April 2025

250401

ENERGY CHRONICLE



 
 


According to EU regulations, bidding zones for the electricity market may only contain structural grid bottlenecks if these do not have a negative impact on neighboring zones. The former EEX trading zone had become such a disruptive factor, mainly because of the ring flows it generated, which is why it had to be reduced in size in 2018 to exclude Austria. At the same time, further redrawing of the bidding zones in Germany, France, and Poland was considered as an alternative, but this was not implemented.

Source: ENTSO-E

ENTSO-E proposes further division of the EEX trading zone into five bidding zones

On April 28, the European Network of Transmission System Operators for Electricity (ENTSO-E) proposed a further division of the EEX trading zone into five bidding zones. This proposal is based on a report (PDF) reviewing the bidding zones in France, Germany, Italy, the Netherlands, and Sweden, which was commissioned by the European regulatory authority ACER in August 2022. In this report, the transmission system operators of the countries mentioned evaluated alternative configurations for bidding zones specified by ACER. However, a proposed change was only made for the Germany/Luxembourg bidding zone.

A bidding zone is a geographical area within the electricity market in which electricity can be bought and sold without taking physical grid constraints into account. The review of bidding zones aims to establish optimal configurations for bidding zones in Europe in order to maximize economic efficiency and opportunities for cross-border trade while maintaining security of supply.

In accordance with the methodology specified by ACER for reviewing bidding zones (“Bidding Zone Review”), transmission system operators were asked to evaluate 14 alternative configurations based on 22 criteria divided into four categories (grid security, market efficiency, stability and robustness of the bidding zone, and energy transition). Based on the findings, the bidding zone configurations were then evaluated according to the criterion of “economic efficiency.”

The bidding zone review, as decided by ACER, involved comparing the status quo with four alternative configurations in the case of Germany. The most favorable solution was found to be the five-zone configuration, which is essentially the same as the four-zone solution, but makes the region of Schleswig-Holstein (green) a separate bidding zone:

       2 Zonen               3 Zonen               4 Zonen                5 Zonen

The colored dots mark the network nodes that have been assigned to the respective bidding zones (Enlarge)

German transmission system operators are dissatisfied with the methodology specified by ACER

“The proposal by the transmission system operators for Central Europe emphasizes that this result is based on the methodology defined by ACER for reviewing bidding zones and does not take important additional aspects into account,” according to the ENTSO-E statement. “Therefore, it should not be considered in isolation, but in conjunction with certain considerations that should be thoroughly examined before the final decision on the future BZ configuration by the Member States affected by a split, as they could have a significant impact on the design and results of the bidding zone study conducted by the transmission system operators.”

Back in February, Amprion called for the “preservation of the single bidding zone in the German electricity market"


In Scandinavia, there are two bidding zones for Denmark, four for Sweden, and as many as five for Norway. Only Finland has a single electricity exchange price across the board.

Graphic: ENTSO-E

This peculiar remark suggests that the German transmission system operators were reluctant to arrive at the results now presented and do not agree with the European regulatory authority's guidelines for conducting the “Bidding Zone Review.” However, this comes as no surprise, as Amprion had already called for the “preservation of the uniform bidding zone in the German electricity market” in February. The current proposal by ENTSO-E was already known or at least foreseeable at that time, at least among transmission system operators. As an alternative to further dividing the EEX bidding zone, Amprion had proposed at the time that the costs for “Redispatch 2.0” and the use of reserve power plants be covered by the federal budget in order to relieve the grid fees of the billions of euros that are incurred annually through “grid congestion management” and which burden electricity prices. Since Amprion has a coordinating role among the four German transmission system operators, the other three are likely to share this opinion.

According to the coalition agreement, the new federal government rejects any change

Amprion's appeal to the new federal government did not go unheard. The Union, along with key business circles, has always been of the opinion that the current EEX bidding zone must be maintained despite all the costs borne by electricity consumers until the planned “electricity highways” are finally completed and relieve the grid bottlenecks. And that is why page 33 of the coalition agreement published by the CDU/CSU and SPD on April 9 now states: “We are sticking to a uniform electricity bidding zone” (250403). The CDU/CSU thus prevailed over the Social Democrats, who wanted to at least examine a redrawing of the German electricity trading zone in the “Climate and Energy” negotiating group in order to reduce the billions in costs that the current electricity market design is devouring.

IEA warns Germany against hasty decisions

This course of events was probably also feared by the International Energy Agency (IEA), which presented its report on the energy policy situation in Germany on April 7 (PDF). It referred to the pending review of bidding zones in France, Germany, Italy, the Netherlands, and Sweden, the results of which are expected shortly. As a precautionary measure, it advised the new federal government “not to make any political decisions that would rule out a division of the bidding zones.”

This advice is likely to refer to section 3a of the Electricity Grid Access Ordinance, which since November 2017 has required “guaranteed grid access in the single electricity bidding zone” and which, along with the entire ordinance, will expire at the end of the year (250203). If the new federal government were to risk enacting a new ordinance of this kind, it would be a declaration of war on the EU Commission and also a violation of European law. Since the 2021 ruling of the European Court of Justice (210901) it has been clear that it cannot be left to the sole discretion of an EU government to determine the configuration of the electricity price zones that affect it.

Rather, the decisive factors are the technical realities of the internal electricity market and the EU regulation of June 5, 2019, which stipulates in Article 14 that bidding zone boundaries must be defined with a view to “long-term, structural bottlenecks in the transmission networks.” This means that an electricity price zone can also cover several countries, as was once the case with Germany, Austria, and Luxembourg. However, it may also be sensible and necessary to divide a country into several electricity price zones within its national borders, as was considered ten years ago as an alternative or additional option when Austria split from the EEX bidding zone (160201). Despite its bold declaration of intent in the coalition agreement, the new federal government will therefore have to avoid decreeing a uniform electricity bidding zone for Germany again, as its black-red predecessor did in 2017 with Section 3a of the Electricity Grid Access Ordinance, after it was forced to accept Austria's separation from the EEX bidding zone under pressure from the EU Commission and neighboring countries (171101).

Links (internal)

on the division of bidding zones

on the costs of congestion management

Links (external, no guarantee)

Why are there grid bottlenecks?

The increase in spot market electricity trading is the most important reason, but not the only one

(see above)

Total electricity consumption in Germany has not changed significantly in the 35 years since reunification (see blue curve in Figure 1). Last year, at 522 terawatt hours, it was actually 28 TWh lower than in 1990. So consumption cannot be the reason why grid bottlenecks have become so frequent since the second decade that the costs of so-called bottleneck management have risen 15-fold between 2011 and 2024 (see Figure 2).

The electricity transmission grid has not become smaller, but significantly larger: in 1990, the extra-high voltage grid (380 kV and 220 kV) had a total length of 28,786 kilometers. Today, it is around 37,700 kilometers. It is therefore around a quarter larger. And this has also increased the transmission capacity.

Nevertheless, despite electricity consumption remaining constant or even falling since the second decade, this improved grid structure is increasingly being overwhelmed by electricity flows. As Figure 1 shows, this apparently has to do with the Leipzig electricity exchange “EEX European Energy Exchange,” which was created in 2002 from the merger of two predecessor companies (011008) and began spot market trading at that time. The red curve shows that the traded volume was initially modest at 31 TWh. By 2005, however, it had already exceeded the total renewable energy generation with 86 TWh, and by 2015 it had also surpassed conventional electricity generation with 254 TWh. From 2019 onwards, the spot market volume was even greater than Germany's total gross electricity consumption, reaching a record high of 880 TWh in 2024. A large part of this volume is likely to be attributable to cross-border deliveries or pure transits.

At the same time – see green and gray curves – an ever-increasing share of German electricity consumption was covered by renewable energies, mainly wind and solar power. As wind power and solar power plants fed into the distribution grids, the Federal Network Agency warned in its 2010 monitoring report that this “could lead to temporary grid bottlenecks in distribution grids.” The feed-in locations of the EEG plants would “often not fit the original grid architecture.” A provision known as “feed-in management” in Section 11 of the Renewable Energy Sources Act (EEG) has therefore allowed grid operators since 2009 to “regulate” EEG plants with a capacity of more than 100 kilowatts or to shut them down completely if this measure would otherwise overload the grid capacity (080601).

In the first year after this provision came into force, 73.7 gigawatt hours of wind power were curtailed (99.8 percent of which affected wind turbines) and the operators were compensated with over six million euros in accordance with Section 12 EEG. By 2021, this “outage work” had increased almost eighty-fold to 5,818 gigawatt hours. The compensation due for this increased 134-fold to 807.1 million euros.

Large quantities of wind power were therefore not generated in the first place because the year-on-year increase in electricity trading clogged up the bottlenecks in the grid. Nevertheless, the operators were compensated as if it had been generated. This was acceptable to both the grid operators and the wind turbine operators, because the compensation for the “outage work” was paid from the EEG surcharge, just like the normal feed-in tariffs.


At over four billion euros, the costs of “grid congestion management” peaked in 2022. This was due to the exorbitant rise in gas prices, which also increased the operating costs of gas-fired power plants for “redispatch.” Gas prices have since returned to normal. Nevertheless, grid congestion costs in 2024 were significantly higher than before the gas price crisis.


The sale of EEG electricity on the exchange exacerbated the problems

In 2010, another regulation came into force that exacerbated the grid problems and placed an even greater burden on the EEG surcharge to the detriment of electricity consumers: this was the “Regulation on the Further Development of the Nationwide Compensation Mechanism of the EEG (AusglMechV)”. This regulation eliminated the previous procedure, whereby the quantities of EEG electricity fed into the grid and subsidized by fixed remuneration were allocated to the end distributors and their customers' electricity bills in terms of both quantity and cost. Instead, transmission system operators were now tasked with recording all EEG electricity and selling it on the stock exchange in the previous day's spot market trading. This eliminated the direct link between the EEG feed-in tariff per kilowatt hour and the amounts of electricity generated.

Since then, it has depended solely on daily stock market roulette whether the market price achieved even reaches the level of the feed-in tariff or even becomes negative. In the latter case, transmission system operators even have to pay a surcharge to get rid of the electricity at all. Even during the trial run of the new regulation at the end of 2009, there were several instances of negative prices of up to €500 per megawatt hour and losses in the seven-digit range (100101). Since the new regulation did not take effect until 2010, these losses could not yet be paid for from the EEG surcharge. Instead, they were booked by the transmission system operators under “system services,” which also meant they ended up on end customers' electricity bills.

From 2010 onwards, the transmission system operators thus became the largest electricity traders on the spot market, contributing significantly to the increase in trading volume and thus to a further narrowing of the grid bottlenecks. Their initial market share of around 40 percent then declined again when, from 2012, the “market premium” was introduced as an alternative to fixed feed-in tariffs, which was primarily intended to offer operators of larger EEG plants a greater incentive to engage in “direct marketing” (130201). As a result, the market share of transmission system operators, which had been 38 percent in 2011, fell to 23 percent by 2013. A further amendment to the law then ensured that, from 2016 onwards, conventional feed-in tariffs could only be claimed for existing plants up to 500 kilowatts and new plants could have a maximum rated output of 100 kilowatts (140601). For all other operators of EEG plants, direct marketing via market premiums became mandatory.

In its foreword to the 2011 monitoring report, the Federal Network Agency stated that “the networks have reached the limits of their capacity due to the large number of transport tasks to be fulfilled in recent years and the change in the generation structure.” This no longer applied only to the distribution networks, but above all to the nationwide transmission network: The main problem was transporting the increasingly abundant wind power generated in northern Germany via the extra-high voltage grid to the main consumption centers in the south, because there was too little demand in the north.

For this reason, the “feed-in management” system introduced in 2009 was increasingly combined with conventional “redispatch” to bridge grid bottlenecks. This means that a certain amount of (wind) power that has to be curtailed on one side of the grid bottleneck is newly generated on the other side by gas or coal-fired power plants. The wind power sold on the spot market and then unable to be transported due to grid bottlenecks was therefore not generated in the first place, but was remunerated by the grid operators as “outage work.” On the other side of the bottlenecks, conventional power plants then generated the same amount of electricity. In this way, spot market trading appeared to function just as smoothly as if there were no grid bottlenecks within the German bidding zone. From the exchange's point of view, everything was back on track. The costs of these complex and expensive redispatch procedures did not burden the exchange or its customers, but were passed on to electricity consumers via grid fees.

In this way, real grid bottlenecks are still being virtually bridged today in order to maintain the exchange's fiction of a bottleneck-free grid within the German bidding zone. This is because it is crucial for electricity trading on the spot market that a contracted amount of electricity can be transmitted at the agreed time, regardless of any real obstacles. Neither suppliers nor buyers need to be concerned with how this is technically achieved and how it succeeds despite actual grid bottlenecks. After all, the additional costs for the apparent “bridging” of grid bottlenecks are borne by electricity consumers.

As early as 2011, the Monopolies Commission pointed to the alternative that underlies the current ENTSO-E proposal.


This proposal by the VDE FNN Committee to divide the German electricity market into two or three bidding zones dates back to 2014. The boundaries were drawn up taking into account the grid bottlenecks that existed at the time.

The European electricity market currently comprises a total of 30 countries with 43 bidding zones. Four of these countries have several bidding zones: Denmark (2), Sweden (4), Norway (5), and Italy (6). Germany and Luxembourg, on the other hand, have a joint bidding zone, which also included Austria until 2018. This unique situation arose from the particularly close economic ties between these three countries in the electricity sector, which were not affected by any bottlenecks in cross-border connections. Following the liberalization of the electricity market in Germany (980401) in 1998 and Austria (011005) in 2001, the new Leipzig-based electricity exchange EEX (011008) therefore included both neighboring countries in its bidding zone.

Until then, there had been no significant bottlenecks in the German-Austrian grid area despite the liberalization of the electricity market. However, parallel to the steady increase in electricity trading, the bottleneck-free zone soon came to an end. Added to this was the general problem that with the elimination or “unbundling” of the former integrated electricity supply, overall responsibility for coordinating generation, grid, and consumption had been lost. Even the establishment of a regulatory authority, which was delayed for a long time in Germany, could only change this to a limited extent. A particular problem arose from the fact that the particularly profitable feed-in from wind power is concentrated in northern Germany, but often cannot be transported to the main consumption centers in the south because the necessary grid expansion is progressing too slowly. As early as 2011, the Monopolies Commission had considered it wrong to try to eliminate the grid bottlenecks caused by spot market trading by building “electricity highways”: the better solution, it said, would be to introduce at least two price zones for electricity trading within Germany (110907 and Background). It thus referred to the alternative solution that now forms the basis of the ENTSO-E proposal to divide the EEX trading zone into five separate bidding zones (see above).

Nevertheless, the relevant political and economic circles have so far insisted that maintaining a uniform bidding zone throughout Germany would be the best solution. When twelve renowned energy economists published an article entitled “The German electricity market needs local prices” in July last year, a dozen leading associations reacted quite allergically with a “Joint appeal by leading trade associations to maintain the German electricity bidding zone.” These included the most important electricity industry associations, such as BDEW, VKU, VIK, and BEE. They were joined by industry associations such as BDI, VDA, VCI, and ZVEI. A little later, the three major DGB trade unions IGM, IGBCE, and Verdi also joined the signatories (240704).