Published on Dec. 6 2024 on our customer app
In 2023, the electricity threshold (9 PJ) was again exceeded, triggering a (normally) automatic increase of the THG quota requirement from 2025 and subsequent years. Local sources explained the Ministry of Environment (BMUV) had, however, yet to agree on this increase.
Sources confirmed that the data relevant to calculating the fulfillment of the electricity quota according to section 37h Abs BlmSchG is retrieved from UBA, not Zoll.
The UBA figure for 2023 was 3 606 GWh, or 12.9 PJ, creating a surplus close to 4 PJ. This is significantly above the 9 PJ threshold, thus normally triggering an automatic increase of the quota from N+2, as it did in 2024 for the 2022 excess.
Local sources said the 4 PJ surplus could translate into an increase of 0.12% to 0.36%, depending on the ratio the Ministry would apply. This ratio can be comprised between 0.5 and 1.5.
We could not confirm directly with the BMUV what its intention was for this quota increase. Sources mentioned some reluctance from the Ministry to increase the quota for a second consecutive year.
At the same time last year, it was already decided internally that the automatic increase would be triggered. The final enforcement was drafted later in February 2024.
Our sources also reported that the draft for RED3 transposition would not be released before Christmas. It looks now clear that only the proposal to be formulated by the new government to be formed following the February legislative elections will be reliable.
