Shaping the Buildings Energy Act: Stakeholder Influence and the Role of Hydrogen in the German Heating Transition

In recent years, low-carbon hydrogen has been discussed as a critical element in decarbonising a wide range of energy-intensive sectors. In Germany, it was proposed as a viable option to decarbonise building heat in the 2023 Buildings Energy Act (BEA). However, research has suggested that using low-carbon hydrogen for individual building heating is unfeasible, due to factors such as high costs, inefficiencies and limited availability. When laws contradict science, social and political factors are likely at play. Through a qualitative, single-case study, the paper examines how stakeholders in the German heating sector influenced the BEA. Using a simplified discourse network analysis, content analysis and process tracing, the authors develop a structured understanding of the power dynamics observed during the policy process and establish a causal explanation for its outcome. The discourse network analysis identifies two distinct groups of stakeholders: one supporting the use of low-carbon hydrogen for building heating and one opposing it. The group advocating for its use is dominated by stakeholders from the gas industry. To influence the policy, gas actors utilised instrumental power to overcome their lack of discursive power and build legitimacy among policymakers, particularly within the Green Party resulting in inclusion of hydrogen in the BEA. The study contributes to the understanding of how instrumental, structural and discursive power interact and reshape one another in the context of climate policy. It also demonstrates how political framings, lobbying and institutional positioning can pull climate policy away from evidence-based pathways, highlighting the need for more balanced and inclusive consultation processes.