Redispatch-Vorbehalt: bne-Analyse zeigt Fehlanreiz – E.ON-Netzgesellschaften könnten besonders profitieren –

The bne’s findings suggest that this regulatory loophole not only shifts the financial burden of grid bottlenecks onto renewable energy investors but also undermines the Federal Network Agency’s (Bundesnetzagentur) efforts to incentivize grid efficiency. At the heart of the controversy is E.ON, a corporate giant that the bne claims has spent years lobbying for this specific provision to protect its bottom line at the expense of the broader energy transition (Energiewende).

I. Main Facts: The Redispatch-Vorbehalt and the Shifting Burden of Grid Congestion

In the complex architecture of the German power grid, "redispatch" is a critical intervention tool. When the amount of electricity generated—primarily from wind and solar farms—exceeds the capacity of the power lines to transport it, grid operators must intervene. They order certain plants to power down (curtailment) while ramping up others elsewhere. Traditionally, the law has been clear: if a renewable energy plant is forced to stop producing due to a grid bottleneck, the operator of that plant is entitled to financial compensation for the lost revenue.

These compensation costs have historically been passed on to consumers through grid fees (Netzentgelte). However, as the volume of curtailed green energy has skyrocketed, so too have the costs, reaching billions of euros annually.

The Mechanism of the "Vorbehalt"

The newly introduced "Redispatch-Vorbehalt" fundamentally alters this logic for new installations. Under this provision, new renewable energy plants may face restricted or entirely eliminated compensation when they are curtailed due to grid congestion.

From the perspective of the grid operator, this is a financial boon. By not having to pay compensation, the "costs" of the bottleneck vanish from their balance sheets. However, the physical reality remains unchanged: the grid is still congested, and clean energy is still being wasted. The bne argues that this creates a "paper efficiency" where grid operators appear to be managing congestion effectively, while in reality, they are simply externalizing the costs of their inadequate infrastructure onto the private sector.

Diluting the Federal Network Agency’s Pressure

This shift directly conflicts with recent mandates from the Bundesnetzagentur (BNetzA). The regulator has sought to include redispatch costs in the "efficiency benchmarking" of grid operators. The logic was simple: if a grid operator has high redispatch costs, it indicates a failure to expand the grid or optimize management. By penalizing these costs, the BNetzA intended to force operators to invest in cables, transformers, and digital optimization.

The Redispatch-Vorbehalt breaks this incentive chain. If the costs of congestion are shifted to the plant owners, they no longer appear in the grid operator’s efficiency audit. Consequently, the operator faces less regulatory pressure to fix the underlying problem.

II. Chronology: The Long Road of Lobbying

The implementation of the Redispatch-Vorbehalt did not happen in a vacuum. The bne’s report meticulously traces the origin of this policy back to 2021, painting a picture of a multi-year lobbying effort led by E.ON and its subsidiaries.

• Late 2021: The first documented proposal for a "Redispatch-Vorbehalt" surfaces from E.DIS, a subsidiary of E.ON. At the time, the proposal was framed as a necessary measure to keep grid fees stable for consumers.
• 2022 – 2023: A joint white paper is published by E.DIS and the consultancy E-Bridge, refining the technical arguments for why new plants should bear the risk of grid connection in "overburdened" areas.
• The Lobby Register: During this period, E.ON officially enters the Redispatch-Vorbehalt into the German Lobby Register as a primary policy goal. The demand is presented as a way to "synchronize" grid expansion with the rollout of renewables.
• Leadership Support: Westenergie, another E.ON subsidiary, joins the fray. Under the leadership of then-CEO Katherina Reiche, the company vocally supports the provision. Concurrently, E.ON leadership begins a public campaign against the BNetzA’s plan to include redispatch costs in efficiency comparisons, arguing that grid operators should not be penalized for "external factors" beyond their control.
• 2024 – 2025: Despite warnings from renewable energy associations, the provision gains traction in legislative drafts, eventually becoming a centerpiece of the regulatory framework for new grid connections.

III. Supporting Data: The Concentration of Congestion

The most striking revelation in the bne’s report is the sheer concentration of redispatch activity within E.ON’s territory. The data suggests that E.ON is not just a passive participant in the grid crisis, but the primary beneficiary of any rule that reduces redispatch liabilities.

The 73% Discrepancy

According to the bne analysis, 73 percent of all redispatch volumes in the German distribution grid occur within E.ON-affiliated grid companies. However, these same companies only account for 26.1 percent of all grid connection points in the country.

This massive imbalance highlights a systemic issue. E.ON’s grids are disproportionately congested compared to their size and number of customers. Under the old rules, E.ON would be under immense pressure from the BNetzA to rectify these bottlenecks or face severe financial penalties via the efficiency benchmark. Under the Redispatch-Vorbehalt, E.ON can effectively "hide" a significant portion of these inefficiencies by simply not paying the new plants they curtail.

Financial Potential

The bne estimates that by shifting the risk to new plants, E.ON could save hundreds of millions of euros in potential penalties and compensation payments over the next decade. This creates a perverse incentive: the more the grid is congested, the more the operator benefits from the "Vorbehalt" because it prevents those congestion costs from impacting their regulatory profit margins.

IV. Official Responses and Industry Backlash

The release of the report has triggered a wave of reactions across the energy sector, highlighting a deep divide between "old energy" infrastructure providers and "new energy" generators.

The bne’s Stance: "Energy Policy for the Whole Country"

Robert Busch, the CEO of bne, did not mince words in his assessment of the situation. He characterized the Redispatch-Vorbehalt as a capitulation of public interest to corporate lobbying.

"The federal government must make energy policy for the whole country—and must not let itself be harnessed to the cart of individual corporations," Busch stated. "We solve the grid crisis by removing bottlenecks, not by shifting their costs onto renewables. The Redispatch-Vorbehalt sets exactly the wrong incentive: the grid operator becomes more efficient on paper, even though the bottleneck remains."

The bne is calling for an immediate repeal of the provision, arguing that it acts as a "poison pill" for the investment climate in wind and solar power.

E.ON and Grid Operators: A Question of Cost-Stability

While E.ON has not issued a direct rebuttal to the specific percentages cited in the bne report at the time of writing, the company’s historical position has been that the grid cannot keep pace with the "unbridled" expansion of renewables. Their argument rests on the idea of "socializing" costs: if grid operators have to pay for every megawatt-hour curtailed, grid fees for households and industry will skyrocket. They frame the Redispatch-Vorbehalt as a "fairness" measure that ensures new actors in the market share the responsibility for the physical limits of the infrastructure.

The Regulator’s Dilemma

The Bundesnetzagentur finds itself in a difficult position. On one hand, it wants to maintain high pressure on grid operators to modernize. On the other, it is wary of allowing grid fees to become a political liability. Critics of the BNetzA suggest that by allowing the Redispatch-Vorbehalt, the agency has effectively handed a "get out of jail free" card to the very companies it is supposed to be regulating.

V. Implications: A Threat to the 2030 Targets?

The fallout from the Redispatch-Vorbehalt extends far beyond the balance sheets of E.ON and wind farm developers. It poses a fundamental threat to Germany’s ability to meet its climate targets and its goal of 80% renewable electricity by 2030.

1. The Investment Chill

For investors, the "Vorbehalt" introduces a massive variable of risk. When calculating the bankability of a new wind farm, the "curtailment risk" was previously mitigated by the guarantee of compensation. Now, an investor must factor in the possibility that their plant will be turned off for significant periods with zero revenue. This increases the cost of capital for green projects, making them more expensive and harder to finance.

2. Slowing Grid Modernization

If grid operators can maintain high efficiency ratings without actually fixing their grids, the pace of modernization will inevitably slow. The bne argues that instead of "risk-shifting," the focus should be on "risk-elimination" through:

• Accelerated Grid Expansion: Faster permitting for new high-voltage and medium-voltage lines.
• Digitalization: Implementing smart grid technologies that allow for higher utilization of existing cables (e.g., weather-dependent line operation).
• Storage Integration: Incentivizing large-scale battery storage to soak up excess energy at the source of the bottleneck.

3. Distorting the Merit Order

By curtailing renewables without compensation, the market signal is distorted. In a healthy market, the cheapest energy (renewables) should flow first. The Redispatch-Vorbehalt allows the grid’s physical failures to dictate the market, often resulting in more expensive, fossil-fuel-based "replacement" power being used elsewhere to balance the grid, ultimately driving up the total cost of the system.

Conclusion: A Call for Reform

The bne’s analysis has pulled back the curtain on what it describes as a regulatory sleight of hand. By allowing E.ON and other grid operators to "hide" the costs of grid congestion, the German government may be saving pennies on grid fees today while spending euros on a stalled energy transition tomorrow.

As the 2026 legislative session continues, the pressure on the Ministry for Economic Affairs and Climate Action (BMWK) to address this loophole is mounting. The message from the "innovators" is clear: the only way out of the grid crisis is through the grid—not through accounting tricks that favor the incumbents of the past over the generators of the future.