Current status.

Note: On this page, we use the terms “CO₂ emissions” and “climate neutrality” for the sake of readability and to facilitate general understanding. These terms refer, respectively, to all GHG emissions and the concept of net greenhouse gas neutrality in the context of Germany’s climate targets.

• Grid Expansion
  Avacon, the operator of the 110-kV grid, is currently evaluating options for expanding its grid to serve Varel. Three possible route options have been identified, and Avacon has simultaneously submitted an application to the Friesland district administration to waive a land-use impact assessment. Avacon publicly presented the current status of the plans to the Varel City Planning Committee on May 12, 2026. Further public information is to follow. In line with this, the grid operator EWE NETZ is evaluating options for a suitable substation. A spokesperson told the NWZ in September 2025 that “the area bordering the PKV to the northwest is very likely to be considered” as a potential site. The spokesperson added: “We expect that a decision on the exact location can be made next year. We are initially planning the substation with three transformers, expandable to four,” said the spokesperson. The substation site is expected to cover an area of 8,000 to 10,000 square meters. This information reflects the current status.
• EBS Power Plant (Substitute Fuel Power Plant)
  PKV has submitted the application for the permitting process under the Federal Immission Control Act (BImSchG) for the planned power plant to the State Office of Labor and Industrial Safety. The documents will be available for public review through the end of September 2026. At the same time, PKV is currently seeking to have the city of Varel adopt a zoning plan that would allow for the construction of the EBS power plant and a large-scale heat pump. PKV provided the relevant planning committee with detailed information about the project during a public meeting on August 5, 2025, and on August 19, 2025, in a public meeting, the committee unanimously approved the initiation of the procedure to adopt Development Plan No. 272, “Varel Paper and Cardboard Factory Industrial Area—south of Hellmuth-Barthel-Straße.” EBS power plant? The technically correct term for the PKV’s planned facility is “substitute fuel steam generator (EBS-DE),” because burning the substitute fuels generates live steam, which is fed into a steam manifold at the existing power plant for use in steam turbines to generate electricity and is then directly utilized for drying in the cardboard and paper machines.

Questions & Answers.

General Questions About Energy Use

• How much energy does private health insurance require?
  In 2023, PKV consumed 1.4 terawatt-hours of energy, which is 1.4 billion kilowatt-hours. Roughly speaking, PKV consumes as much energy as one-third of the city of Oldenburg. In terms of energy consumption per metric ton, this places us well below the industry average. It should be noted, however, that this average also includes companies that, due to the nature of their products, are technically forced to use more energy—for example, when processing virgin fibers. By comparison, recycling waste paper (as PKV does) is less energy-intensive.
• How much CO₂ does the PKV emit?
  Currently, PKV generates energy almost exclusively from natural gas. The company’s on-site power plant_emitted approximately 281,600 metric tons_{of CO2*} in 2021; in 2023, that figure was approximately 246,000 metric tons_{of CO2}. This corresponds to about 91.6 grams_{of CO2} per square meter of paper or cardboard (with an average basis weight of 290 g/sqm). By comparison: A passenger car with an internal combustion engine produces about 233 grams_{of CO2} per kilometer driven, and even an electric car emits 162 grams per kilometer over its entire life cycle. * If all relevant greenhouse gases other than_CO2 are taken into account, the total comes to 285,384 metric tons of_{CO2 equivalents}.
• How important are energy costs in private health insurance?
  Before the war in Ukraine, a level of 9–11% of revenue was normal—in the crisis year of 2022, PKV was able to limit the increase to 14% of revenue thanks to forward-looking procurement. An increase to 30% would certainly have been possible. Today, despite all efforts, the share stands at 22% in 2023 and 15% in 2024. This meant energy costs of around 54 million euros in 2024. In absolute terms, our energy costs per metric ton (excluding the CO₂ price) have doubled from 2018 to 2024.
• What steps has the private health insurance sector taken so far to conserve energy?
  PKV meets its energy needs almost exclusively through its own power plant, whose facilities have always been consistently designed for combined heat and power generation, thereby ensuring the most complete possible utilization of the energy source. Our ISO 50001-certified energy management system ensures, among other things, that resources are used as efficiently as possible. Our four gas turbines, five high-pressure steam boilers, and four steam turbines generate, depending on steam demand, up to 200 metric tons of steam per hour and more than 50 MW of electricity through a highly efficient combined heat and power (CHP) process. The primary energy source is natural gas. In addition, the process water treatment plant produces its own biogas, which is primarily converted into electricity in two gas engines with a combined electrical output of just under 2 MW (this electricity is currently fed into the public grid). The flue gas heat is used for steam generation, and the engine heat is used to heat the boiler feedwater. An additional amount of biogas is used thermally in a natural gas steam generator to substitute for natural gas. In practice, this allows the combined-cycle power plant to achieve a fuel utilization efficiency of just under 90% for both natural gas and biogas energy. On a specific basis—that is, calculated per metric ton—the packaging industry has significantly improved its performance over the past decades thanks to modern technology and processes. In absolute terms, however, the volume of_{CO₂ emissions} has increased because the rising demand for packaging worldwide and in Germany has also led to higher production volumes. This trend will continue for a few more years, due to a planned 16 percent increase in production volume and the gradual implementation of decarbonization measures.

Our Decarbonization Pathway

• What technical and organizational steps does the private health insurance sector plan to take to address decarbonization?
  PKV will replace its use of natural gas, on the one hand, by switching to electricity as an energy source and, on the other hand, by constructing a new EBS power plant (EBS = alternative fuels). In addition, the use of large-scale industrial heat pumps is planned, which would further improve the plant’s energy efficiency and enable better water recovery.
• Which approach will contribute what part to the solution?
  By saving energy (using heat pumps) and generating our own energy from waste and biogas, we plan to reduce the amount of energy purchased from external sources to 55 percent of the current level. Of the energy we will still need, > 70% is to come from electricity and < 30% from the EBS power plant.
• How much will this path to climate neutrality cost private health insurers?
  We currently estimate the cost to be a substantial three-digit million amount; however, it is not yet possible to quantify all associated costs with a high degree of certainty over the long term. We are working to take advantage of appropriate funding opportunities.
• Will the public benefit from the decarbonization of private health insurance?
  The energy transition requires industry and local governments to think in a networked way. All sectors must address challenges related to sustainable energy generation, energy transmission, and heat utilization. It is quite possible that, along the way, we will be able to identify and leverage positive synergies between the needs of PKV and those of the city of Varel. However, if industry is to serve as an energy source for municipal needs, this energy must be as climate-neutral as possible; otherwise, it benefits no one. Furthermore, the region benefits from a PKV that is positioned for the future as a stable company and employer. The transition to climate neutrality has now become an integral part of this. If this transformation fails or cannot be achieved economically, the private health insurance sector will lack the crucial legal and economic foundations necessary for successful operation. This would pose a very significant risk to the company and the region.
• When will the burning of natural gas come to a complete halt?
  According to Germany's Climate Protection Act, by 2045 at the latest—and before then, it will be phased out gradually in line with our goals.
• What will happen to the PKV's gas-fired power plant after 2045?
  We can't say that yet. It's possible that grid-connected power plants will be needed as an emergency reserve when operating on hydrogen, but no one can say for sure at this point.
• Will PKV continue to use the biogas it produces?
  Yes. We expect to have slightly more biogas available in the future than we do today (from our water treatment processes), and we will use this renewable energy in biogas engines to generate electricity and heat. Overall, biogas can cover a single-digit percentage of our energy needs.
• Why can't the private health insurance sector switch entirely to electricity as an energy source?
  Electricity cannot meet 100% of our energy needs—in part because the grids simply cannot handle that volume, including redundancies and peak-load coverage, even after the planned expansion of the power grid. Furthermore, a complete switch to grid power would be uneconomical—that is, too expensive—for PKV given current and foreseeable electricity prices and grid fees. This is also due to the following consideration: If we no longer want to use natural gas, we must turn to other energy sources. The unavoidable waste that is delivered to us along with the waste paper is one such energy source. Today, we pay high disposal costs to have this waste incinerated elsewhere so that its energy can be utilized. That makes little sense in a future world. That is why we plan to use this energy source right here on site.
• Why can't private health insurers build their own wind or solar farms to meet their electricity needs?
  On the one hand, in-house systems of this type could never meet total demand, since the PKV requires a continuous supply of energy—even at night and during periods of calm. On the other hand, meeting the PKV’s energy needs would require land that is not available here, as well as systems of a size that would entail an unreasonable investment.
• Why can't private health insurers build energy storage systems to make it easier to use electricity from renewable sources?
  Storage solutions could play a role in the coming years; this will depend heavily on investment and operating costs, as well as technical and regulatory integration—and ultimately, on the impact on cost-effective production. However, such a solution is certainly conceivable.
• Why can't the private health insurance sector stick with natural gas and use CCS (carbon capture)?
  Under this scenario, the PKV would have to capture and transport 246,000 metric tons (2023 figures) of_CO2, which would be uneconomical and result in unreasonable transportation demands—not to mention the political uncertainties that still surround Carbon Capture and Storage (CCS). Furthermore, the electricity consumption for this technology is very high; it currently makes sense only for truly unavoidable_{CO2 emissions}. It is possible that in future years, the waste-to-energy power plant will be equipped with this technology to capture and sequester the remaining_CO2 from fossil fuels. However, this depends on a number of factors that cannot yet be foreseen.
• Why isn't hydrogen part of the solution?
  The PKV primarily uses energy to generate process heat (in the form of steam). It would be very inefficient to produce hydrogen via electrolysis—a process that requires large amounts of energy and water—only to then use it to generate heat, resulting in significant losses. Electricity, on the other hand, can generate heat with almost no conversion losses in what is known as a power-to-heat module—a kind of oversized electric kettle. Even when considering the foreseeable costs for this application compared to the alternatives, hydrogen is currently not a compelling option for our intended use. Furthermore, the availability of hydrogen and the infrastructure that would need to be built are foreseeable obstacles to its use. Initially, only those large-scale consumers where hydrogen is needed in the production process—rather than for heat generation—will be connected, such as steel mills. Hydrogen may eventually play a role at a later date if PKV’s current natural gas power plant were to be used as a grid-supporting hydrogen backup power plant.
• Why isn't geothermal energy part of the solution?
  PKV commissioned a study to assess the feasibility of this solution, but experts have concluded that geothermal energy is very likely not a viable solution—either technically or economically—at the Varel site to meet PKV’s energy needs.
• Why isn't biomass part of the solution?
  Biomass is part of the solution—a portion of the fuels used in the waste-to-power plant consists of biomass and is classified as climate-neutral. Theoretically, more (RED III-certified*) biomass could also be used there. However, this biomass must be available (regionally) in sufficient quantities and on a long-term basis. In our view, importing it from abroad makes no sense, either economically or ecologically. (Also) for this reason, a pure biomass power plant is out of the question; the required quantities could under no circumstances be sourced regionally. Not to mention the significantly larger facilities and storage areas for fuel that would then be necessary. * European Union Renewable Energy Directive III
• Why can't private health insurance companies purchase 100% biogas, for example, from the agricultural sector?
  This idea has already been explored; unfortunately, the required quantities are nowhere near available, even if we were to source them nationwide. Furthermore, based on current prices, this solution would be uneconomical.

Dekarbonisierung durch Strom

• What does the switch to electricity mean for private health insurance?
  PKV requires electricity to operate its facilities and process heat to dry the wet paper/cardboard web. Until now, both have been generated from natural gas at PKV’s own power plant. In the future, the process heat (in the form of steam) will also have to be generated using electricity. At the plant, this means setting up the necessary infrastructure, particularly power-to-heat modules that can generate steam from electricity (one such module has been in use at PKV since 2019). These modules are not large installations; they do not tower over the existing buildings and do not produce any unusual noises or odors during operation. However, the switch to electricity also means that significant amounts of electricity must be supplied to PKV—unlike in the past. To do this, the PKV needs a new power connection. Currently, the plant has a connection at the 20-kV level; in the future, a connection at the 110/20-kV level will be required (see below). Finally, the transition to electricity also means that, unlike in the past, electricity purchase prices and grid usage fees will become significant economic factors for the PKV. In light of the upcoming transition to climate neutrality, the PKV has therefore been calling for years for an industrial electricity rate, a reform of grid fees to safeguard global competitiveness, and the maintenance of the electricity tax at the European minimum.
• How is all that electricity supposed to get to PKV?
  PKV plans to use a new 110-kV transmission line and a new substation for this purpose; both are scheduled to be built in the coming years and will secure the electricity supply for the city of Varel and its economy during the energy transition. PKV will be a major consumer of this transmission line’s capacity, but it is also capable of supplying electricity to businesses and the community for a variety of other purposes, as well as receiving and transmitting green electricity from private and public facilities.
• Where are this 110-kV transmission line and the new substation to be built?
  That is not yet clear. The grid operator Avacon is currently evaluating options for expanding the 110-kV grid, while EWE Netz is evaluating options for a potential substation. For technical reasons, such a substation must be built in any case, but not on the plant grounds—ideally, it should be located near the plant. On the factory grounds themselves, the technical requirements for receiving larger amounts of electricity must be met; however, there are no significant visible elements related to the connection itself.
• Do private health insurers have to contribute financially to the expansion of the network?
  Private health insurance companies must contribute a significant portion of the network expansion costs; this is required by law (similar to private home connections).

Dekarbonisierung durch EBS (Ersatzbrennstoffe)

• EBS Power Plant (Substitute Fuel Power Plant): Is this a waste-to-energy plant?
  The modern terms “EBS power plant” (substitute fuel power plant) or “waste-to-energy power plant” have become established because modern facilities are technically on an entirely different level than the traditional waste-to-energy plants or waste incineration facilities that were controversial in the 1980s. Waste-to-energy plants are primarily designed to reduce the volume of waste through incineration. Some of the heat generated is used to produce energy. A substitute fuel power plant is primarily designed to generate energy while replacing primary fuels—such as natural gas or coal—with substitute fuels, such as rejects or non-hazardous sorted waste. But at the end of the day, the specific term doesn’t matter: What matters is a power plant in which residual materials (such as rejects from recycled paper) are thermally utilized (i.e., incinerated) to harness the energy they contain. The correct term for the PKV’s planned facility is “substitute fuel steam generator (EBS-DE),” because the combustion of the substitute fuels generates live steam, which is fed into a steam manifold at the existing power plant for use in steam turbines to generate electricity and is then directly utilized for drying in the cardboard and paper machines.
• What happens to the residual materials from private health insurance today?
  Some of the waste paper we purchase isn’t actually waste paper at all, but all sorts of things that are disposed of along with it: plastic film, bags, wood scraps… That amounts to about 40,000 metric tons per year—or roughly 1,600 truckloads. Even today, we have to separate this waste very carefully from the paper fibers. Decades ago, such waste was disposed of in landfills. Today, we sort and process it in our reject processing plant into small pellets that can be used as fuel. However, it is then incinerated elsewhere—in cement plants or, as is already the case today, in EBS power plants.
• Why should a power plant like this be built?
  We want to phase out natural gas as an energy source. Green electricity will make up the majority of our future energy mix (accounting for more than 70%). At the same time, we hope to significantly reduce our overall energy demand (by around 30%) using large-scale industrial heat pumps. Nevertheless, a gap remains. Electricity cannot cover 100% of our energy needs—in part because the grids simply cannot handle that volume, including redundancies and peak load coverage, even after the planned expansion of the power grid. So we need a third component of the solution (in addition to electricity and heat pumps). To achieve this, we want to use alternative fuels (EBS), a large portion of which is already on our site today and a significant portion of which also comes from our region. It makes little sense in the future to let this fuel be used elsewhere, pay for that, and at the same time purchase other energy sources—such as electricity—as a substitute. However, these waste volumes are not sufficient even for the smallest power plant of this type that makes sense at PKV for technical and economic reasons; we will therefore have to purchase additional substitute fuels on a limited scale.
• Where should this power plant be built?
  Initial plans assume that it can be accommodated on the northern part of the plant grounds. However, we need to protect our urgently needed waste paper storage areas there. We will already lose storage space due to the planned heat pump building, because, for process-related reasons, it must be located directly next to the paper machine halls. To avoid losing even more storage space, the preferred location for the EBS power plant is currently on the northeastern edge of the plant grounds.
• What kind of building will it be?
  The facility could be approximately 35 meters high, 60 meters long, and 30 meters wide, and will require a chimney about 45 meters high.
• What is supposed to be burned at the EBS power plant?
  For one thing, the EBS power plant is designed to incinerate so-called rejects in order to harness their energy. In the paper industry, we call “rejects” everything that’s in waste paper but can’t (any longer) be processed into new paper. These include sorted-out fibers, stickers, plastic films, bags, and much more that ends up in the blue bin. In addition, substitute fuels from outside the PKV are to be burned. These are non-hazardous wastes as defined by the Federal Emissions Control Ordinance—for example, municipal solid waste, scrap wood, wood waste, or biomass. We are currently envisioning a breakdown of approximately 60% of our own EBS and 40% external EBS. In total, this amounts to a volume of just a few truckloads per day that would be delivered to us via external EBS—but in return, we’ll save at least as many truck trips that previously transported our own rejects to incineration plants.
• Why should additional external substitute fuels be burned?
  An economically viable EBS power plant cannot be built to any size. The EBS volumes generated by PKV from waste paper are not sufficient to operate even the smallest economically viable EBS power plant. For this reason, external volumes are also to be used on a limited basis.
• Where are these additional external substitute fuels supposed to come from?
  It would be best, most sustainable, and most cost-effective if they came from the immediate vicinity—and that is our goal. However, supply contracts with, for example, the Friesland district are subject to a Europe-wide bidding process, and we must, of course, wait for the results of that process.
• Will this result in additional traffic?
  There will be no additional traffic; if anything, traffic will decrease slightly. Overall, we’re talking about a volume of just a few trucks per day that would come to us with external EBS—but in return, we’ll save at least as many truck trips that previously transported our own waste to external incineration plants. Overall, we’re talking about a low single-digit percentage of the truck movements that take place at our facility every day (through which we receive waste paper and transport our products to our customers).
• But isn't this waste actually a form of renewable energy?
  Well, to some extent—the fuel consists of fossil materials (plastics, etc.) and biogenic materials (fiber components in waste paper that can no longer be used) in roughly equal proportions and is therefore considered 35%_CO2-neutral.
• A facility like that produces emissions. What are the applicable emission limits?
  The planned EBS power plant must comply with the strict legal requirements of the 17th Federal Immission Control Ordinance (BImSchV) and the associated Best Available Technology (BAT) standards. Just recently (February 2024), an amendment to the 17th BImSchV further tightened the already strict emission limits for waste incineration plants. These complex and detailed permitting procedures in Germany, which involve extensive public participation, ensure that every such project meets the very high standards of protection for people and nature required by law. Technically, this is achieved using appropriate cleaning systems (the flue gas cleaning system is about the same size as the entire EBS boiler) and is continuously monitored using measurement data. Our existing natural gas power plant also produces emissions and must comply with the regulations of the BImSchV. The use of the natural gas power plant will be scaled back accordingly once electricity and energy from the EBS power plant become available.
• Does PKV publicly disclose the actual emissions figures for the EBS power plant?
  The BImSchV permit for the power plant will require online emissions monitoring that is accessible to the public.
• How is compliance with these limits ensured?
  The exhaust gas from the EBS power plant undergoes chemical-mechanical and electrochemical treatment before it leaves the stack. The height of the stack ensures adequate mixing with fresh air. Emissions levels and the operation of the exhaust gas cleaning system at such an EBS power plant are monitored continuously, that is, around the clock. This enables PKV to respond to even the slightest signs of irregularities and adjust the plant accordingly.
• Will the operation of the EBS power plant cause an odor problem?
  Strict regulations govern the amount of odor that may be emitted by PKV (as is well known, this odor is primarily caused by natural acidification processes during paper production). These limits would not change as a result of a new permit for an EBS power plant; thus, the PKV would not be granted a permit for any “additional” odor emissions. Everything must remain within the existing framework. It will therefore be essential to ensure that the operation of such a power plant also fits within the existing framework. Incidentally, fuels are already being processed today without this having led to any additional odors.
• What residues are produced during the incineration of EBS, and how are they disposed of?
  In the flue gas cleaning process at EBS power plants, pollutants are removed from the combustion exhaust gases. The resulting waste materials include filter dust, solid reaction products, and spent adsorbents (i.e., “full” filter materials). These residual materials are disposed of by licensed specialized companies depending on their composition (either recycled or disposed of in special landfills).
• In 2017, when the waste treatment plan was approved, PKV said: “A waste-to-energy plant is not an option for us.” Why has that changed?
  Because the legal framework in Germany and Europe has changed fundamentally. We are required to phase out natural gas as a fossil fuel by 2045 at the latest. At the same time, economic conditions have also changed dramatically—compared to natural gas, with its rising prices and CO₂ tax, the use of alternative fuels has become significantly more attractive.
• Will the EBS power plant jeopardize the "climatic health resort" status of the Dangast district?
  No. This issue would also be examined as part of the permitting process to prevent any negative impacts. First of all, according to the TA Luft regulation regarding emissions, an area with a radius of 50 times the chimney length must be taken into account—given the likely chimney lengths, this area does not extend as far as Dangast. Furthermore, it must be taken into account that when the EBS power plant is brought online, the existing PKV gas-fired power plant would be shut down accordingly; thus, emissions—and consequently air pollution—would be reduced.
• What is the process for obtaining regulatory approval for an EBS power plant?
  PKV must prepare numerous project plans and expert reports internally in order to submit the necessary application for approval to the Labor Inspectorate. At the same time, a corresponding zoning plan must first be drawn up; the city of Varel is responsible for this. The PKV has already submitted an application to have this zoning plan drawn up. The actual permitting process under Section 16(1) of the Federal Immission Control Act (BImSchG) is conducted by the Trade Supervisory Office, including a comprehensive environmental impact assessment, a review of compliance with the 17th Federal Immission Control Ordinance (which sets very strict emission limits), and the corresponding public participation process.
• When is the EBS power plant scheduled to be built?
  Even if the regulatory approval processes and requirements are handled expeditiously, the facility is not expected to begin operations before 2028.