Die glorreichen Sieben: Wirksame Alternativen zum Redispatch-Vorbehalt – Bundesverband Neue

According to a new analysis released today by the Bundesverband Neue Energiewirtschaft (bne), the current legislative path regarding grid management is not only technically flawed but creates perverse market incentives. The bne warns that the proposal, which allows grid operators to curtail renewable energy without the traditional compensation under specific conditions, threatens to drive up system costs, deter investors, and paradoxically benefit the very grid operators that have lobbied for it over the years—most notably E.ON.

Main Facts: The Crisis of Grid Synchronization

The "Redispatch-Vorbehalt" is intended to manage grid congestion by allowing operators to preemptively limit the amount of electricity wind and solar farms can feed into the grid. While the government argues this is a necessary "emergency brake" to prevent grid collapse while infrastructure catches up to generation, the energy industry sees it as a shift of systemic risk onto private investors.

The bne’s analysis highlights three primary concerns:

1. Investment Risk: By making the right to feed electricity into the grid conditional and uncompensated, the policy makes wind and solar projects significantly harder to finance. Banks view the "uncalculable risk" of redispatch as a threat to debt serviceability.
2. Incentive Distortion: The bne alleges that the current structure favors large incumbent distribution system operators (DSOs). E.ON, which manages a vast portion of Germany’s regional grids, stands to benefit from a system that reduces their liability for delayed grid expansion.
3. System Efficiency: Instead of using storage or digital management to balance the grid, the policy defaults to "turning off" green energy, leading to higher overall costs for consumers as expensive gas-fired plants are often used to balance the resulting fluctuations elsewhere.

Chronology: From "Energiewende" to Grid Gridlock

To understand the current friction, one must look at the evolution of German energy policy over the last decade.

• 2017–2021: Rapid expansion of wind and solar began to outpace the construction of high-voltage "electricity highways" (like SuedLink) and regional distribution upgrades. Redispatch costs—the price paid to stabilize the grid—began to climb into the billions of euros annually.
• 2023: The "Easter Package" and subsequent reforms accelerated renewable targets, aiming for 80% of electricity from renewables by 2030. However, the physical grid remained the "Achilles’ heel" of the strategy.
• 2024–2025: As grid congestion worsened, the concept of the "Redispatch-Vorbehalt" gained traction within the Ministry of Economic Affairs and Climate Action (BMWK). Grid operators argued that they could not be held financially responsible for every kilowatt-hour of lost production in an increasingly complex, decentralized system.
• Early 2026: The coalition government (SPD, Greens, and FDP) faced internal strife over the implementation of the "Grid Connection Package." While the Greens pushed for storage-first solutions, elements of the coalition favored the "reservation" clause to keep grid fees from skyrocketing in the short term.
• October 7, 2026: The bne releases its "Glorious Seven" proposal, marking a definitive break between the renewable industry and the current government trajectory, supported by heavyweight players like RWE who fear for the "bankability" of future offshore and onshore projects.

Supporting Data: The "Glorious Seven" Solutions

The bne argues that the "Redispatch-Vorbehalt" is an "unnecessary apple of discord." Instead of punitive curtailment, the association has proposed seven concrete pillars to synchronize generation and grid expansion intelligently.

1. Guaranteed Grid Access for "Freedom Energies"

The bne asserts that investors need a reliable, statutory right to grid connection. This right should not be replaced by "arbitrary individual contracts" with uncalculable risks. Crucially, this must extend to energy storage systems that share a connection point with renewable plants, ensuring that "Freedom Energies"—a term popularized to describe the security benefits of renewables—are not stifled by bureaucracy.

2. Peak Shaving as an Enabler

"Spitzenkappung" (peak shaving) should be used as a tool for growth, not a restriction. If a wind farm agrees to limit its top 5% of peak production, that "freed up" capacity must be legally allocated to new projects or storage. The bne demands that grid operators be forced to include these reduced injection levels in their binding grid planning.

3. Prioritizing Intermediate Storage

Current regulations often result in wind farms being throttled while nearby battery storage remains empty. The bne proposes that during redispatch events, electricity must flow into storage first. Furthermore, storage units at renewable sites must be allowed to take in grid power (e.g., excess wind from other nearby sites), a move that maximizes existing infrastructure and aligns with the "MiSpeL" (Multi-use Storage) regulatory framework.

4. Standardized Construction Cost Subsidies (BKZ)

Predictability is the currency of the energy transition. The bne recommends nationwide, non-discriminatory standards for construction cost subsidies (Baukostenzuschüsse). Currently, these costs can "stack" on top of other fees, making projects unviable. The bne argues that these subsidies should be used as a "signpost" to guide projects to where the grid is strongest, rather than a "stop sign" for all new development.

5. Radical Transparency

"Transparency creates trust," the bne report states. Project planners currently operate in a "black box," often unaware of where grid capacity actually exists. The bne calls for a digital map of all available and reserved capacities, including the utilization of individual switching fields in substations. This would prevent grid operators from claiming "full capacity" when technical solutions like "overbuilding" are possible.

6. Private Grid Expansion (The 24-Month Rule)

If a grid operator cannot eliminate a bottleneck within 24 months of a project’s approval, the bne suggests that project developers should be allowed to build or pre-finance the necessary grid infrastructure themselves. These costs would then be reimbursed or offset against future grid fees. This "right to build" would break the monopoly-induced delays currently hampering the sector.

7. Legal Right to Flexible Connections in the EEG

The power imbalance between small developers and massive grid operators is a major hurdle. The bne calls for clear rules within the Renewable Energy Act (EEG) that grant developers a "right to overbuild" and establish binding usage rules for shared connection points.

Official Responses: A Divided Front

The bne’s critique has resonated across the spectrum, creating an unusual alliance.

Robert Busch, Managing Director of bne, was blunt in his assessment: "A grid bottleneck is, first and foremost, a task for the grid operator. Anyone who wants to synchronize generation and grids must digitize the grids, expand them, and let storage do its job. Our seven proposals show how a suitable legal framework can be created."

RWE, Germany’s largest power producer, has echoed these concerns, noting that the "Redispatch-Vorbehalt" creates a "risk premium" on capital. "If we cannot calculate the revenue of a wind farm because the grid operator can turn it off at will without compensation, the cost of capital will rise, and those costs will eventually be passed on to the consumer," a spokesperson for RWE stated.

E.ON, the target of much of the bne’s criticism regarding "perverse incentives," maintains that the "Redispatch-Vorbehalt" is a pragmatic solution to an extraordinary physical challenge. In previous statements, E.ON representatives have argued that the sheer speed of renewable expansion makes it physically impossible to build copper wires fast enough, necessitating "smart management" (which critics call curtailment).

The German Ministry of Economic Affairs (BMWK) has yet to formally respond to the "Glorious Seven" proposal, but sources within the coalition suggest that the FDP (Free Democrats) may be open to the bne’s calls for private grid financing and increased transparency, while the Greens are focusing on the storage-integration aspects.

Implications: What is at Stake?

The resolution of the "Redispatch-Vorbehalt" debate will determine the trajectory of the German energy market for the next decade.

Economic Implications: If the bne’s warnings are correct, the current policy will lead to a "stacking of risks" that increases the Levelized Cost of Energy (LCOE). Higher financing costs for developers mean higher bids in EEG auctions, ultimately raising the "EEG-Umlage" or requiring more taxpayer subsidies to meet climate goals.

Technical Implications: The bne’s proposals push for a "Digital-First" grid. By prioritizing storage and peak shaving, Germany could potentially double its renewable integration capacity without digging a single new trench. However, this requires a fundamental shift in how DSOs (Distribution System Operators) operate—moving from "passive wire owners" to "active system orchestrators."

Political Implications: For the Scholz administration, the grid crisis is a test of the "Deutschland-Geschwindigkeit" (Germany-speed) promised at the start of the term. If the "Redispatch-Vorbehalt" becomes a permanent fixture, it may be seen as a surrender to the limitations of the old grid, rather than a bridge to a new one.

As the Bundestag prepares to debate the latest version of the Grid Connection Package, the "Glorious Seven" proposal serves as a roadmap for an alternative path—one where the "Freedom Energies" are not held hostage by the very infrastructure meant to carry them. The coming months will decide whether Germany’s energy transition remains an investment magnet or becomes a cautionary tale of regulatory mismanagement.