29.04.2025
The Initiative Energien Speichern (INES) expresses clear criticism on behalf of its members regarding the current draft of the Gas Storage Level Regulation (GasSpFüllstV), which was submitted for consultation by the Federal Ministry for Economic Affairs and Climate Action (BMWK) on Monday afternoon.
Berlin, April 29, 2025 – “The BMWK’s rushed approach to the gas storage law could backfire. Frustration in the industry is accordingly high. What the storage sector needs are rules that do not undermine the market and competition, while ensuring the safe and cost-efficient filling of gas storage facilities before winter,” explains Sebastian Heinermann, Managing Director of the Initiative Energien Speichern (INES).
INES provides a nuanced assessment of the planned adjustments to the legal gas storage level targets. While the association expressly welcomes the removal of the interim target for October 1, it sees a need for improvements in other measures with regard to supply security and market impacts.
Elimination of the Interim Target Increases Cost Efficiency
INES supports the decision to forgo the interim target on October 1. Reducing existing interim targets creates additional flexibility and enables cost-optimized gas procurement. Fewer interim targets mean more flexibility – which can contribute to a more efficient and economical filling of storage facilities.
Security of Supply Should Not Be Compromised by Misaligned Incentives
INES points out that both the planned increase of the storage level target to 40 percent by February 1 and a general reduction of storage level targets could affect the gas supply situation in winter.
A mandatory high storage level in February – combined with technically limited withdrawal rates – could lead to some reserves being unusable by the end of the heating season. Additionally, a reduction in the November 1 target could result in lower storage levels heading into future winters.
Both developments should be carefully weighed to ensure that the objective of the gas storage law – securing gas supply in winter – is not undermined. INES therefore recommends refraining from raising the February target and assessing the potential impacts of the planned reduction in storage level targets before winter.
Discriminatory Individual Requirements Jeopardize Fair Competition
INES is concerned about the planned introduction of storage-facility-specific level requirements during the validity period of the gas storage law until March 31, 2027. These proposals represent a significant interference in competition, the effects of which are currently unpredictable. INES calls for a comprehensive analysis of the potential consequences of this discriminatory market intervention before implementation.
EU-Law-Based Flexibility Instead of Market Intervention
In light of the anticipated development of the European Regulation (EU) 2017/1938, INES recommends considering a postponement of the current November target to December 1 as an alternative to storage-facility-specific level requirements. This could avoid the proposed significant and discriminatory market intervention while also providing a solution in compliance with EU law.
As a general principle, such significant regulatory interventions should be carefully designed and carried out in close dialogue with the industry.
FURTHER INFORMATIONEN:
Pressemitteilung auf Deutsch lesen / Read Press Release in German