November 2025 |
251104 |
ENERGY CHRONICLE |
On November 6, the Bundestag passed a revision of the Carbon Dioxide Storage Act, which came into force 13 years ago and is usually referred to by its English abbreviation, CCS. The main purpose of the new version is to enable the storage, transport, and permanent underground storage of climate-damaging CO2 emissions that are unavoidable in some industrial processes, such as lime and cement production or waste incineration. In principle, however, CO2 emissions that could be avoided can also be “disposed of” in this way in geologically suitable formations on land or under the sea. This applies in particular to electricity generation in gas-fired power plants, which could be made climate-neutral by switching from natural gas to “green” hydrogen as a fuel.
The revised CCS Act only excludes coal-fired power plants from its scope. And even that only applies to domestic plants, which are to be decommissioned by 2038 anyway. In contrast, operators of foreign coal-fired power plants are allowed to make unrestricted use of the infrastructure planned in Germany for the transport and storage of carbon dioxide in offshore long-term storage facilities under the North Sea (underground storage on land would only be possible under the relevant laws of the respective federal states). According to the explanatory memorandum to the law, this is intended to “avoid influencing the choice of other European Union member states regarding the use of their energy resources, their decision between different energy sources, and the general structure of their energy supply.”
The new “Act Amending the Carbon Dioxide Storage Act” reforms the “Act on the Demonstration of Permanent Carbon Dioxide Storage,” which was approved by parliament in July 2011 (110703), but then had to be amended at the request of the Bundesrat (110901) so that it could actually only be used for research purposes (120604). This made the law uninteresting to coal-fired power plant operators, who were the driving lobby behind this project of the black-yellow government at the time, and it gained no practical significance.
This time, however, the Bundesrat approved the “Act Amending the Carbon Dioxide Storage Act” on November 21, even though in its statement on the draft it had “urgently” requested that not only coal-fired power plants but also natural gas-fired power plants be excluded from using the planned technology for the capture, transport, and underground storage of greenhouse gases. “The federal government rejects the proposal,” was the terse response on September 26. “According to the federal government's draft bill, a legal exclusion is only planned for coal, not for natural gas. An exclusion for coal is to be implemented because the end of its use is legally stipulated by the coal phase-out. The usability of CCS for gas-fired power plants is being examined as part of the power plant strategy.”
This review will certainly not be the end of the matter. In fact, the natural gas lobby is playing a similar role in the revision and expansion of the law today as the coal-fired power producers did 15 years ago. There is therefore every reason to fear that the revised CCS law will hinder and delay the necessary displacement and replacement of natural gas by renewable energies. This became clear, for example, when Federal Minister of Economics Katherina Reiche announced plans to put out to tender the construction of gas-fired power plants with a capacity of 20 gigawatts to support green electricity generation, without even considering their possible conversion to hydrogen operation. Only when she noticed that this was not well received did she at least mention a “prospect of conversion to hydrogen.” . Yet it is precisely these types of gas-fired power plants that would be ideally suited for grid control, powered by electrolytically produced hydrogen from surplus wind and solar power generation, which is then converted back into electricity at a later time to compensate for periods with lower green power generation.
The natural gas industry would not need to fear such competition from “green” hydrogen, as this climate-friendly fuel will remain significantly more expensive for the time being and will be available in far smaller quantities than “blue” hydrogen, which can be obtained from natural gas, oil, or coal. The greenhouse gases produced during this conversion can now be separated and sunk into pipelines under the North Sea, just as they are when natural gas is used directly as a fuel. But the current process is, of course, more convenient and cheaper. It therefore remains an open question how the natural gas industry actually intends to fill the nationwide hydrogen network, which it initially presented as a “vision” in January 2020 (200106) and then specified in November 2023 as an application for the establishment of a German “hydrogen core network” (231104).
Before this hydrogen network is built or existing natural gas pipelines are converted, pipelines are now more likely to be built to transport greenhouse gases from industries covered by the Emissions Trading Act to the North Sea. As announced by the Federal Cartel Office on August 5, Open Grid Europe GmbH (OGE) – the operator of the largest gas transmission network in western Germany – is planning to build a CO2 pipeline in cooperation with the eastern German gas transmission network operator ONTRAS Gastransport GmbH (ONTRAS) and another CO2 pipeline in cooperation with the Belgian company Fluxys. From a competition perspective, the authority has no fundamental objections to either cooperation project.
In the cooperation project between OGE and Fluxys, OGE plans to build a pipeline system from western and southern Germany to the German-Belgian border. From there, Fluxys plans to build a CO2 transit pipeline through Belgium to Zeebrugge. Existing natural gas pipelines cannot be repurposed for CO2 transport. Therefore, new pipelines must be built. In both projects, this will be done largely along existing natural gas routes of the respective transmission system operators.
The Federal Cartel Office noted with some reservation: " If demand for CO2 transport services increases significantly in the future, competing pipeline projects would also be conceivable, meaning that new projects of this magnitude would then have to be examined more closely under antitrust law.“
The current revision of the CCS Act was already planned by the traffic light coalition government (240201, 230408). However, most environmental associations continue to reject it. A year ago, Greenpeace Germany presented a 50-page critique of these plans (PDF) and, in its statement on the draft law (PDF), once again emphasized that this was a “mistake” that threatened to “prolong fossil fuel business models.”