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TransnetBW GmbH

TransnetBW operates the high-voltage electricity transmission grid in the German state of Baden-Württemberg.

Lobbying Activity

Meeting with Christian Ehler (Member of the European Parliament) and EnBW Energie Baden-Württemberg AG and

12 Dec 2025 · Energiepolitik

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

19 Nov 2025 · Grids Package

Meeting with Andrea Wechsler (Member of the European Parliament) and FuelsEurope

17 Oct 2025 · Energy Policy

Meeting with Andreas Glück (Member of the European Parliament) and Air Products

16 Oct 2025 · Energy Policy

Meeting with Michael Hager (Cabinet of Commissioner Valdis Dombrovskis)

7 Oct 2025 · Competitiveness of the energy sector

Meeting with Bruno Tobback (Member of the European Parliament) and IBERDROLA

1 Oct 2025 · The announced EU Grids Package

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

26 Sept 2025 · Energy policy

Meeting with Andreas Glück (Member of the European Parliament)

20 May 2025 · Industry and Energy Policy

Meeting with Joachim Balke (Head of Unit Energy)

16 May 2025 · follow-up study, "Adequacy 2050" on the study "European Energy System 2050" published 2 years ago

Meeting with Thomas Pellerin-Carlin (Member of the European Parliament)

15 May 2025 · Energy security

Meeting with Joaquim Nunes De Almeida (Director Internal Market, Industry, Entrepreneurship and SMEs)

15 May 2025 · EU power system and climate policy

Meeting with Andrea Wechsler (Member of the European Parliament)

28 Apr 2025 · EU energy and industry policy

Meeting with Andrea Wechsler (Member of the European Parliament)

6 Mar 2025 · EU Energy and Industry Policy

Meeting with Jens Geier (Member of the European Parliament)

6 Mar 2025 · Exchange on Grid action Plan

Meeting with Andreas Glück (Member of the European Parliament)

4 Mar 2025 · Climate and Energy Policy

Meeting with Anna Stürgkh (Member of the European Parliament, Rapporteur)

12 Feb 2025 · EU Electricity Grids

Meeting with Jens Geier (Member of the European Parliament)

23 Jan 2025 · Exchange on the energy market bidding zone review

Meeting with Christian Ehler (Member of the European Parliament)

23 Jan 2025 · European Resourcy Adequacy Assessment

Meeting with Angelika Niebler (Member of the European Parliament)

17 Jan 2025 · Electricity Market

Meeting with Michael Bloss (Member of the European Parliament)

8 Jan 2025 · Austausch Industriepolitik

Meeting with Christian Ehler (Member of the European Parliament) and EPIA SolarPower Europe and

13 Dec 2024 · Energy policy

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

6 Dec 2024 · Energiepolitik

Meeting with Andreas Glück (Member of the European Parliament)

5 Dec 2024 · Energie

Meeting with Jens Geier (Member of the European Parliament)

4 Dec 2024 · Exchange on the Grid Action Plan

Meeting with Andrea Wechsler (Member of the European Parliament) and NKT A/S and Unternehmer Baden-Württemberg e.V.

24 Oct 2024 · EU Energy and Industry Policy

Meeting with Norbert Lins (Member of the European Parliament)

8 Oct 2024 · Europas Energiesystem der Zukunft

Meeting with Andrea Wechsler (Member of the European Parliament) and Wärtsilä Corporation and Negative Emissions Platform

17 Sept 2024 · EU Energy and Industry Policy

Meeting with Christian Ehler (Member of the European Parliament) and RWE AG and

13 Sept 2024 · Energiepolitik - allgemein

Meeting with Andrea Wechsler (Member of the European Parliament)

22 Jul 2024 · EU Energy Policy

Meeting with Andreas Glück (Member of the European Parliament)

16 Jul 2024 · Energy and Climate Policy

Meeting with Andreas Glück (Member of the European Parliament)

6 Mar 2024 · Energie-Politik

Meeting with Christian Ehler (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

26 Jan 2024 · Energiepolitik allgemein

Meeting with Jens Geier (Member of the European Parliament) and BDEW Bundesverband der Energie- und Wasserwirtschaft e. V. and

12 Jan 2024 · Exchange on industrial and energy policy

TransnetBW Urges EU to Broaden Net-Zero Technology Definition

12 Jun 2023
Topic — This consultation proposes framework measures to strengthen Europe's net-zero technology manufacturing ecosystem.
Message — The operator wants the EU to remove technology readiness level requirements. They also request aligning permit timelines with existing law and simplifying public procurement.123
Why — Broadening the scope would help the operator overcome supply chain bottlenecks.4
Impact — Producers of polluting SF6 gases face reduced demand as cleaner alternatives receive priority.5
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TransnetBW Opposes Mandatory Virtual Hubs and Offshore Generation Subsidies

17 May 2023
Topic — The EU is reforming electricity market design to improve resilience and energy transition.
Message — TransnetBW urges the Commission to preserve current spot markets and avoid mandatory regional virtual hubs. They propose a faster, technology-neutral concept for capacity investments instead of traditional mechanisms. Additionally, they insist that congestion income should not subsidize offshore generation.12
Why — This approach prevents significant financial risks for TSOs and avoids unproven, disruptive models.3
Impact — Offshore wind generators would lose a proposed compensation mechanism funded by grid congestion income.4
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Meeting with Michael Bloss (Member of the European Parliament)

28 Apr 2023 · Strommarktdesign

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

On 16 July, the European Commission opened a public consultation on its review of the Renewable Energy Directive (RED). TransnetBW welcomes the opportunity to provide below its views on several of the proposals. In summary our comments relate to the following aspects: With regards to new Art 20a(1), the provision of estimated renewable energy sources (RES) generation data is already widespread among European TSOs. However, such data can derive from estimates or calculations. This would particularly be true for the provision of data on the greenhouse gas content. In consequence, it is important, the legal framework frees TSOs of liability in case of estimation or calculation errors for such data. We fully support the integration of small and mobile systems into ancillary services markets as stipulatd by new Art 20a(4). Where, for technical reasons, a minimum size threshold is needed for the direct participation of such units in these markets, the market participation through aggregation should remain an option. Hybrid offshore assets, as referred to by Recital 8 are transmission assets that combine both functions of connecting different bidding zones or countries, and connecting the wind parks to shore. Hybrid offshore assets are not a combination of transmission and generation assets. This would risk conflicts with unbundling rules, which is why Recital 8 should be corrected. We fully support the European Commission’s proposal for Member States to define 2050 offshore RES targets per sea basin with intermediate steps for 2030, 2040 as suggested in new Art 9(7). As Offshore RES will have a significant impact on the European power systems, these targets should be defined in coordination with TSOs. Green hydrogen, and other renewable fuels of non-biological origin (RFNBOs) as referred to in Recital 22, is key for reaching decarbonisation targets. However, at this point in time, requirements such as “additionality” and “temporality” would negatively impact the urgently needed increase in hydrogen production and the deployment of RES. We recommend for Article 19(7) to include a requirement for ‘timestamping’ of Guarantees of Origin (GOs). This would not only enable more transparency in the trade of renewable certificates but it would also facilitate the push towards an enhanced GO-system based on hourly or quarter-hourly matching. Likewise, a Guarantee of Origin should have geographic attributes and the standard unit of production should be reconsidered.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

On 16 July, the European Commission opened a public consultation on its review of the Energy Efficiency Directive (EED). TransnetBW considers energy efficiency as a key driver to reach the EU’s energy and climate policy objectives for 2030 and beyond. The European power systems will play a decisive role in supporting and enabling the achievement of these ambitions. In this context, TransnetBW welcomes the opportunity to provide its views on several of the proposals. In summary The Energy Efficiency First principle must take fully into account aspects such as system reliability, RES integration and market integration. Art 25 should thus be clear about such interpretation of the principle rather than merely focussing on the reduction of energy consumption. Moreover, cost-benefit methodologies assessing energy efficiency should be developed jointly by TSOs and NRAs. Article 25.3 must not impose the reduction of losses as the driving principle for an efficient development and operation of the grid. Losses at transmission level are of technical nature and are thus an inherent part of the transmission system. TSOs have close to no control over such losses, which are likely to increase in absolute terms as a result of the energy transition and market integration. Article 25.3 should therefore rather focus on the overall efficiency of the energy system. The reporting of such losses needs to remain practicable. This is particularly relevant with regards to the requirement for TSOs to ‘map’ transmission losses. Since transmission losses are not a control variable that TSOs can determine, the concept of ‘avoidable losses’, as referred to in Art 25.3 is misconceived in the context of the transmission level and should not have application. However, if such a concept is indispensable, it should be defined jointly by TSOs and NRAs, carefully taking into consideration potential effects on the transmission system and its operations. Energy efficiency and sustainability criteria are to be taken into account by TSOs in procurement contracts. Some flexibility in the application of the requirements is needed in case supply markets are too tight and regulatory frameworks should take potentially higher costs into account. The extension of the concept of ‘obligated parties’ to TSOs as proposed by articles 2.17 and 9.2 risks conflicting with TSOs neutrality requirement towards all market participants. This addition should thus be deleted. For a more detailed account, please consider our response document attached.
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Response to Revision of the guidelines for trans-European Energy infrastructure

8 Mar 2021

TransnetBW welcomes the opportunity to provide feedback to the proposed revision of the regulation on guidelines for trans-European energy infrastructure (TEN-E). This paper reflects our current state of analysis of the revision. Our main observations relate to the following aspects: / Cross-border cost allocations (CBCAs, Article 16) should be a measure of last resort and applied only when a number of conditions are met: The proposed CBCA mechanism poses financial risks to TSOs. Therefore, a negotiated voluntary cost-sharing solution should stay the default approach for project financing between respective countries of hosting project promoters. / Similarly, we are concerned about new and wide-ranging cost-sharing principles for offshore development (Article 15). The proposals lack clarity, while their financial implications could be significantly more important than those subject to Art 16. / Onshore and offshore grid planning has to be done in a synchronized, holistic process (Art 14). Since the offshore and onshore transmission infrastructure is interconnected and managed as one network, it is not appropriate to spilt the planning process in two separate process with two different time horizons as currently proposed. / The concept of “Comprehensive Decisions” (Article 8.3) poses a critical risk for TSOs in Germany as it will likely result in delays to the permit-granting process. As this is an unintended consequence of the proposal, it should be amended or removed. / The proposed update to the TYNDP Scenario process (Article 12) is adding complexity, reducing efficiency and lacking clarity as to the split of responsibilities. This may make it even harder for stakeholders to follow the scenario-building process. Instead, the suggested framework guideline could be replaced by an annex to the regulation. / Some of the proposed requirements for transparency and public participation (Article 9, Annex VI) are overly prescriptive and could result in unreasonable or double reporting. To avoid that they add unnecessary red tape and thus make the PCI-label unattractive, they should not be applicable if similar requirements are already in place at national or regional level. / The identification of infrastructure gaps (Article 13) should not discriminate between infrastructure and non-infrastructure solutions when applying the “efficiency first principle”. We fully agree that the efficiency first principle should be applied in this process. By no means, however, should it be taken for granted that “non-infrastructure based solutions”, which are not defined in the regulation, are always more efficient than infrastructure-based solutions. / As regards Article 4, we would like to re-emphasise the need to streamline the PCI process for mature projects (i.e. projects under construction or in permitting) and are demonstrating steady and concrete progress, as per their implementation plan. Such projects should be automatically re-confirmed in the future PCI lists until their commissioning without imposing re-application by project promoters. / Finally, the requirements for CBA data to be made public by default (Article 11), may be problematic due to differing confidentiality requirements across different Member States. Inconsistent data quality and thus misleading data across the EU might be the result. For a comprehensive review of our comments, please access our uploaded PDF-paper.
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Response to Climate Law

6 Feb 2020

TransnetBW strongly supports the EC’s plan to introduce a European climate law, while also stressing the need to put security of supply at the center of the discussion around the future of our energy system. Putting the objective of climate neutrality into binding legislation would help to communicate a definitive, irreversible commitment towards this goal and would put more pressure on the timely implementation of all the measures necessary to realize it. Transmission grids are already playing a major role for delivering the energy transition, as they are balancing the geographically concentrated RES production with often far away consumption centers. More ambitious CO2 emission reduction targets will continue to push more and more renewables into our system. This will also put more pressure on the transmission grids and enhance the need for the already agreed upon grid expansion measures that are vital for a climate-neutral electricity supply without jeopardizing security of supply. A consensus has emerged around the fact that full decarbonisation cannot result from electrification alone and that a mixture of different solutions, energy carriers, flexibilities and an interlinkage of energy sectors will have to come together in order to get to net zero emissions. Still, it is likely that the demand for electricity from renewable sources will continue to rise. In the EC’s long term strategy, electricity is projected to more than double its share in the overall energy mix until 2050. Recent publications of several sectors of the industry have shown that the decarbonisation of key sectors (like steel or chemical industries) will require massive additional capacities in terms of renewable electricity. If climate neutrality by 2050 is to become a binding target, we have to make these additional needs transparent. As a basis for sustainable grid planning, we need reliable scenarios on the power system 2050, whose components (generation, flexibility, storage, demand side management) need to be designed and planned in advance. Therefore, the impact assessment on the EC’s plan to enhance the 2030 CO2 emission reduction targets should also look closely at potential consequences for the 2030 electricity grid based on the envisaged generation landscape. With regard to the PCI status, potential financial disadvantages of the status in the national regulatory system need to be avoided and administrative burdens lowered. In contrast, the PCI status needs to ensure palpable advantages in terms of financial incentives and efficiency gains (i.e. with regard to permitting) when it comes to implementing projects that are vital for the European internal energy market. We therefore expect the revision of Regulation (EU) 347/2013 to pave the way for a forward-looking European energy infrastructure policy, in line with the 2050 target. We also welcome the fact that the Green Deal initiative aims at ensuring that all EU policies contribute to the climate neutrality objective. In our view, existing legislation should also be checked for compatibility with this objective. While the political objective of building a competitive internal energy market is undoubtedly still valid, we would like to encourage decision-makers to reexamine established rules and practices in light of the rising importance of climate objectives. One example is the obligation stemming from Regulation (EU) 2019/943 of introducing a minimum available capacity for cross-zonal electricity trade of 70%. This obligation, designed to maximize cross-border electricity trade, should be subject to a thorough climate impact assessment. We fear that its implementation might increase CO2 emissions by significantly raising the amount of necessary remedial actions (for instance redispatch). As a TSO, we stand ready to support decision-makers with our technical expertise and for planning an electricity grid that fits the future climate-neutral energy system.
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Meeting with Maroš Šefčovič (Vice-President) and

24 Apr 2017 · Clean Energy Package