This is how the federal government wants to enforce gas rationing

The digitization of German offices and authorities has so far been a tragedy. That is why there was no reassurance when the federal government announced in spring that it wanted to manage the worst possible crisis – the collapse of the gas market in the middle of winter – with a digital “security platform”.

Now the software package, with which the state wants to allocate scarce natural gas according to need in an emergency, is almost ready for use. The Federal Network Agency presented it to the public on Wednesday.

To anticipate: Doubts about the good digitization of official processes are always appropriate in Germany, but probably not in the case of the impending gas shortage. The "Gas Security Platform", which a young team of programmers, market and regulation experts from Trading Hub Europe (THE) and the Federal Network Agency have now presented to the public, makes a well thought-out, practicable impression. This is important: after all, it is the state's most important instrument for largely limiting the theoretically immense damage and diverse risks of a gas shortage.

The gas safety platform is used when the federal government declares an emergency level due to an acute gas shortage, the third and last escalation level in the national gas emergency plan. It will do this when the gas market collapses due to Russian supply disruptions, meaning consumers can no longer be supplied.

With the "security platform" that has now been set up, a communication tool has been created through which energy suppliers and pipeline operators can exchange data with the Federal Network Agency on a daily basis and make decisions about who gets how much gas in Germany.

It doesn't affect everyone: only the largest gas consumers are obliged to register on the safety platform's website from October 1st. Germany had a gas consumption of about 1000 terawatt hours last year. Around 300 terawatt hours are accounted for by private households and small businesses, whose consumption has so far been measured using so-called standard load profiles. They are not affected by the registration requirement.

The remaining 700 terawatt hours are accounted for by around 40,000 larger "end consumers". But only those who consume at least ten megawatt hours of gas are required to register on the data platform. These are around 2,500 companies that account for 45 percent of Germany's gas consumption.

Among these 2,500 major consumers, a manageable group of 250 companies account for 70 percent of the gas requirement. In the event of a shortage, the state will probably adhere to them first. But all 2,500 major consumers are required to submit numerous data by the end of October. These include the estimated cost of a gas supply disruption, the amount of gas left in the company and the social relevance of its products.

If the emergency level is declared, the Federal Network Agency, in its role as "federal load distributor", opens an "initiative" on the security platform depending on the current situation. The network operators enter current data on the missing gas quantities in the various regions of Germany. Then a crisis team of the authority decides in a weighing process which company is allowed to consume how much gas.

Studies on the "vulnerability" of supply chains are also used to prevent upstream or downstream sectors from being unnecessarily affected by rationing. Every company that has to ration is given a “maximum performance value” that must be adhered to on a daily average.

In the event of an emergency, companies are obliged to be available 24 hours a day, seven days a week, in order to be able to implement the orders of the federal load distributor without delay.

Energy market expert Gernot-Rüdiger Engel from the Luther law firm criticizes the fact that companies are hardly given any time in advance to prepare for rationing. Those responsible in Germany have defined "bottleneck regions".

But the borders of these regions, which are particularly threatened by the lack of gas, should remain secret. "That is incomprehensible," criticizes Engel: "This means that companies in the bottleneck regions are deprived of an opportunity to prepare for the impending rationing at an early stage."

So it remains completely unclear in advance who exactly the rationing could affect and with what probability. The Luther law firm had already developed so-called protection applications, which companies used to justify their gas requirements to the Federal Network Agency in advance. More than 100 companies from 20 sectors made use of this opportunity: the Federal Network Agency always replied with a standard letter.

"This is very unsatisfactory for the companies presumably affected," says lawyer Engel: "After all, according to the scenarios of the Federal Network Agency itself, it is no longer a question of whether there will be a gas shortage, but only when."

Unfortunately, Engel is probably right about that. Because according to the scenarios drawn up by the Federal Network Agency, the collapse of the gas market and the declaration of an emergency level this winter is still an acute danger.

After the complete supply failure of Russia, the authority's "Scenario 1" is relevant. Even if two liquid gas terminals on the German North Sea coast go into operation at the beginning of the year and the industry saves 20 percent of its gas consumption, there would still be a gas shortage with a deficit of 222 terawatt hours from December. In addition, the scenario assumes that Germany saves a total of five percent anyway.

So far, however, the industry has only been able to save more than 20 percent of consumption in the months of July and August. Even if the industry manages to save more than 20 percent, German gas exports would still have to be reduced by 35 percent to avert a shortage. Such a lack of solidarity in the market intervention could, however, have a clearly negative impact on Germany in the European Union.

Nevertheless, there is a small hope: The storages have recently been filled faster than assumed in the scenarios. In addition, more liquid gas terminals could be connected to the grid more quickly in the coming year than was last expected.

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