Public consultation: key points of the Federal Ministry's funding directive for offshore electrolysis. 18 January 2023. Dear Mr Büchner, achieving the Federal Republic of Germany's climate protection and expansion targets for green hydrogen has long been and remains a central concern for us. Alongside strategies and political declarations of intent, the swift and timely implementation of concrete and targeted measures is needed in order to build and advance the hydrogen economy in Germany and Europe. We therefore emphatically welcome the publication of the key points for a funding directive for offshore electrolysis. The AquaVentus concept aims to make an important contribution to the national hydrogen targets with 10 GW of offshore electrolysis capacity and also advocates European interconnection. The planned site tender for the SEN-1 area and the funding tender preceding it, on the basis of a funding directive still to be drafted, can be the decisive starting signal for achieving the targets for offshore electrolysis. We see a great opportunity for both tenders, in their genuinely novel interplay, to contribute jointly to the lasting ramp-up of the offshore hydrogen industry — an outcome that can be achieved not least through competition for the best concept on the basis of the qualitative criteria of the Ordinance on Other Energy Generation Areas (SoEnergieV).
We are therefore grateful for the opportunity to contribute actively to this consultation. We ask you to take note of and consider the arguments attached here. For the further procedure in preparing the funding tender, we consider it urgently necessary to seek supplementary exchange with the actors in the sector. AquaVentus, as an overarching initiative of more than 100 organisations, research institutes and companies along the entire value chain, recognised the opportunities for offshore hydrogen early and first formulated the concept in 2020. This great potential was already acknowledged through the inclusion of the two sub-projects AquaPrimus and AquaDuctus in the national pre-selection for IPCEI funding. The AquaVentus family of projects can contribute substantially to decarbonising the German and European energy supply while at the same time promoting domestic value creation, creating skilled jobs in the northern German region and minimising environmental impact. To make this concept a reality and enable the associated advantages, it is important to set the right course together.
We look forward to the continued dialogue on this.
With fresh greetings from the high seas. Public consultation: key points of the funding directive for offshore electrolysis. Statement — Summary: • AquaVentus welcomes the fact that the planned funding directive is intended to support the ramp-up of hydrogen production at sea. We consider connecting the SEN sites via a hydrogen pipeline to be very expedient. • The key points of the funding directive state that funding is to be granted for projects including a pipeline and that separate funding for pipeline construction is excluded. In view of the unbundling to be expected, but also for business reasons, integrating the pipeline into the project is not expedient. The Federal Government should rather fund the collector pipeline outside the project in order to realise a large-scale German and European infrastructure promptly. • The funding tender should be extended to 6 months. Following the announcement of the successful funding bidder, a period of at least two months should be provided before bids are submitted for the site tender. • The decision on the site should be taken by means of the qualitative criteria of the SoEnergieV. Fixing on a single funding recipient in the funding tender prevents competition between the highest-quality projects within the SEN site tender and thereby jeopardises a successful start to building an offshore hydrogen industry. • Pre-qualification criteria should moreover ensure that developers possess competence in developing offshore wind projects or experience in gas process engineering, in order to minimise the realisation risk. • Dividing the area into two separate SEN sites tendered 2-3 years apart is clearly preferable to a single large other energy generation area, in order to enable a step-by-step scaling of the technology and to reduce the funding required. • We would be very glad to explain in detail the advantages of this step-by-step ramp-up of an offshore hydrogen economy and to discuss them in a workshop organised by the Federal Ministry together with other stakeholders of the hydrogen sector.
Preliminary remark. We expressly welcome the fact that the planned funding directive is intended to support the ramp-up of hydrogen production at sea. We also consider it expedient to favour connecting the SEN sites via a hydrogen pipeline and, in doing so, not to fund the blending of high-grade green hydrogen into a natural gas pipeline or the option of transport by ship. In what follows we would like to address key individual aspects and will conclude by answering the specific questions of the Federal Ministry from our perspective. Since some very fundamental and complex aspects requiring discussion are at issue here, we suggest discussing these publicly in a workshop with interested stakeholders and are of course available for this at any time.
Pipeline. The unbundling of transport and production is necessary in order to ensure independent, non-discriminatory and efficient planning of a European hydrogen network. The key points of the funding directive expressly state on several occasions that funding is to be granted for projects including the pipeline connection and that separate funding for pipeline construction is excluded. Two options are envisaged: a spur pipeline to a hydrogen collector pipeline, or the direct connection of the SEN sites to land via pipeline. In both cases the capacity is to be at least 2 GW and must enable non-discriminatory access for further projects. A project-owned pipeline to land has so far been excluded by the BSH for comprehensible reasons of spatial planning efficiency. This is also why AquaVentus developed, with the concept of the independent and non-discriminatory AquaDuctus collector pipeline, a solution that takes up precisely these requirements and ensures the greatest possible spatial and economic efficiency. The key points of the funding directive do not, however, take adequate account of this approach.
a) Fundamentals. aa) Regulatory aspects. In view of the regulation of offshore pipelines, including for hydrogen, to be expected from the EU, we have considerable reservations as to how the construction and operation of a transport pipeline can be integrated into the tender for the project to produce hydrogen at sea. On the basis of the statements and determinations of the Federal Ministry and the BSH, and in view of the regulation of hydrogen transport infrastructure to be expected, AquaVentus has hitherto aligned itself with the separation of production and infrastructure that applies in all areas of energy infrastructure. Accordingly, two independent and entirely separate projects were developed with AquaSector and AquaDuctus.
On the one hand, AquaSector was geared towards constructing the wind farm with connected electrolysis. On the other, AquaDuctus was developed as a project for designing an independent collector pipeline of up to 10 GW extending into the so-called Entenschnabel and beyond, in order to enable a hydrogen network with European neighbouring countries. We continue to regard the separation of transport and generation as decisive for transporting hydrogen at the large scale required, above all for German industry. What is at issue is thus a large and central infrastructure that needs to be developed and built. In our view this is the task of one (or several) independent gas transmission system operators (TSOs) which, by virtue of their legal classification and certification, guarantee non-discriminatory access to the pipeline. For a project consortium competing to produce hydrogen on the SEN sites, a pipeline would be an entirely new and different line of business that is currently not feasible either in the short or the medium term. AquaVentus is therefore of the opinion that the unbundling principle should be observed from the very start of project planning, in order to ensure independent, non-discriminatory and macroeconomically sensible network planning.
ab) Business aspects. Project developers must assume that the rules of unbundling will ultimately apply to this project as well. Since critical infrastructure is at issue here, we consider this aspect to be extraordinarily difficult, and not only in economic terms. In the view of AquaVentus there are two options within the proposed framework for integrating a pipeline into the project. • Subcontracting the pipeline: a bidder for the SEN sites could subcontract the construction and operation of its own pipeline. In this case, however, the project developer would have to assume that it would have to relinquish the pipeline under the unbundling rules, for example by selling it to a transmission system operator. The value of such a pipeline is, however, very difficult to quantify in a market that is monopolistic in character and still under construction, and depends substantially on potential further customers, for example. A project developer has no influence over the designation of further SEN sites for offshore hydrogen production and thus over further customers. For the project developer, the path outlined here therefore represents an incalculable and potentially unsustainable commercial and regulatory risk. In addition, the pipeline increases the capital expenditure requirements, which in turn significantly raises the investment risk of the project as a whole, while there is no adequate safeguard for the execution of the pipeline contract by a third party. AquaVentus therefore fears that these considerably increased and in part incalculable risks may lead to high risk premiums raising the funding required, and could even deter potential bidders from bidding at all.
– Agreement with a transmission system operator before bid submission: another possibility is that an agreement is reached before bid submission, for instance with a gas transmission system operator. It is currently difficult for AquaVentus to foresee whether such a solution for a transport pipeline is politically desired under the unbundling rules, or whether it can endure in the medium term. From this perspective, AquaVentus envisages two independent projects for transport ("AquaDuctus") and production ("AquaSector"). Such a path accordingly entails considerable uncertainty and a major risk for a potential project developer. In addition, it would lead to delays of 12 months or more in reaching agreement with possible contractual partners on matters such as securities, guarantees, liability or bid price. Both options entail major uncertainties for the investor in the wind farm and electrolyser, on both the regulatory and the project side, increase the risks for a project developer and lead to delays in the market ramp-up of the offshore hydrogen industry.
b) Pipeline variants. ba) Spur pipeline. A so-called spur pipeline from the SEN-1 project into another hydrogen pipeline is conceivable but currently difficult to design, since — as things stand today — there is no sufficient visibility of the planning status, let alone any concrete planning commitments, for such a hydrogen pipeline. With current knowledge it would therefore be impossible to price a spur pipeline concretely, since there is no certainty about the prospective existence and routing of such a pipeline and no information about a possible feed-in point. The situation could look different if, for example, concrete starting points and a state commitment emerge from the current negotiations of Minister Robert Habeck on a German-Norwegian hydrogen pipeline that would prospectively enable the transport of 100 % green hydrogen. We would very much welcome this, as it would take account of the concept of the AquaDuctus collector pipeline including its continuation into the European area.
bb) Project-related direct line to land. The other possible variant is a project-owned direct line. For a developer of the SEN-1 project, however, a project-owned direct line offers no incentive to price in more than the minimum capacity of 2 GW for a pipeline. It stands to reason that, if integrated into the project, the pipeline would not be provided with more than 2 GW of capacity, in order to reduce the funding required. With a view to the AquaVentus concept of 10 GW of transport capacity, the opportunity to realise a large-scale German and European infrastructure in the near future — and thereby to unlock the full potential of offshore hydrogen technology in the first place — would thus be missed. Such an infrastructure must be pursued independently of the currently planned SEN tenders, so as not to hinder the build-up of an offshore hydrogen industry and rather to let deeds follow the Federal Government's agreements with Norway and the Esbjerg declarations.
Conclusion. The responsibilities for realising the grid connection and the funding of the transport pipeline as a collector pipeline must be separate from and independent of the allocation of the SEN site(s) and of the specific funding of the wind energy and electrolysis installations. In this respect the arrangement should be designed by analogy with the arrangement for offshore wind electricity, which provides for a clear separation of responsibility between the farm operator and the transmission system operator and unambiguously defines the transfer point before the bid is submitted. AquaVentus sees considerable risks in integrating the pipeline into the funding tender, on the one hand for potential bidders and on the other in that the capacities prospectively required for an offshore hydrogen network conceived in European terms will not be provided, or not on an optimal scale. We see no substantive reasons why the Federal Government intends to fund a project-related pipeline. This applies all the more since, under the Ordinance on Other Energy Generation Areas, only the description of a transport concept was hitherto subject to assessment and costs were considered only up to the transfer point within the project. In light of all this we consider it important that the Federal Government comment in a separate procedure on the aspects of the collector pipeline and promote corresponding investments that serve more than just the current SEN sites. Only in this way can the Federal Government's declarations at Esbjerg and the current agreements with Norway become reality.
We therefore see three possible solutions. 1. A state commitment to a collector pipeline: in the view of AquaVentus, what is needed before the tender begins is rather a clear state commitment to a large separate collector line of at least 2 GW and ideally more than 10 GW, which lies outside the project and unites the Federal Government's current initiatives in a European context with domestic offshore hydrogen production. As soon as the routing for this collector pipeline is fixed in planning terms, the necessary spur pipeline can be priced clearly. 2. A dynamic funding approach for the spur pipeline where framework conditions are unclear (e.g. transfer points, dimensioning): if the collector pipeline cannot be planned promptly before the funding tender is submitted and correspondingly taken into account for connecting SEN-1 by spur line, the Federal Government would have to ensure that the uncertainty regarding the length and dimensions of the spur pipeline, with correspondingly varying costs, allows a later adjustment on the funding side. 3. Consideration of the pipeline in network planning rather than as part of a project: alternatively, the imponderability of the hydrogen transfer point could also serve as grounds for initially providing for both the funding and the site tender without feed-in infrastructure, leaving the latter to the network planning to be carried out by the Federal Government and funding it separately.
Timeframe of the tenders. The intended timeframes are too tight and must take account of internal coordination and approval processes and of the complexity of the two tenders. AquaVentus welcomes the fact that both the funding tender and the site tender are to begin at the same time, so as not to lose valuable time and to have clarity from the outset about the framework conditions of both tenders. The deadlines are based on the system already established for offshore wind, under which tenders are likewise to be published at least 4 months before the bid date for sites not centrally pre-surveyed and at least 5 months for centrally pre-surveyed sites. However, these tenders are not comparable to the tenders for other energy generation areas, for several reasons. In offshore wind, central framework conditions such as site size or award criteria are generally known well in advance and the technology is proven worldwide. Offshore electrolysis, by contrast, is a new technology, and there is currently still great uncertainty regarding the boundary conditions (site size, criteria, interplay of the tenders, hydrogen offtake market, etc.). We therefore have considerable reservations as to whether the intended timeframes are sufficient for such a complex and high-risk first-mover project. Given the great importance of the funding tender, far-reaching internal approval processes and coordination with external partners are already required before bid submission in this tender. An overly ambitious preparation period of only 4 months carries the risk, particularly in light of the still unclear framework conditions, that potential applicants will refrain from applying. Beyond this, the interval between the fundamental funding commitment and the submission of the bid for the site also appears far too short. In the shortest case the interval is only about 2 weeks. This time is far too tight to prepare the bid for the site tender after the announcement of the result of the funding tender and to complete internal coordination and approval processes. Conclusion: AquaVentus therefore proposes extending the funding tender to 6 months, with a subsequent internal review period of 6 weeks for the administration. Bids for the site tender should close after a further period of at least 2 months. In addition, participants must reserve appropriate resources for the bidding procedure. It would be helpful here if these could be planned in advance on the basis of transparent milestones published by the Federal Ministry ahead of the funding tender.
Interaction of the funding and site tenders. Fixing on a single funding recipient in the funding tender prevents competition between the highest-quality projects within the SEN tender and thereby jeopardises a successful start to building an offshore hydrogen industry. The key points paper outlines a two-stage process in which funding is awarded in the first stage on the basis of the lowest total investment (capital expenditure). In a second tender the site is then to be awarded on the basis of a qualitative award procedure according to the criteria of the SoEnergieV. AquaVentus supports the view expressed in the SoEnergieV and in this key points paper that a public subsidy is needed, among other reasons because of the novelty of the technology. If, however, there is only one potentially successful bidder, as proposed in the key points, it is very unlikely that other bidders will participate in the actual site tender without a provisional funding commitment. Something similar would apply if the bid of the bidder with the lowest funding requirement also set that requirement for all other bidders. In view of the high degree of innovation of the technology and the importance of this innovative first-mover project for the step-by-step scaling of the supply chain towards a mass market, it is in the view of AquaVentus decisive that not only the lowest funding amount but precisely also the quality of the project should play a decisive role. The SoEnergieV already contains a balanced catalogue of assessment criteria for this, with the aim of enabling the practical trialling and implementation of innovative concepts for energy generation not connected to the grid in a spatially ordered and space-saving manner. On the basis of the qualitative criteria of the award procedure, the award should thus go to the most promising projects that can be realised promptly. Only in this way can it be ensured that the successful project sets in motion the development of viable supply chains for offshore hydrogen and paves the way for the ramp-up of the technology. The bidder that receives the most points under the catalogue of assessment criteria laid down in the SoEnergieV should therefore be awarded the contract. Under the concept proposed here, however, this catalogue would de facto play no role in selecting the best project and thus ultimately in determining its quality. The prompt realisation of a project, and thereby the efficient use of public funds, cannot be ensured in this way. Pre-decisions in the funding tender should therefore be avoided as far as possible, because in the end they prevent competition between several bidders for the best concept. Conclusion: the Federal Ministry itself rightly emphasises in the SoEnergieV and in this key points paper the necessity of a public subsidy, among other reasons because of the novelty of the technology. In our view it is therefore unrealistic that a bidder would participate in the site tender without the prospect of the funding acknowledged to be necessary.
AquaVentus therefore recommends that competition between several bidders in the qualitative award procedure should be the focus, in order to ensure, through the selection of suitable projects, the step-by-step scaling of the technology and of the necessary supply chains as well as the market ramp-up of the offshore hydrogen industry. Pre-decisions in the funding tender should be avoided as far as possible, since otherwise competition between several bidders for the best concept in the qualitative award procedure would in the end be de facto prevented.
We therefore propose the following solution. At least three potential bidders (with the lowest respective funding requirements) should be given a provisional funding commitment at their respective funding levels, so that the winner can then be determined by points in the subsequent site tender. It must moreover be ruled out that the level of funding is set for all participants on the basis of the bid of the project with the lowest stated requirement. This too would run counter to the differing competitive approaches, the specific bidder-individual project design and the later qualitative selection.
Pre-qualification criteria. Given the importance of the project for the ramp-up of the offshore hydrogen industry, suitable pre-qualification criteria and securities are required to ensure the success of the tenders. The ambitious expansion of offshore wind and hydrogen places high demands on all involved along the entire value chain. The market ramp-up of a pioneering technology such as offshore hydrogen, together with rising inflation and interest rates, presents major technical, financial and operational challenges, with the consequence that realisation risks increase. The ramp-up of offshore hydrogen technology as a whole is thereby jeopardised. It is therefore decisive that the regulatory framework be set so that competent and reliable developers compete for the best projects. This is also in the general regulatory interest of the state and should be achieved through suitable pre-qualification requirements already in the funding tender. Suitable criteria can ensure, among other things, that bidders must demonstrate their seriousness (e.g. by securing the binding nature of a bid) and their suitability (e.g. sufficient experience with comparably complex offshore projects) already in the funding tender. An overly ambitious or insufficiently elaborated bid in the funding tender can lead to the successful bidder not participating in the site tender. Under the present proposal, non-participation in the site tender would have no direct consequences for a potential winner of the funding tender. Since it can be assumed that other bidders cannot participate in the site tender without funding, no project would be realised in such a case. This would mean that the process would have to be started again and the tender criteria adjusted at the latest then. Conclusion: offshore hydrogen projects are a combination of two technologies, and a bidder should therefore bring competence in at least one of the two, that is, in the development of offshore wind projects or experience in gas process engineering. Bidders should therefore meet at least one of the following two criteria. 1. Offshore wind farms have been realised by many different developers for years. In a complex and innovative first-mover offshore hydrogen project, developing an offshore wind farm remains a challenge but is the considerably more proven component. A pre-qualification criterion should therefore ensure that developers possess a certain amount of experience in this field, in order to minimise the realisation risk. A pre-qualification criterion should therefore establish the developer's competence as measured by successfully completed offshore projects in Europe — e.g. at least 2 GW over the past 10 years, with joint ventures counted pro rata. 2. A further pre-qualification criterion should cover competence and capabilities in realising and operating pipeline-connected gas process plants, including experience in safety engineering (HSE). Beyond this, securities can help safeguard the success of the auctions. Securities of the same amount as for the site tender should therefore be lodged already for the funding tender, falling due if a bidder receives a provisional funding commitment and then submits no bid in the site tender.
Site size. Tendering two separate SEN areas 2-3 years apart, instead of a single large SEN area, enables a step-by-step scaling of the technology and thus reduces the funding required. We expressly welcome the designation of further SEN areas in order to accelerate the technological and economic breakthrough of the technology, and we already made corresponding submissions to the BSH in our statement on the second draft Site Development Plan. In our view, dividing the area into two separate other energy generation areas is clearly preferable to a single large other energy generation area. This enables a step-by-step scaling of the technology, and the design, installation and technology improvements to be expected, particularly on the part of the entire supply chain, can be transferred continuously to subsequent projects. Costs can thereby be lowered and efficiency increased.
A staggered tendering of two sites thus offers the best possible basis for directly implementing the learning effects and applying the next generation of technology in a second, then more cost-efficient, follow-up project. Such a step-by-step approach reduces not least the funding costs necessary for the ramp-up of this new technology, since the support required per MW or per kilogram of hydrogen in the second tender will already be significantly below that of the first tender thanks to the learning effects. From a macroeconomic perspective, too, a staggered tendering of two sites with a sufficient interval (2-3 years) is therefore preferable. Sequential tendering of the sites likewise enables the tender design to be optimised on the basis of experience from the first tender. With a single large site, or with both sites tendered simultaneously, none of the positive effects of a staggered tender named above could be achieved. Conclusion: from the AquaVentus perspective we want to make rapid progress in order to be able to use further and larger sites for offshore electrolysis. But for the reasons stated it is necessary to minimise risks so as to avoid a false start, and to make the expected design, installation and technology improvements — particularly on the part of the entire supply chain — usable by tendering two sites 2-3 years apart. In the view of AquaVentus the originally envisaged site size of around 27 km² is a sensible order of magnitude for Germany's first large-scale offshore hydrogen flagship project, since here the considerable financial, technical and operational risks on the part of the project developers stand in a bearable relation to the expected added value. With a considerably larger project delineation for the first large-scale realisation of offshore hydrogen production, however, these risks and the investment costs increase significantly and make financing and realising the project more difficult. Independently of this, we support the medium- to long-term designation and tendering of further large-scale SEN sites in the gigawatt range. In order to make full use of the economies of scale envisaged and to build a viable infrastructure and supply chain, early predictability is strictly necessary here.
Consultation questions. F1: Do you consider the planned minimum and maximum installed electrolysis capacity (820 and 950 MWel) for a site SEN-1 (approx. 95.4 km²) sensible, or do you propose different values? – Setting (minimum) targets for installed electrolysers appears sensible and the basis named here appears realistic. – As described above, we do however consider a staggered tender beginning with the originally envisaged smaller SEN-1 site to be sensible, so that the capacity would have to be adjusted accordingly.
F2: Do you consider the planned overplanting ratio of 0.8 to 0.95 appropriate, or do you propose higher or lower values? – We consider an overplanting ratio of, for example, 0.7 to 1.05 more suitable, in order to give project developers latitude to optimise their business case. – The technology required here (electrolyser, desalination, etc.) will be deployed offshore at industrial scale for the first time in the SEN-1 project. This means that every developer must reckon with the technology required here needing more maintenance hours and intervals than is currently the industry standard for offshore wind turbines. In addition, the electrolyser stacks themselves will degrade over time, as is known from today's onshore installations. – From a societal perspective it is advantageous to design the project for maximum hydrogen generation over its entire lifetime. Values above 1 must therefore also be permissible in order to allow redundancy, which can both offset degradation effects and increase system reliability.
F3: Do you consider the transport capacity of at least 2 GW for a direct or spur hydrogen line to SEN-1 (approx. 95.4 km²) appropriate? We would first like to refer here to our explanations in the preceding pipeline chapter. – For a direct hydrogen line, a transport capacity of at least 2 GW appears conceivable, albeit oversized for SEN-1 and capped at 2 GW. However, this applies only taking into account the arguments above regarding responsibility for the development and construction of a direct line. – A limitation to 2 GW nevertheless offers little scope for the AquaVentus solution of 10 GW and more, i.e. extending well beyond SEN-1, and independently of the AquaVentus concept also generally prevents the realisation of the economies of scale of offshore hydrogen technology. This conflicts, for example, with the recent agreements between Norway and Germany, in which the connection of several offshore wind farms to a hydrogen pipeline was explicitly mentioned by Minister Robert Habeck and which can also represent a feed-in option for the SEN sites. – For a hydrogen spur line connected to a larger external pipeline, a minimum capacity of 2 GW appears sensible only if other SEN sites would at least prospectively feed hydrogen into it. According to the current plans of the FEP, however, no further SEN sites are envisaged nearby. Conceivable sites in the Entenschnabel would be far too distant from SEN-1 to realise a feed-in from there into the spur pipeline of SEN-1. For reasons of spatial efficiency as well, a spur pipeline should therefore be dimensioned only for the respective quantity of hydrogen generated by one (or several adjoining) SEN areas.
– A spur pipeline from SEN-1 is, as set out, entirely a conceivable option if it remains within the dimensions of the hydrogen production of this site and the connection to the external pipeline is sufficiently assured, or if the uncertainty regarding the length and dimensions of the spur pipeline, with correspondingly varying costs, allows a later adjustment on the funding side.
F4: Which milestones, oriented towards the realisation deadlines of the SoEnergieV, do you consider suitable for partial disbursements? – In view of the high costs and the large investments that must be made within the projects, it is decisive that not only a few payments fixed in advance are made in the course of the project, but that applications for cost reimbursement can be submitted throughout the entire project period. – In line with customary funding practice we would therefore expect applications to be submissible on a continuous basis (e.g. quarterly). If the funds are not fully drawn down at a given point in time, they should moreover not be forfeited but transferable to the next phase. – We would therefore regard the milestones derived from the implementation deadlines of the SoEnergieV only as upper limits for the costs incurred up to that point, and not as the time of payment or reimbursement. Otherwise the intervals between milestones are too long and considerable costs could arise during that time, which would significantly increase financing costs and the subsidy required. – The milestones up to the demonstration of existing financing for the construction of the installations approved in the plan approval decision or the plan permit should not be subject to possible clawbacks based on the project outcome. – On the basis of these assumptions we regard the following milestones as suitable upper limits and have also roughly estimated in brackets the share of costs incurred up to each point: o Submission of the documents for the plan approval procedure (10 %) o Submission to the Federal Maritime and Hydrographic Agency of the documents required for conducting the hearing procedure on the plan under Section 73(1) of the Administrative Procedure Act and Section 68 of the Offshore Wind Energy Act (5 %) o Demonstration of existing financing for the construction of the installations approved in the plan approval decision or the plan permit (25 %) o Demonstration that construction of the installations has begun (30 %) o Demonstration that the installed capacity of the operational installations corresponds to at least 95 per cent of the quantity approved in the plan approval decision or the plan permit (30 %)