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www.bundesnetzagentur.de
Role and structure of the German regulatory authorities
and the role of BNetzA in implementing the “Energiewende“
Workshop Germany – Brasil
University of Campinas, March – 13th 2013
Dr. Annegret Groebel, BNetzA
Head of Department International Relations / Postal Regulation
© Bundesnetzagentur
Agenda
1. Presentation of BNetzA – the German regulator
2. Energy regulation in Germany
3. German energy policy – the „Energiewende“
4. New competencies for BNetzA – synergies
5. Network Development Plan 2012:
a) Consultation launched
b) Grid expansion approved and submitted
6. Challenges and Next Steps
7. Conclusions
© Bundesnetzagentur
Introductory Remarks
In Germany:
Network industries traditionally were (legal) monopolies mostly owned by the state or
regional municipalities or at least enterprises under huge state influence.
Deficits resulting from the monopolistic structures led to the desire for more dynamics,
higher efficiency and lower prices.
Process of liberalisation was initiated by the European directives in order to open up
markets for competition while the state influence was restricted to regulation in order to
guarantee and safeguard competition.
Process of legal market opening (liberalisation) will not work without economic
regulation to ensure new entrants (competitors) can make use of new possibilities and
compete effectively: (ex ante) regulation guarantees a level playing field!
For effective regulation the NRA needs to be independent
Independence is increased in the case of a multi-sector regulator
© Bundesnetzagentur
Overall Mission of Bundesnetzagentur…
… to promote sustainable competition in the markets for electricity, gas,
telecommunications, postal services and railways...
…via regulating these markets, i.e. market regulation by a regulatory body with
ex-ante powers (to impose sector specific obligations)
administrative body whose decisions are administrative acts
(subject to juridical control)
no micromanagement of markets, but pro-competitive regulation: setting
conditions by implementing the rules and giving price signals in order to steer
market forces towards a competitive market development as competition is the
best driver for efficient investment and delivering benefits to consumers (more
choice and more value for money)
© Bundesnetzagentur 5
Bundesnetzagentur: the German National Regulatory Authority
Independent higher federal authority in the scope of the Federal Ministry of Economics and Technology
Sector-specific regulatory authority tasked with
ensuring effective competition in network industries:
Telecommunications and Posts (since 1998),
Electricity and Gas (since 2005), and
Railways (since 2006)
Electricity and Gas network planning (since 2011)
BNetzA employs ar. 190 staff in energy regulation,
up to 240 staff will be recruited for Electricity and Gas
network planning
Overall headcount for all sectors: ar. 2600 staff
HQ in Bonn
© Bundesnetzagentur
Organisation Chart BNetzA (1a)
© Bundesnetzagentur
Organisation Chart (1b)
President
Vice President Vice President
Management
Office
President's
Chamber (Ruling Chamber 1)
Ruling Chambers
2
3
4
5
6
7
8
9
Information
Technology and
Security
Human Resource
& Accounting
Department
Regional Offices of BNetzA
Department for
International
Relations & Postal
Regulation
Department for
Energy Regulation
Department for
Railway Regulation
Department for
Economic
Regulation Telecoms
incl. numbering
Department for Legal
Telecoms
Regulation,
Frequency Manage.
Department for
Technical Telecoms
Regulation incl.
standadization
Department for Grid
Planning (NABEG)
© Bundesnetzagentur
Ruling Chamber 6
Access Electricity Grids
Ruling Chamber 7
Access Gas Networks
Ruling Chamber 9
Grid charges,
gas
Ruling Chamber 8
Grid charges,
electricity
601
Economic Policy Issues
607
Gas Distribution Network Access
602
Incentive Regulation, Benchmarking
608
Electricity Transmission Network Access
603
Monitoring
609
Gas Transmission Network Access
604
Unbundling
610
Grid Charges, Electricity
605
Duties un. the Renewable Sources Act
611
Grid Charges, Gas
606
Electricity Distribution Network Access
612
Cooperation with State authorities
Department 6
Energy Regulation
Ruling Chamber 4
Investment Measures
Organisation of energy regulation inside BNetzA (1c)
613
Grid Development
© Bundesnetzagentur
Organisation Chart (2) – Internal Governance
BNetzA headed by President and two Vice-Presidents
nominated by government upon proposal of Advisory Council appointed by the President of Germany besides their responsibility to govern BNetzA, President and Vice-Presidents form the so-called
“President’s chamber”, a ruling chamber with legally defined competences with regard to market definition and analysis and frequency management
Advisory Council
members of Upper House of Parliament & Lower House of Parliament (democratic control)
advise BNetzA on various issues
Ruling Chambers
key regulatory decisions executed by Ruling Chambers
one chairperson and two vice chairs
clear rules for ruling chamber proceedings
• hearings and oral proceedings
• participation in proceedings
• investigation rights
independent rulings and strict administrative procedures
Short timelines and decision stays effective when challenged in court
Departments:
Economic, Legal and Technical Department for telecommunications, departments for each of the other sectors, plus HR/accounting and IT department for all five sectors (synergies) as well as litigation office and press office responsible for all sectors
© Bundesnetzagentur
An Independent Regulator?
What does “independent” mean?
no influence by market players (no regulatory capture)
no influence on daily business by ministry (no overruling)
Regulator has to be impartial, i.e. take neutral decisions
Problem: how to guarantee it?
clear separation of functions
rules that clearly define the roles / competencies
clear assignment of powers (incl. enforcement)
institutional set-up (organisational structure / governance rules)
© Bundesnetzagentur
An Independent Regulator !
BNetzA is a higher federal authority in the scope of business of (but separate from) the Ministry of Economics and Technology
Institutional set-up and rules, transparency:
consultations
oral hearings
publication of docs
Ruling chambers’ decisions independent (consistency requirement), no overruling by Ministry
No control at all?
Ministry can give (general) directives, but they have to be published
BNetzA decisions subject to juridical review by independent courts
Democratic oversight via the Advisory Council and accountability rules
© Bundesnetzagentur
Accountability
Activity Report on status and development of telecoms and postal sector as
well as for energy and railway sector to be submitted to the legislative bodies of
Germany every two years ensures accountability
Principles of administration to be published at regular intervals
(transparency and predictability)
Report of the Monopolies Commission to be submitted every two years to
report whether there is effective competition in the telecoms + postal markets as
well as in the energy and the railway markets (assessment of whether objectives
have been reached)
© Bundesnetzagentur
Multi-sector regulation (1)
General Advantages of a multi-sector approach:
Regulatory capture can be avoided.
Regulator can take its decisions based on a wider perspective.
Broad expertise strengthens the regulator’s role as professional policy adviser.
Multi-sector competences strengthen the regulator’s independence.
Different levels of regulatory powers are levelled up to the strictest one!
Advantages both in terms of professional decision-making as well as in
organisational terms: realizing synergies and saving administrative costs
© Bundesnetzagentur
Multi-sector regulation (2)
Advantages with regard to regulatory decisions
Reflection of market realities
Networks are increasingly
converging.
Struggling over
competences between
different authorities can be
avoided.
Synergies
Similar questions arise in all
sectors.
Broad expertise can be used
and shared/transferred.
Expertise and experiences
from other sectors can easily
pour in regulatory decisions.
Regulatory Consistency
Close co-operation of
experts from different
sectors allows consistent
regulatory approaches and
measures.
© Bundesnetzagentur
Synergies (1)
BNetzA‘s competence to regulate different infrastructure based sectors (network
industries) allows for the creation of synergies and a broad discussion of regulatory
issues as problems and tools to solve them are the same: pro-competitive market
regulation that needs to be enforced with ex-ante access and price regulation
Examples:
• BNetzA’s telecommunications and energy experts have substantially contributed
to the ongoing discussion about the determination of adequate capital costs in the
railways sector (project team).
• BNetzA’s experts for telecommunications standardisation are deeply involved in
the work and discussion to develop smart grids in the energy sector.
• Rotating of staff members ensures knowledge transfer, particularly important
where networks, services and markets converge
• BNetzA’s responsibility for energy regulation and the network development
plan facilitates new task of planning and permitting to speed up the
necessary grid expansion
Some departments are responsible for the authority as a whole: e.g. HR for all
recruitments of BNetzA, IT for all IT services (synergies, cost saving)
© Bundesnetzagentur
Synergies (2)
In the past 15 years regulation in Germany has
provided for a stable framework and the promotion of
effective competition and efficient investment.
Transparent, reliable, predictable and proportionate
regulatory decisions are crucial for attracting investors,
which is particularly important now with the expansion
of the electricity grid as well as the roll-out of highspeed
broadband networks.
Multi-sector competence and expertise is beneficial in
converging markets and environments.
In the case of new challenges a multi-sector regulator
is better prepared and has the capability to
- elaborate similarities,
- transfer experience and knowledge,
- prevent anti-competitive interference,
- maintain flexibility.
© Bundesnetzagentur
Regulation vs. Application of competition law
Competition law intervention:
abuse of dominance (i.e. anti competitive behaviour) by dominant firms
(ex- post intervention)
ban on cartels (incl. some exceptions) (ex-post)
merger control (ex ante/ ex post)
No ex-ante price approval, but ex-post price examination by BKartA (NCA):
usually prices of comparable competitive markets
checking for margin squeeze
Ex-ante powers of the national regulator BNetzA when applying regulatory law:
ex-ante price control: prices based on costs of efficient service provision (stricter
standard)
ex-ante margin squeeze test
© Bundesnetzagentur
Utilities
Federal Network Agency/
State Energy Regulators
Generation
Network
End user supply
State Competition Autho.
Cartell Office (NCA)
BNetzA & BKartA – Example Energy (1)
© Bundesnetzagentur
BNetzA & BKartA – Example Energy (2)
Federal Network Agency (BNetzA/NRA): Network regulation under the Energy Industry Act, inter alia:
approving network access charges ex-ante
setting-up an incentive regulation scheme
ensuring non-discriminatory network access and set access conditions
taking steps against abuse of market power by network operators
monitoring unbundling provisions
setting fines, where appropriate
Federal Cartel Office (BKartA/NCA): Application of competition law in generation/production and supply:
Abuse of market power in wholesale markets,
control of end-user prices,
merger control
Cooperation: each one has the right to comment on the draft decisions of the other and each one is obliged to inform the other of observations/findings that may be relevant for the fulfillment of the tasks of the other
© Bundesnetzagentur © Bundesnetzagentur 20
Energy Industry Act - Independence of the Regulator
BNetzA : seperate higher federal authority within the scope of business of, but separate
from the Federal Ministry of Economics and Technology
Staff and Management act independently (art. 35, art. 37(4) and (5) Electricity / Gas
Directives)
from any market interest
do not seek or take direct instructions from any government or other public or
private entity when carrying out the regulatory tasks
Takes autonomous decisions: independence from any political body!
Collaborate with EU regulators (CEER)
Collaborate with the Agency for the Cooperation of Energy Regulators (ACER)
Effective regulation requires an independent NRA
Effective regulation on the European level requires a close cooperation among NRAs
© Bundesnetzagentur © Bundesnetzagentur 21
National legislation directly linked to the European targets and provisions:
1. 2009 Renewables Energy Directive: 20/20/20 targets
2. 2009 Internal Energy Market Package: integration of national markets into a
European energy market (transposed with amended 2011 Energy Industry Act)
3. and implementation of IEM: European Network Codes and Market Coupling
4. 2011: Energy Infrastructure Package: connecting European energy
infrastructure and integration of renewables
National energy policy has an effect on the European level: both are interlinked!
BNetzA cooperates closely with NRAs on EU level, both within CEER and ACER,
e.g. informing both organizations early on about measures and impacts for
cross-border trade
National measures and European targets
© Bundesnetzagentur 22
− Separation of generation and supply activities from network operation (Unbundling)
− Network access regulation, including tariff regulation (incentive regulation)
Transport
and
distribution
networks
Supply Generation
Wholes
ale
trading
Potentially competitive market segments
►No ex-ante regulation, ex-post supervision by the Competition Authority
Natural monopoly
►Regulation
Network regulation in the energy market value chain
Limited responsibility of Bundesnetzagentur in comparison
with other national energy regulators − More recently, however, rapidly
growing fields of activity recently, linked to the Energiewende
© Bundesnetzagentur
Energy Regulation – the Legal basis
Market opening already in 1998 (i.e. customers have the right to switch to another
operator), but only in 2005 BNetzA was given ex-ante regulatory powers
Energy Industry Act 2005
(Energiewirtschaftsgesetz – EnWG)
Unbundling: isolate the network from the other activities to neutralize the “monopoly
power” and to prevent discriminatory behavior as well as cross-subsidization
Third party access
Ex-ante regulation of network charges:
Electricity Network Tariff Ordinance and
(Stromnetzentgeltverordnung – StromNEV)
Gas Network Tariff Ordinance
(Gasnetzentgeltverordnung – GasNEV)
Incentive Regulation Ordinance
(Anreizregulierungsverordnung – ARegV)
© Bundesnetzagentur 24
Liberalization – Aims of the new Energy Industry Act 2005
measures aims
“neutralization” of the energy grids
unbundling
non-discriminatory access and usage
Ex-ante approval of network tariffs by
the Bundesnetzagentur
© Bundesnetzagentur 25
Liberalization – German energy market since 2005
New Energy Industry Act 2005 aims at a secure, low-priced, consumer-friendly, efficient, and
environmentally compatible supply of electricity and gas.
Responsible regulatory authority: Bundesnetzagentur – Federal Network Agency
(less than 100.000 costumers: fall in the responsibility of the Energy State regulatory authorities)
Unbundling: strict separation between transmission/distribution network and all other parts of the
value chain)
Non-discriminatory third-party access to energy networks
as the basis for the development of competitive markets
Ex-ante approval of grid charges
Since 2005 the following basic split of competences between
the Federal authorities (national level) applies:
Federal Network Agency: Network regulation
Federal Cartel Office: Generation/production and supply
(e.g. abuse of market power in wholesale markets, plus merger control, but no longer
supervision of the grids)
Introduction of the Energy Industry Act 2005
© Bundesnetzagentur
Split of regulatory competencies in a dual approach
State level competence for networks with fewer than 100.000 customers
State level competence for networks not crossing State borders
Energy State Regulatory Authorities control tariffs, system responsibilities,
unbundling provisions, abuse proceedings
BNetzA has sole responsibility for the national level and cross border (i.e. for
EU level contact, cooperation with NRAs from other EU Member States)
Transfer of competencies from the States to BNetzA possible
(currently 6 out of 16 States have indeed transferred their competencies to
BNetzA)
Aim: Consistent regulation through a joint Committee of BNetzA and
the 10 existing Energy State Regulatory Authorities
However, this regards regulatory functions only, so far the permitting
responsibility lied solely with the State Permitting Authorities (in general
separate from the State Regulatory Authorities)
Division of labour: Federal vs. State level (1 )
© Bundesnetzagentur
Baden-Württemberg
Saarland
Rheinland-Pfalz
Hessen
Nordrhein-Westfalen
Hamburg
Brandenburg
Sachsen-Anhalt
Sachsen
Bayern
Division of labour: Federal vs. State level (2 )
© Bundesnetzagentur 28
TenneT (formerly E.ON Netz, acquired by TenneT, publicly-owned Dutch TSO, Ownership Unbundling) Amprion (subsidiary of RWE, a Vertically Integrated Undertaking) TransnetBW (subsidiary of EnBW, a Vertically Integrated Undertaking)
50Hertz (formerly Vattenfall Europe Transmission, acquired by Elia, publicly-owned Belgian TSO and IFM, an Australian investment fund, Ownership Unbundling)
Electricity Transmission System Operators
More than 10 gas TSOs,
Circa 1600 electricity and gas DSOs
© Bundesnetzagentur
Distribution System Operators
Ca. 866 electricity DSOs in
public or private ownership,
in addition to the 4 TSOs
(plus 695 gas DSOs and
17 gas TSOs)
© Bundesnetzagentur
Energy regulation in practice
Examples for BNetzA’s activities:
Approval of investment budgets/measures with regard to the connection of offshore wind farms to the transmission networks onshore.
Guidelines concerning the induction of renewable energy into the transmission networks.
Assessment of the effects resulting from the plan to take off nuclear power plants from the grid.
Like in the telecommunications sector BNetzA also provides advice to the German Ministry of Economics and other decision makers as well as the legislator with regard the transposition of the European energy directives (2009 – 3rd energy internal market package) and the amendment of the German Energy Act.
According to the energy package (approved 7/8 July 2011) BNetzA is responsible for the spatial planning procedures concerning the roll-out of supra-regional (interstate) and cross-border transmission lines) in order to accelerate the required extension of the networks.
Closer coordination with regard to cross-border issues with NRAs of the Member States of the EU within ACER – Agency for the Cooperation of Energy Regulators
© Bundesnetzagentur
Principles of incentive regulation (1)
Incentive regulation is a reliable instrument for network regulation
incentive for network operators to increase rate of return while reducing
their costs: becoming more efficient
leads to reduced network fees for consumers
win-win-situation for all actors
leads to comparable efficiency scores
© Bundesnetzagentur 32
Advantages of incentive regulation
no annual cost control, lesser bureaucratic burden
automatic cost reduction incentive:
Operators who “beat” or exceed the regulator’s efficiency target
generate higher returns than operators that perform less.
cost reduction for network users
(rebasement at the beginning of the 2nd period)
Disadvantages of incentive regulation
Risk for less efficient network operators
(for example unprofitable network operation)
Risk for network users
(for example decrease in network investments and quality decrease), but
this can be prevented by e.g. investment budgets and with quality
regulation, thus incentive regulation can be designed in such a way that
the necessary investment takes place while operation becomes more
efficient and quality of service is maintained
Principles of incentive regulation (2)
© Bundesnetzagentur
§ 21a EnWG and Incentive Regulation Ordinance (ARegV)
Set two regulatory periods with a duration of 5 years each (first regulatory period for gas operators to last 4 years only)
Longer planning horizon for operators
Decouples revenues from costs: More efficient companies are granted higher returns, less efficient companies receive lower returns
Regulator seeks to incentivise network operators to identify further economies and increase profits, customers also benefit from efficiency increase
Revenue “cap“ set for each calendar year of the regulatory period (thus “revenue path”)
Revenue cap ≠ price cap: Avoids giving network operators an incentive to increase sales
Start of 1st regulatory period: 2009
Rationale of incentive regulation (1)
© Bundesnetzagentur
Regulatory authority must set individual efficiency requirements
based on the relative efficiency of each network operator
by means of an efficiency benchmarking on the basis of suitable efficiency benchmarking methods, to apply both
Data Envelopment Analysis – DEA and
Stochastic Frontier Analysis – SFA;
with standardised (irrespective of different asset age structures, amortisation approaches and capitalisations) and
non-standardised capital costs.
Regulator must use “best-of-four-methods”-result
Individual efficiency requirement must be set at a level allowing the network operator to achieve and exceed it, using all possible and reasonable measures
Minimum efficiency (“floor”) set by law at 60%, hardship clause
DSOs may choose a simplified procedure with efficiency score pre-set at 87.5%
Cornerstone: Individual efficiency targets
© Bundesnetzagentur
Regulatory period
Year 0 Regulatory period
Year 5
Re-Assessment of costs
(Year 4 in gas)
Initial and final cost appraisal
Decoupling of revenues and costs:
Operator may „keep“ cost reductions
„below“ the revenue path
during the regulatory period.
Allowed
revenues
Actual
cost
Rationale for incentive regulation (2)
© Bundesnetzagentur
Incentive Regulation - Formula
Incentive regulation since 2009
Implemented to provide incentives, both CAPEX and OPEX are subject to incentive regulation
Revenue cap regulation with efficiency benchmark
Efficiency comparison
Productivity factor
Expansion factor
Quality element
Inflation rate
Non-controllabe costs 1 (e.g. taxes)
Non-controllabe costs 2 (e.g. structrual
parameters)
Controllable costs
Cost components
Allocation factor for inefficiency reduction
At = t/10 for the first regulatory period
ttt Infl
Infl
0 c,t0 2, nc t1, nct Q EF PF CA 1 C C RC0
t
© Bundesnetzagentur
While DSOs may primarily benefit from the Expansion Factor, TSOs may apply for ‚Investment budgets‘ for expansion projects:
Connection of offshore-facilities to the grid
grid extension measures to connect new power generation
integration of Renewable Energy/Cogeneration facilities
development of the gas transport capacities between market areas
development of interconnection capacities
underground cables
restructuring measures to ensure technical network security
cable temperature monitoring and operation of high temperature cables
Individual applications will be checked ex ante for costs and the necessity of the project
Approved costs will be treated as “non-controllable costs” for one or two regulatory periods in general, i.e. increasing revenues directly
Investment budgets/measures (1) - § 23 ARegV
© Bundesnetzagentur
Allowed Revenues in the first Regulatory Period
2006 2007 2008 2009 2010 2011 2012 2013 2014
Year
Base year for
Revenue Cap
New revenue path
including additional
expansion costs and
efficiency targets
Investment budgets/measures (2)
= Costs of expansion investment in 2010 and following years
© Bundesnetzagentur
The Energiewende
The change of Energy policy in Germany after Fukushima and the Role of the
Regulator
© Bundesnetzagentur © Bundesnetzagentur 40
Nuclear Phase-Out in Germany (1)
On 15 March 2011, the German
government announced to shut
down 8 of its 17 reactors
immediately, i.e. all reactors that
went online before 1981
On 30 May 2011, the government
plan to progressively shut down
all nuclear reactors by 2022 and
massively foster the development
of renewable energy production
By 2050 80% of the production
with renewables
Consequences on the grid stability
analyzed by BNetzA - Report on
our website
operating
shut down
© Bundesnetzagentur 41
Following the Fukushima
catastrophe, the orientations
set in 2010 have been
complemented by an
accelerated nuclear
generation exit
(previously foreseen
for 2036)
Moratorium imposed
by the Government on
the eight oldest nuclear
power plants immediately
after the Fukushima
catastrophe rendered
permanent
Closure of the remaining
nine nuclear power plants
by 2022
2021
2022
2015
2021
2017 2021
2022
2022
2019
Already decommissioned
Date of decommissioning
Nuclear power plants
Nuclear Phase-Out in Germany (2)
© Bundesnetzagentur
Energiewende – Political process
Important that the previous Socialdemocrat/Green Party government under Chancellor Schröder had launched the slow phase out of nuclear power to be replaced by renewables already
When Merkel was reelected in 2009 she reversed this approach by prolonging the time nuclear power plants were allowed to run
When Fukushima happened, Merkel was shocked as obviously all the safety measures failed and ordered (overnight) a shutdown of the 8 oldest nuclear power plants („moratorium“)
In the following discussions she had to convince her own party more than the opposition which favoured the phase out of nuclear power anyhow, thus the Green Party was in favour as were the Socialdemocrats
Important to remember that without the original shift towards renewables, Merkel would not have been able to push through the „Energiewende“ which consisted of a package of 8 new or amended laws
© Bundesnetzagentur
Effects of the Energiewende
Change on the generation level away from conventional and nuclear power to renewables as well as the shut down of nuclear power plants after Fukushima caused a number of effects on the electricity grid:
Short term: more redispatching measures needed to stabilize the grid (more critical situations) and temporary change in the direction of cross-border electricity trading: Germany became a net-importer for a while whereas it usually is a net-exporter
Middle term: more efficient use of existing capacities
Long term: grid expansion and reinforcement plus smart grid development on the distribution level
Long term: smart market development and increase of energy efficiency (energy savings)
Bundle of measures on both the transmission and distribution level as well as on the demand side
© Bundesnetzagentur © Bundesnetzagentur 44
The German Energy Package 2011
Legislative measures – 8 new laws or amendments to existing laws adopted in July 2011
Atomic Energy Act – phase-out of German NPPs
Act to Accelerate the Expansion of the Grid – including acceleration of spatial planning (NABEG) – to speed up grid expansion
Energy Industry Act – transposition of 3rd Internal Energy Market Directives (enforcing stricter unbundling rules: OU, ISO, ITO and new monitoring tasks)
Renewable Energy Sources Act (EEG) – cost-efficient expansion of renewables
Energy and Climate Fund Act – from 2013 all revenues from auctioning emission allowances will be a contribution to this fund
Energy efficiency – i.e. tax concessions for renovation of buildings; climate-friendly development of cities and municipalities; public procurement
entered into force: the 4th and 6th August 2011
Range of new provisions to implement the Energiewende given to BNetzA! A long process…with impact on its neighbors
© Bundesnetzagentur 45
Grid Expansion Acceleration Act (NABEG)
speeds up the permit procedures for necessary high voltage power lines (in the past
processed by the State Permitting Authorities, took up to 10 years)
now: Federal Network Agency in charge for inter-state (trans-regional) connections
(max. 5 years between application and final decision)
coordination between the national and European 10-year-network-development-plan
(completion of the European internal energy market)
Grid Expansion Acceleration Act
© Bundesnetzagentur 46
Renewable Energy Sources Act (EEG)
Basis for the success of renewable electricity in Germany
is the Renewable Energy Sources Act
(Act on granting priority to renewable energy sources, Erneuerbare-Energien-
Gesetz, EEG)
EEG entered into force in 2000 and has been amended several times
Purpose of the EEG: Facilitating a sustainable development of energy supply by
promoting the development
of technologies for the generation of electricity from RES
Objective: Increasing the share of renewables
in electricity supply to at least 35 % by 2020 and continuous increase thereafter
(up to 80 % in 2050)
© Bundesnetzagentur 47
EEG-related tasks of the regulator
BNetzA must inter alia monitor:
the transfer of renewable electricity and tariffs including the marketing of such
electricity by the TSOs,
calculating and claiming the EEG-surcharge by the TSOs
in case BNetzA has a legitimate doubts, audits of installation operators may be
conducted
compliance of Grid System Operators with feed-in management rules; BNetzA
may set further feed-in management guidelines
Additional task: Calculation of the feed-in tariffs for
PV installations
© Bundesnetzagentur 48 48
Germany’s Energiewende (energy turnaround)
National targets 2020 2030 2040 2050
Reduction of greenhouse gas
emissions
(in comparison with 1990)
40 % 55 % 70 % 80-95 %
Share of renewable energy
in final energy consumption 18 % 30 % 45 % 60 %
Share of renewable energy
in electricity generation 35 % 50 % 65 % 80 %
Reduction of primary energy demand
(in comparison with 2008) 20 % 50 %
Action plan adopted by the Federal Government in 2010
© Bundesnetzagentur 49
Renewable
energy
generation
Conventional
electricity
generation
Energy
efficiency
increase
640
Domestic
electricity
generation
Electricity
generation Electricity
imports
Electricity
demand
90
285
550
2008 2050
350
510 130
160
65
in TWh
+ > 300% 80% share
of renewables
14.5% share
of renewables
Ambitious targets on Renewable energy,
energy efficiency and electricity imports
Germany’s Energiewende (energy turnaround)
© Bundesnetzagentur
Government Energy
Policy:
Share of electricity
produced by
renewables to rise to
35 % by 2020
80 % by 2050
Renewable Energy
Act (EEG) designed
to foster this process
NABEG to speed up
grid expansion and
ensure integration
of renewables
Electricity Mix Germany 2011 Renewables: 19.9 %
Hard coal
18.6%
Natural gas
13.7%
Nuclear
17.6%
Lignite
24.9%
Renewable energy
sources: 19.9%
Oil1.1%
Other 4.2%
Source: AG
Energiebilanzen
Renewable Energy Targets Electricity Production
© Bundesnetzagentur
Key Challenge: Grid expansion for the
Quelle: Alpha Ventus
Quelle: VDE
Quelle: Vattenfall
Quelle: Spiegel Quelle: Kurier.at
Quelle: sigma wind energy
storage power
stations
grids
CCS systems
climate-neutral
buildings
biomass
power plants
Electric mobility
photovoltaics
Integration of the Renewables
© Bundesnetzagentur Renewables and Grid
Expansion
52
Changes in Generation Require New Grids (1)
Traditionally, fossil and
nuclear production
plants have been built
close to where the
energy was actually
needed, i.e. where
most of the industrial
load is located: in
Southern/Western
Germany. .
Renewable energy
production develops
mainly in Northern
Germany, esp. wind
© Bundesnetzagentur
Increase by 2022:
12.900 MW Scenario B
Increase by 2022:
20.400 MW Scenario B
2021
2022
2015
2021
2017 2021
2022
2022
2019
shut down
planned shut down
Main generation
Main load
wind offshore
wind onshore
Increase by 2022:
36.000 MW Scenario B
solar
Nuclear power plants
Changes in Generation Require New Grids (2)
© Bundesnetzagentur © Bundesnetzagentur 54
Changes in Electricity Generation Require New Grids (3)
Increase by 2022:
20.400 MW Scenario B
2021
2022
2015
2021
2017 2021
2022
2022
2019
shut down
planned shut down
Increase by 2022:
12.900 MW Scenario B
wind offshore wind onshore
Increase by 2022:
36.000 MW Scenario B
solar
Nuclear power plants
Expansion and
reinforcement of the
networks urgently needed
Transmission system
Offshore wind farm
connection
Modernization of the
distribution system
Investments needed of
approx. € 30 to 50 billion
until 2020 (DENA-II study)
New competences for
BNetzA: a new role
beyond regulation!
Increase by 2022:
7.300 MW Scenario B
gas-fired plants
© Bundesnetzagentur
German „Energiewende“ package 2011
Rapid expansion of renewables: 80% wind, solar and biomass by 2050
Nuclear phase-out by 2022
Reduced electricity consumption as a result of increased efficiency
Increased cross-border electricity trading
Consequences for the network
Volatility of consumption and production in terms of both time and
location reduces predictability and requires higher resilience
Average distance between production and consumption increases
Volatility of the network situation increases: more difficult to manage
Network development (grid expansion) is a clear priority:
to speed the process up BNetzA was given new competencies
Underlying transformation of the energy system
Reasons for Network Development:
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 56 © Bundesnetzagentur 56
How will BNetza work on this?
Implementation of EnWG 2011 and NABEG:
BNetzA is building up competence in −
network modelling and network planning
specialist planning and plan approval
environmental issues and
procedures of participation
Around 240 new colleagues being recruited
Connection between the new tasks and
energy regulation issues synergies and
bundling of competence
Cooperation with Laender level:
consistent decisions
Bundesfachplanungsbeirat
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 57
New network development process: From scenarios to plans and permits
Scenarios Network Development Plan
Federal Requirements Plan
Corridor permitting
Line path permitting
BNetzA approved
TSO scenario framework
TSO consulted on draft
Network Development
Plan
BNetzA consults on
revised TSO NDP
BNetzA to confirm NDP and draft a
Federal Requirements
Plan
Legislator to adopt Federal
Requirements Plan
TSOs to submit permitting
applications
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 58
Enhancement of Network Development
Network development as a transparent concept under federal supervision of BNetzA
Faster permit procedures are on the way in Germany – legislation passed in June
2011
Network expansion is clearly decided: “of highest public interest”
Planning
of cross-
border and
interstate
transmissi
on system
corridors
by BNetzA
Option for
Permitting
Procedure
s for
BNetzA
10-year network development
plan (“NEP”/TYNDP)
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
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Draft Scenario Framework by TSOs
Consultation
Approval of the TSOs‘ „Scenario Framework“ by BNetzA
Approved „Scenario Framework“
Establishment of the Draft German Network Development Plan
involving all TSOs by 3th June 2012
Consultation of German Network
Development Plan and of the
Environment Report by BNetzA
Draft Federal Requirements Plan by BNetzA
Federal Requirements Plan (Bundesbedarfsplan)
Scenario Framework reflects the development of the energy policy framework (e.g. production capacities, consumption, etc.). It is the starting point to define the need for network development.
Federal Requirements Plan reflects the need to develop the network in a concrete way
Process leading to the Network Development Plan
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 60
Network Development Plan: Involve the public
Objective of the National Network Development Plan: Increasing local acceptance
Prerequisite is improved transparency
Consultation of network development plan
on several stages:
Include the public (especially the actual and
potential users) with 6 townhall meetings
Acceptance of public: overcome NIMBY
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 61
Consultation of the „NEP 2012“ started on 6 September – lasting until 17/10/12
All in all 3,800 km of new transmission lines are needed (current total: 17,500 km)
The Network Development Plan, consulted on and modified by the four transmission system operators, sets out the nationwide expansion measures for the grid up to 2022 / 2032 that are needed to secure electricity supplies into the future. The Bundesnetzagentur with the help of TU Graz has made its first assessment of these which it has published in an accompanying document.
Contains a total of 50 projects, 13 accepted in principle, the rest will be reviewed in parallel to consultation
Strategic environmental assessment: BNetzA is taking protection of the environment, too, extremely seriously
6 public hearings are scheduled to take place across Germany
NEP and following from that the draft Federal Requirements Plan (containing the concrete corridors/routes) is expected to be adopted by end 2012
All information published on extra website: www.netzausbau.de
Consultation of the German Network Development Plan
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 62 62 62 62
Key to map
DC new build
AG new build
AC reinforcement
Existing AC network
DC corridor
B
DC corridor
A
DC corridor
C
DC corridor
D
Initial transmission network planning for 2022
Scenario B of draft TSOs‘ NDP
Contains all measures needed for a
secure and reliable network system
operation, contains time plan
(prioritisation) of measures
Recommends for the first time the use
of HVDC to a considerable extent
NOVA principle
Assessment of necessity of measures
by BNetzA and of consistency with
Europ. TYNDP
Most important: North-South
transmission lines to bring electricity
from the Offshore wind farms in the
North Sea to the industrial users
concentrated more in the South of
Germany
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 63 63
Electricity transmission network planning
National Ten-Year Network Development Plan (TYNDP) prepared by the 4 TSOs for consultation, based on EU Directives
Covers 2012-2022 submitted to consultation end of May 2012
Based on generation/load scenarios
Identifies requirements for network optimisation, improvement and expansion
New AC links: 2800km on existing routes, 1700km in new routes
For the first time, 2100km of DC links (10 GW capacity) in 4 corridors
Cost estimated at 20bn euro over 10 years
BNetzA consulted on the TYNDP and approved it with revisions
TYNDP submitted as draft federal requirement plan to the Ministry of Economics on 26 Nov. 12 to be turned into federal law, spatial planning and line permitting for nationwide and cross-border transmission lines to follow to speed up permitting procedures
On 19 Dec. 2012 the Ministry published the draft Federal requirement plan law including competencies for BNetzA with regard to permitting of nation wide and cross-border transmission lines
All information can be found online: www.netzausbau.de
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 64 64
64
Results of BNetzA‘s assessment
BNetzA for now
only confirmed the need for:
51 out of 74
proposed projects
Only 3 out of 4 proposed
DC corridors were approved
Overall 2800 km in new routes were
confirmed,
2900 km reinforcement of existing
routes
AC 380 kV new build
3 HVDC corridors – new build
AC 380 kV reinforcements
© Bundesnetzagentur © Bundesnetzagentur 65 © Bundesnetzagentur 65
One and a half year after…
not so optimistic any more, but still supported by 80% of the population
But: it is a „Generation project“
BNetzA to support the policy goals on the regulatory side and by using its new
competences to shorten planning procedures („OSS“)
Grid expansion is a key issue
Reduce congestion on transmission grids
Integrate offshore wind production in the transmission grids
Have smart distribution grids
Tight time table can only be met if all parties involved cooperate as closely as
possible each one playing its role
Early involvement of public in every stage of consultation to overcome NIMBY effect
as there is a general acceptance of nuclear shut down
In the long term all elements must work together: grid expansion, smart grids and
energy efficiency of users in a smart market design, probaby capacity mechanisms,
process to be coordinated
Close cooperation with all NRAs + ACER to reach European targets
© Bundesnetzagentur
The Energiewende requires the integration of renewables and thus an
expansion and reinforcement of the electricity grid (both on the
transmission as well as on the distribution level) requiring considerable
investment
The Energiewende will work only if the grid expansion is speeded up by
shorter planning and permitting procedures as one of the main obstacles
The Energiewende requires in the short term more redispatching measures
of the TSOs to stabilize the grid
New competences of BNetzA with regard to planning procedures for
nationwide and cross-border electricity transmission lines: synergies as
BNetzA is the energy regulator: OSS concept
Shortening of planning and permitting procedures requires also a greater
coordination both within Germany between the Federal and the Laender level
as well as on the European level (European Energy Infrastructure Package of 27/11/12)
Conclusions (1)
© Bundesnetzagentur
Acceptance of the users is essential: extensive consultation process started by BNetzA on 6 September 2012 of the NEP 2012 containing all grid expansion measures planned by TSOs (more than 3000 comments)
NEP and draft Federal Requirements Plan approved by end of Nov. 2012 by BNetzA and submitted to the Ministry of Economics on 26 Nov. 2012
Necessity and obligation of operators to invest once the Federal Requirements Plan Law is finally adopted and legally binding, BNetzA to be responsible for permitting of nationwide and cross-border lines
Incentive regulation is desgined in such a way that all new projects can be realized, attractive rate of return on equity of 9.05%, stable + predictable regulatory regime provides confidence to investors
Tight time table, but so far BNetzA has delivered and performed the new tasks assigned with NABEG, the Energiewende is managable, but all players must cooperate as well as coordinate and join the effort!
Overall, a strong independent regulator well resourced is essential
Conclusions (2)
© Bundesnetzagentur 68
Summary and Outlook
Introduction of ex-ante regulation through BNetzA with the 2005 Energy Industry Act was
successful:
Electricity tariff regulation is successful since 2005
Network tariffs (in particular for households) decreased since 2005 and switching increased
Incentive regulation sets efficiency targets for cost reduction and ensures necessary
additional investments in the future
One of the major drivers will be the integration of renewables
High quality and security of supply to be ensured in the future
Substitution of the shutdown of 8 nuclear power plants in 2011
Withdrawal from the nuclear energy generation by 2022
Grid expansion to balance the increasing generation of renewable energy in the northern part
of Germany and the lack of nuclear power capacity in southern Germany (“power
transmission highways”)
© Bundesnetzagentur © Bundesnetzagentur 69 © Bundesnetzagentur 69
Thank you very much for your attention
Dr. Annegret Groebel
Bundesnetzagentur
Head of Department – International Relations / Postal Regulation
Tulpenfeld 4
D-53113 Bonn
annegret.groebel@bnetza.de
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 70 70 70 70
A N N E X
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 71 71
Existing energy network (capacity “KW”)
Smarkt grid and smarkt market distinction
Increase of transmission/distribution capacity for renewable energy needs by
building new lines
Upgrade of existing (distribution) grids by adding communication-, metering-,
control- and automation technology + IT to enhance quality, efficiency and capacity
of the grid
Establishing technical prerequisites for markets
(e.g. data hub) and establishing market rules beyond the grid
Grid
S
mart G
rid
Sm
art Market
intelligent Energy Markets
(Trading of energy and energy-related services “kWh”)
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 72 72
Political / regulatory action
Existing grid
+ intelligent grid control (adding ICT)
Natural monopoly requires regulation
Intelligent markets
Increased energy trading and new
services
Prerequisite:
Smart Meter and availability of
consumption- and price data
Liberalisation, deregulation and
competition
(Smart) Grid Smart Market
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 73 73
Smart Grid
Transmission grids are already smart today…
Where appropriate, enhancement of „Smartness“ could be needed (monitoring of power lines, better information flow from DSOs to TSOs)
Focus on new (conventional) power lines (Offshore connection, SuperGrid, corridors)
Distribution grids have to become smart…
Network status / usage not really known
Feed-in (amount and generation profile) of local generation not known
No or little possibility for active switching operations
Focus on refitting of grid with communication, metering, control, regulation and automation technology and IT components as well as expansion of grid
Smart Grids vs. conventional grid expansion
This is a entrepreneurial decision of the DSO (not the regulator) in line with incentive regulation
Decision is dependent of many parameters (available technology, anticipated utilisation, capacity need due to business models of Smart Market etc.).
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 74
Smart Market
existing grid
+ intelligent control
= Smart Grid smart
metering
smart
storage
smart
consumption
smart
generation
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 75 75
Network tariff developments
Most recent developments:
Transmission network tariff increases due to:
capital costs of approved “investment measures”
in the incentive regulation system
for connecting offshore wind farms and reinforcing onshore lines
cost for system services such as balancing, redispatch or
the contracting of “reserve power plants” to ensure
security of supply in winter are passed on to final customers
Distribution network tariff increases due to:
upstream transmission network tariff increases
passed on to final customers
remuneration for network tariffs avoided through decentralised feed-in
use of the „extension factor“ in the incentive regulation system
retrofit costs for older PV to address frequency stability issues („50.2 Hertz“)
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 76 76
Network tariff developments
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 77 77
Retail electricity price developments 2006-12
4,49 5,90
7,19 8,36 8,10 8,41 8,39
7,30 6,34 5,92
5,80 5,81 5,75 6,04
2,48 2,58 2,81
2,91 3,71 5,18 5,42
4,66 5,26
5,47 5,68 5,79
6,11 6,21
26,06
23,42 22,75 21,39
20,08 18,93
25,45
0
5
10
15
20
25
30
2006 2007 2008 2009 2010 2011 2012
ct/kWh
Energy procurement & supply
(incl. margin) Network tariff
Surcharges and concession fees
Taxes
Development of household electricity retail tariffs in 2006-2012 (volume-weighted average across all tariff plans)
Source: BNetzA Monitoring data
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 78 78
Retail electricity prices
Breakdown of the household electricity retail tariff in 2012 (volume-weighted average across all tariff plans)
24.1%
8.2%
0.6%
0.0%
20.6%
7.9%
2.5%
15.9%
6.4%
13.8%
Network tariff Metering and billing
Electricity tax Value-Added Tax
Concession fee Renewable energy surcharge (EEG)
Co-generation surcharge (KWKG) Network tariff reallocation charge (§19StromNEV)
Energy procurement Supply including supplier margin
Source: BNetzA Monitoring data
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 79 79
Renewable energy support 2010-2011
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
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EEG remuneration scheme 2013
Shares of individual cost positions
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 81
** estimate
2012:
11,7 ct/kWh
2013:
ca. 14,4 ct/kWh
Concession fee (average)
Value-Added Tax
Electricity tax
EEG surcharge
KWKG surcharge
§ 19 StromNEV reallocation charge
Offshore liability surcharge (from 2013)
+2,7
ct/kWh
Strompreisanalyse Oktober 2012 26.10.2012
Seite 81
Retail electricity price developments in 2013
Source: BDEW
Overall level of fees, taxes and surcharges
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
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Hurdles that need to be overcome
Planning and permitting procedures to be shortened:
Implementation of a “One Stop Shop”
BNetzA in charge of
Approval of investment financing (“budget” for new projects)
Federal sectoral/spatial planning
Plan permitting approval
(if determined by ordinance requiring the consent of the “Bundesrat”)
Ownership unbundling requirements
Investors are not interested in controlling rights, shareholder agreements are a
common approach
Traditional financial regulation which considers investments in energy infrastructure as “risky” (eg Solvency II)
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
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Financing Grid Expansion
Capital spending globally cautious… but:
investors look for attractive opportunities;
stable economic data in Germany
Considerable investment needs in power grid
Regulatory framework in Germany is
economically interesting and legally stable
Bundesnetzagentur has done a lot to clear up
any cases of doubt regarding the framework
conditions
Quelle: pixelio.de
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
© Bundesnetzagentur 84
How can all of this be financed?
Network is refinanced by the users (rolled in network charges)
In case a network operator is unable to organize the financing
of the needed measures involvement of
financial Investors possible
No scarcity of capital, investment budgets/measures approved
by BNetzA for all but one project
Basic principle: All Projects should be privately financed
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
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BNetzA's philosophy on returns
More important than the nominal rate of return is the
sustained profitability of the investment, generating
steady, stable cash flow.
Providing certainty to investors: regulation is predictable
BNetzA sees to attractive returns for the long term
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
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Return on equity : BNetzA decision on 2 November 2011
risk premium
3.80% Risk-free rate:
historic 10 year current
yield average
corporation tax
Interest rate after
taxes: 7.39%
3.59%
1.66%
Rate of return
before corporation
tax: 9.05%
Rate of return
before corporation
and trade tax:
10.48 %
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
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Investments in grid: almost no investment risk (1)
No planning and approval costs, ie the costs incurred before a line is taken
into service are borne by the consumer
Cost increases are recognised fully where there is proof of good reason for
the increase
There is no risk for German network operators as a result of the incentive
regulation account and individual consideration of the cost of debt
"Stranded investment" costs are borne entirely by the consumer (for
instance, if the line is built but the wind farm doesn't materialise)
No risks from fluctuating capacity
• as a result, for instance, of weather-reflective feed-in, or
• cyclical consumption, or
• technical faults in the generating facilities (eg wind farms)
Kapazitäten und Netze – Herausforderungen für die
Versorgungssicherheit
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Investments in grid: almost no investment risk (2)
Proposal of BNetzA: Strong limitation of liability. Regarding construction and
operation of offshore connection lines TSOs are liable for claims of offshore-
operators only with respect to intention and gross negligence. Liability for
damages due to gross negligence is limited. Any additional liability of TSOs is
excluded.
Real time refinancing; investors earn money from the very first day
Actual cost of debt are remunerated, if the cost of debt correspond to market
condition
Strict continuation of the calculation methodology ensures risk-adequate rates
of return that are predictable and that can be planned for in the long term
© Bundesnetzagentur
European Energy Infrastructure Package
CEER/ACER is actively following the ongoing discussions on the Energy Infrastructure Package proposed by the Commision in October 2011: promote transeuropean energy infrastructure
The criteria for the selection of Projects of Common Interest (PCI) projects should be clear and quantifiable. Otherwise we will have long discussions which will just delay investments – which is not the intention.
Investors need to be clear that only efficiently incurred costs will be allowed by national regulators for cost recovery from network tariffs in order to ensure the effective use of capital.
We do not want to delay commercially sound projects by suggesting that they may be eligible for incentive that they don’t actually need. Nor do we want to allow the costs of investments to spiral inefficiently. It is essential that national regulators retain the power to decide on the nature of incentives, on a case-by-case basis, and that such incentives should be proportionate to the risk incurred by investors.
National Regulatory Authorities have the core expertise in ensuring that investments in infrastructure are made, and are made efficiently. However, the critical issue is whether the framework within which regulators operate helps them to work effectively – or hinders them.
© Bundesnetzagentur
Conclusions incentive regulation (1)
Incentive regulation works as it can provide incentives both for efficiency as well as
investments
Strict continuation of the calculation methodology ensures risk-adequate rates of
return that are predictable and that can be planned for in the long term providing
certainty for operators and giving investors confidence
There is no risk for German network operators as a result of the incentive regulation
account and individual consideration of the cost of debt
Higher rates of return do not deliver more rapid expansion but mean higher use of system charges!
© Bundesnetzagentur © Bundesnetzagentur 91
4 reasons why it is worth investing in German energy infrastructure:
1. Germany is the biggest electricity and gas market in Europe.
2. Germany has the most secure electricity network in Europe and an
excellent natural gas infrastructure.
3. Germany has the most ambitious energy and climate change targets.
Infrastructure expansion is a growth market.
4. Bundesnetzagentur has done a lot to clear up cases of doubt regarding
the framework conditions
Conclusions incentive regulation (2)
Recommended