Together with Tech for Net Zero and other organizations working on innovative heat solutions and energy storage, we have submitted a joint statement on the Bundesnetzagentur(Federal Network Agency for Electricity, Gas, Telecommunications, Post and Railway)’s draft determination on the general grid fee system for electricity (AgNes).
We welcome that the draft contributes to a more predictable German grid fee system. From the perspective of providers and operators of large heat pumps, power-to-heat plants, thermal storage, and battery storage, we still see a need for adjustment:
1) Adapt the Basic Model to Enable Flexibility: Incentives for flexibility have largely been postponed to 2027, pending the decision on industrial grid fees and dynamic grid fees for storage and generation. No dynamic incentives are planned for end users. The basic model could still be adjusted now to lay the groundwork for flexible consumption:
- Allow AP2 (Arbeitspreis 2: an energy fee) exceptions during low-load hours so the intended price signals are not inverted.
- Lower the minimum capacity threshold for controllable loads.
- Expand options for aggregating withdrawal points, base construction cost contributions on reserved capacity, and allow mid-year adjustments to orders.
2) Equal Treatment for Innovative Heat Solutions: Electrolyzers receive a special grid fee to support market ramp up, but large heat pumps, power-to-heat plants, and thermal storage are excluded for lack of concrete targets.
These innovative solutions make an invaluable contribution to heat modernisation and energy resilience, and should be treated the same as electrolyzers when setting tariffs under AgNes. Their grid-supportive flexibility potential is structurally comparable, proof of low-carbon production is becoming more relevant, and targets for electrifying process heat are already sufficiently concrete. We propose equal treatment or, at minimum, an opening clause for a later determination.
3) Confirm That Thermal Storage Is Energy Storage: The draft does not specify whether thermal storage, and particularly systems that can reconvert heat to electricity, falls under the definition of electricity storage.
This definition determines access to the transitional arrangement, future dynamic grid fees, and affects operator models that supply heat to neighboring industrial sites. We ask the BNetzA to clarify this and to explicitly recognize pure heat storage as a flexible, grid-supportive consumer. Scaling up innovative process heat and heat-based long-duration energy storage requires regulatory certainty.
4) Set Workable Thresholds for Transition Periods: The transitional arrangement for battery storage improves legal certainty, but its proof requirement goes further than necessary.
Binding orders for at least half of the investment volume favor well-capitalized incumbents and risk excluding advanced projects that are not yet fully contracted. We propose a lower threshold or alternative proof, such as documented planning status, permits, or grid connection agreements. The arrangement should also cover comparable thermal storage projects, as well as plants commissioned during the transition period.