German industry therefore strongly recommends extending the existing AbLaV by one year until an adequate successor regulation has been developed and implemented. Without an extension of the AbLaV, comparable measures by industry to support the system balance would no longer be possible starting in July 2022. It would be inappropriate and, moreover, risky to do without the flexibility that companies have provided thus far.

Russia’s invasion of Ukraine and the resulting uncertainty regarding European and German energy availability make every additional tool indispensable. The events since February 2022 have further exacerbated the already tense situation on the energy markets and also increased the risk to system stability. If system stability can no longer be maintained, forced outages are likely. This would be disastrous for Germany as an industrial hub and a catastrophe for our companies. Especially in this situation, all available tools are needed—there must be no regulatory gaps.

Industrial flexibility: a key tool for system stability and security of supply

The federal government rightly attributes an important role to industrial flexibility in the future energy system. Furthermore, interruptible loads are already an important tool for safeguarding system stability today: According to a report by the Federal Network Agency, a total of 259 calls for interruptible loads took place between 2017 and 2020. Of these, 253 were made to support the system balance, and six were due to congestion-related reasons. In addition, there were another 61 calls in 2021 and 2022. Most recently, in early April 2022, the AbLaV particularly clearly demonstrated its crucial importance for system stability: Between 11 a.m. and 1 p.m., nearly all available interruptible loads were activated to compensate for imbalances in the system balance caused by deviations from weather forecasts. Without the use of available interruptible loads, system stability would consequently be severely compromised.

Joint Industry Position

The joint industry position was developed under the leadership of the German Chemical Industry Association, the German Metal Industry Association, and the German Association of Industrial Energy and Power Companies.