible staff members are still thinking about how to guarantee that only “green” power

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