“It’s a miracle we have any storage projects in Germany at all”

pv magazine: On October 17, the Federal Network Agency published an FAQ on grid connections for large battery storage systems. Was this completely new, or did an earlier version already exist?

Britta Wißmann: No, there wasn’t an earlier version covering these topics. The FAQ reflects BNetzA’s legal opinion, but it isn’t a binding regulation. Still, grid operators are expected to follow the legal interpretation of their supervisory authority.

Previously, were large-scale batteries over 100 MW handled only under the Power Plant Grid Connection Ordinance (KraftNAV), or were there already separate procedures for feed-in and draw capacity?

As I understand it, transmission system operators, who usually handle these large projects, followed a process based on the KraftNAV. It was logical and transparent, combining both feed-in and draw capacity in one procedure. Now BNetzA says the KraftNAV applies only to feed-in, while grid draw must follow Section 17 of the Energy Industry Act (EnWG). That raises the question of whether two separate procedures will now be required. That’s new and still developing.

Have you seen any reaction from grid operators to the publication?

I’ve heard that not all transmission operators were happy about it. At least now we know BNetzA’s position, though whether it would hold up in court remains uncertain.

Does anything change for large-scale projects that already have a grid connection commitment?

I hope not. Anyone who already has a binding commitment from a clearly defined process that isn’t subject to later changes should be able to rely on it. Otherwise, it would be disastrous. But there’s no absolute certainty. The energy sector has seen plenty of surprises. If a project only has a nonbinding preliminary statement, it’s quite possible the procedure could change. Whether that change would hold up legally depends on how it’s implemented. It will always come down to the specific case.

Could two separate procedures mean different connection dates, for example, feed-in from 2029 but grid draw only from 2035?

The grid operator must always check whether network capacity is available. They can refuse connection if grid expansion is needed and must conduct a transparent, non-discriminatory, and fair process. If grid draw capacity is temporarily unavailable, it doesn’t matter whether the process follows KraftNAV or Section 17 of the EnWG. However, it’s conceivable that a project could receive draw capacity but not yet feed-in capacity, or the other way around. In that case, the storage project loses its foundation because it can’t operate. That’s the core of my criticism: the regulatory framework doesn’t treat stand-alone storage as a distinct asset class that requires both charging and discharging capacity. A storage system without one side simply isn’t viable.

What about batteries under 100 MW?

For those, Section 17 of the EnWG applies, meaning a transparent and fair procedure. Often, the “first come, first served” principle is used to secure draw capacity. There are cases where a feed-in commitment exists, but grid draw hasn’t yet been secured, as it’s handled separately and requires an advance payment toward the grid connection cost. Those payments can be very high, posing a challenge for developers. Some grid operators even say: “Today there’s capacity available, but I can’t guarantee it’ll still be there in two months.” That makes planning extremely difficult.

Are there deadlines for how long grid operators must keep their offers valid?

No statutory deadlines exist. We’ve seen offers valid for four weeks and others for up to two months. It varies from one operator to another.

Wouldn’t it have been simpler to apply the EnWG procedure to large storage systems too, instead of introducing two?

Even the EnWG procedure isn’t uniform. Many operators already separate draw and feed-in. So the main issue isn’t which law applies, but the fact that both sides are handled separately. That makes no sense technically or economically. It blocks capacity that might never be used if, for example, grid draw isn’t later secured. This delays projects that are more likely to be realized.

BNetzA also allows a “realization fee.” How do you view that?

Such a fee can improve the likelihood of projects being built because it requires financial commitment. Paying a fee shows serious intent. BNetzA clarified that under Section 17 of the EnWG, a realization fee may be charged upfront for securing grid draw capacity and later offset against grid connection or construction costs. A unified legal framework would make sense, one combined process with clear rules and, if necessary, binding payments.

Under KraftNAV, no construction cost contribution is charged. If both procedures now apply, would large systems over 100 MW have to pay both, the reservation fee and the construction cost contribution, possibly plus a realization fee?

If we strictly follow BNetzA’s interpretation, yes. BNetzA says the realization fee can be offset against grid connection or construction costs. But it says nothing about the KraftNAV reservation fee. So, if the two sides are truly separated, the feed-in side would involve a reservation fee under KraftNAV, while grid draw would involve a construction cost contribution and possibly a realization fee. The exemption from construction cost payments under KraftNAV was originally designed only for generation assets to encourage feed-in. Storage, however, both draws and feeds power. Unlike generators, storage draw isn’t just for self-consumption; it’s electricity taken from the grid to later feed back in. So storage plays a dual role.

What happens to those payments if a project isn’t built?

According to BNetzA, the realization fee is forfeited, and that’s the intended incentive. An exception applies only if non-realization is beyond the developer’s control. BNetzA considers refund terms acceptable if they follow the case law on KraftNAV reservation fees. The same logic applies to the KraftNAV reservation fee itself. Developers should therefore think carefully before filing multiple grid requests without serious intent. Whether a paid construction contribution must be refunded if a project fails is unclear; some operators return it minus costs, others not at all. There’s no consistent rule yet.

Construction cost contributions are often criticized as nontransparent. Do you agree?

BNetzA published a position paper that, while not binding, many operators follow when calculating these contributions. However, some use the current price instead of the five-year average price, which must be checked for legality. When significant time passes between feed-in reservation and grid draw confirmation, prices can change substantially. This makes cost planning difficult and jeopardizes projects since developers often need time to raise the capital required to secure grid draw capacity.

And that ultimately threatens the realization of storage projects overall?

Yes. I’ve long said: it’s a miracle we have any storage projects in Germany at all — not because of regulation, but despite it. Grid operators and storage developers aren’t that far apart in what they want. Both need clear processes and planning certainty. Operators don’t want a flood of speculative requests, and developers need reliability. Lawmakers must now establish clear rules that give investors confidence and ensure viable projects can move forward. Storage is central to the energy transition, it shouldn’t be slowed down by impractical procedures.