BWO statement: Guidelines of the Federal Network Agency on feed-in tariffs

On March 27, the BWO submitted its statement on the BNetzA's renewed consultation regarding feed-in tariffs within the framework of the AgNes determination procedure. In its statement, the BWO reiterates its clear opposition to all forms of feed-in tariffs for producers, including construction cost subsidies. 

The basis for the consultation is laid by the BNetzA's guiding principles from 17 February 2026. 

core positionFeed-in tariffs would represent a further, difficult-to-calculate risk that would jeopardize investment security and increase costs. This form of tariff, as well as construction cost subsidies, should therefore be rejected for offshore wind energy generation technology. From the BWO's perspective, a technology-specific approach is both necessary and warranted. 

In the statement submitted today, the BWO demands and explains accordingly: 

•  The investment environment must not be further deteriorated.Risks beyond the control of developers and investors already significantly complicate project implementation. What's needed here is de-risking, not further uncertainty. 

• The Impact on the economic viability of projects, risk hedging requirements and levelized cost of electricity These factors must be taken into account. Additional burdens from feed-in tariffs and construction cost subsidies would further increase uncertainty and directly translate into higher project and hedging requirements in the form of risk premiums. This would also be reflected in higher levelized cost of electricity (LCoE).  

• Multiple burdens must be avoided.Offshore wind power already contributes to grid expansion costs through the second bidding component. Together with feed-in tariffs and other measures, this threatens to result in a structurally multiple burden on offshore wind energy development.

• Protection of existing rights is essential for the investment locationWithout protection of legitimate expectations, there is a risk of a permanent loss of investor confidence. Existing and awarded projects would be unable to anticipate potential future feed-in tariffs and therefore could not factor them into their calculations. Retroactively introducing such tariffs would significantly impair existing business models and investments already made.

• There is no location control function through feed-in tariffs for offshore wind.Feed-in tariffs and construction cost subsidies have no steering effect, as the location of projects is not at the discretion of the developers. The location of an offshore wind farm, as well as the timing of the tender, is centrally determined via the area development plan and is integrated into the long-term grid expansion planning within the grid development plan.