Network charge optimization §19 + §118 + AgNes

Network charges are not a minor item for energy-intensive industries. They are a major cost block — and the only one that can be influenced by regulation.

The Cost Trap: Peak Load Component of Network Charges

For industrial companies with 1 MW peak or more, the share of grid fees in electricity OPEX is typically between 30 and 40 percent. The driver is the power component (HLZ - peak load time window), which scales linearly with the annual peak load. A peak load of 1,000 kW for 15 minutes is sufficient to fix the power price for an entire billing year.

Three structural factors will worsen the situation by 2030:

• Network expansion delay Transmission grid investments are passed on to all consumers. Industrial sites bear the largest share through their performance-based prices.
• Volatility from renewable energy expansion — Fluctuating generation increases the need for flexibility. Those who cannot shift their load will pay for volatility as a grid fee surcharge.
• Rollout of proven optimization levers — §19 Para. 2 Sentence 1 StromNEV (Atypical Grid Usage) expires on December 31, 2028. The successor regulation, AgNes, will start on January 1, 2029, with a different mechanism and optionality.

Industrial companies without active load shifting optimization will lose between €50,000 and €200,000/MW/year in grid utilization fee differences by 2030 compared to optimized competitors.

Lever 1: §19(2) Sentence 1 StromNEV — Atypical grid usage

Mechanism

Instead of the standard calculation based on the individual annual peak load, a reduced calculation is used for proven atypical grid usage - typically based on the load during the peak load hours (HLZ) windows. The reduction in grid charges, depending on the grid operator, load profile, and voltage level, ranges from 20 to 80 percent compared to the standard calculation.

Prerequisites

• Voltage level Medium or high voltage. Low-voltage connections fall under different regulations.
• Backlash characteristic: The reference during the average load must be significantly below the annual average — to be demonstrated using half-hourly load data from the last 12 months.
• Application At the network operator, annually renewed. Application deadline September 30, 2028 for the last application in the accounting year 2028.

First and last

Expiration on December 31, 2028. The atypicality regulation in its current form ends at the turn of the year 2028/2029. From January 1, 2029, AgNes will take over as the successor mechanism, with a different mechanism (see Lever 3).

For the depth regarding §19 atypicality, including an isolated practical example with savings of €480,000 over four billing years: Atypical Network Usage — Deep Side.

Lever 3: AgNes from January 1, 2029 — From static to dynamic marketing

Entry into Force and Regulatory Status

AgNes (Incentive-Based Network Charge System) comes into effect January 1, 2029 in Kraft. The BNetzA regulation is the basis GBK-25-01-1#3. The discussion paper was published on September 24, 2025; the final determination is expected at the end of 2026.

Agnes replaces the static atypia regulation (§19 para. 2 sentence 1 StromNEV) with an incentive-based system: Grid fees become the control variable for load flexibility — those who shift load benefit; those who place peak load in critical time windows pay more.

Network-led vs. price-led

AgNes has two management modes:

• Network-guided — The load follows grid signals from the regional grid operator. Use preferably in regions with strained grid expansion. Compensation through reduced grid fees and flexibility surcharges.
• Price-regulated — The load follows day-ahead and intraday price signals in the electricity market. Higher marketing potential, but also higher modeling requirements. A prerequisite is a BESS or a controllable load portfolio.

Compatibility with BESS and mFRR

BESS are the natural grid-balancing infrastructure: their response time (≤ 1 second) meets every requirement, their capacity is predictable, and the §118 exemption can be applied in parallel. mFRR (minute reserve) remains as Auxiliary channel relevant – not as a primary channel – because the remuneration per megawatt-hour procured is below the AgNes price-driven marketing revenues.

For depth into reserve energy markets and FCR/aFRR revenue components: Ancillary Services — Deep Side. For location-specific AgNes marketing modeling: Schedule an appointment

Who benefits? — Qualification and Process

ICP Profile

• Peak 1 MW — below this threshold, the leverage effect of the performance component is too small to justify the §118 IBN investment over 20 years
• Medium or high voltage level Low-voltage connections fall under different regulatory regimes, which are not covered here.
• Backlog with optimization potential — counter-cyclical profile to peak grid load (for §19) or controllable load portfolios (for AgNes)
• Investment horizon 5-20 years — the §118 exemption pays for itself over the 20-year term, with IRR-relevant effects from year 5

Four-stage process

CUBE CONCEPTS works through each location in four stages — from cold aisle analysis to IBN planning. Throughout all four stages, over 250 operating variants into the modeling, based on the site's real-time half-hourly load data.

CUBE Models - Implementing the Three Levers

CUBE CONCEPTS offers two models for implementing the network charge levers presented here. Both use §118 as the basic anchor, both address §19 atypicality (until expiration) and AgNes (from entry into force). They differ in investment logic and revenue distribution.

The decision between Contracting and purchasing depends on the investment horizon, the balance sheet strategy, and the risk appetite. CUBE CONCEPTS evaluates both models for each location.

Further