Ellevio Bilaga B Samrådsredogörelse (2024)

Title: Bilaga B: Samrådsredogörelse — Nätutvecklingsplan 2025–2034 Document type: Consultation report (samrådsredogörelse) — Annex B to Ellevio’s DNDP Language: Swedish

Mandatory consultation summary submitted alongside Ellevio’s DNDP under EIFS 2024:1. Documents the full consultation process, all 41 respondent replies, and Ellevio’s responses to each. Provides important context on stakeholder expectations, what changes were made to the final DNDP, and Ellevio’s stated positions on contested questions (municipal granularity, investment detail, flexibility stance).

Key claims

Consultation process

The preliminary DNDP was published on 13 September 2024 with written response via web form until 31 October 2024 (approximately 7 weeks). Email responses were also accepted after questions came in through other channels. Municipalities were granted an extended deadline to 15 November 2024 to accommodate municipal decision-making processes; further extensions were granted on request.

Two digital information sessions were held during the consultation period; approximately 80 participants attended.

41 responses received, from: municipalities, regional bodies (regioner), county administrative boards (länsstyrelser), power sector entities, and other grid companies. List of respondents:

Municipalities (23): Mariestads kommun, Täby, Kungsbacka, Varbergs, Munkedal, Hudiksvall, Hagfors, Eda, Mölndal, Tjörn, Malung-Sälen, Laxå, Strömstad, Orust, Rättvik, Säter, Mora, Lekebergs, Kristinehamn, Öckerö, Gagnef, Nynäshamn, Stockholms stad.

Regions: Region Halland, Region Stockholm, Region Dalarna, Region Gävleborg, Region Örebro.

Länsstyrelser: Hallands, Örebro, Gävleborgs, Stockholms, Värmlands, Dalarnas, Västra Götalands, Västernorrlands.

Grid/energy companies and others (5): Affärsverket Svenska kraftnät, Fortum Sverige AB (×2, hydropower and general), Framtidskraft Skaraborg, Falu Elnät AB.

Recurring themes and Ellevio’s responses

1. Request for municipal-level granularity

Multiple municipalities and regions requested more detail at municipality level — which investments affect which specific municipalities, and municipal-level capacity forecasts. Ellevio’s position: for this first DNDP edition, investment descriptions focus on investeringspaket (packages of related projects) at regionnät level rather than individual projects per municipality. Rationale: a project can physically reside in one municipality but affect adjacent ones directly and others indirectly — simplistic municipal attribution risks creating more confusion than clarity.

Ellevio’s commitment: this is flagged for improved treatment in future DNDPs. Continuous bilateral dialogue with municipalities remains the preferred channel for specific questions.

2. Local grid investments not prominently featured

EIFS 2024:1 requires reporting of huvudsaklig distributionsinfrastruktur (primary distribution infrastructure). Ellevio defined this as regionnät investments — local grid (lokalnät) investments were not individually reported because: (a) the number of projects is very large and reporting all voltage levels would quickly make it hard for readers to see where the significant capacity-enabling investments are, and (b) lokalnät investments usually have a different time perspective than the 5–10 year DNDP horizon, and utilities can generally build away constraints faster at those levels.

Final version addition: supplementary information on how lokalnät investments are continuously planned (§3.2.1 in the final version) was added in response to consultation feedback.

3. Remaining risk of constraints

Several respondents requested clearer information on whether constraints persist at specific points in time (near-term vs. end-of-period). Ellevio agreed and clarified the adequacy assessment in §4 of the final DNDP to explicitly state short-term, medium-term, and end-of-period adequacy per delområde.

4. Map color coding

The color coding of delområden in the preliminary version was misinterpreted as having significance. Ellevio clarified it was arbitrary (each area needed a distinct color). Changed to alternating green/orange in the final version for readability. Side effect: delområden appear in a different order in the final document.

5. Terminology / accessibility

Feedback that language was sometimes technical and hard for non-specialist readers. Ellevio added a glossary of terms (ordlista) to the final version — the same glossary visible in the final DNDP text.

Notable specific responses

Täby kommun (response #3): Täby’s own energy plan (KF 17 April 2023) quotes utilities’ load forecasts of a 25–30% power increase (up to 200 MW) by 2040. Ellevio’s DNDP shows roughly +15% to 184 MW by 2034. Täby stated that the gradually increasing annual need in Ellevio’s DNDP “in principle” appears to match the need in the energy plan to 2040 (the response itself gives the energy-plan range as both 25–30% and 25–40%). Ellevio simply agreed and looked forward to continued dialogue.

Falu Elnät AB (response #2): Raised capacity challenges in Falun’s 50 kV grid (radial feeding toward Tänger, Långnäs, Linghed, Svärdsjö) that were not addressed in the preliminary DNDP. Also argued that reinforcement toward Grycksbo should be included, noting that consumption as well as production is constrained. Ellevio took the comment into account and made clearer in the final DNDP that capacity challenges exist in this area; it noted that the Grycksbo reinforcement is a sub-investment within investeringspaket DAL 7.

Mariestads kommun (response #1, first to respond — 16 September 2024): Confirmed that the municipality’s earlier input (2024-03-06) had been incorporated in Ellevio’s forecasts. Also asked whether a specific unnamed company’s (Företag 1) connection plans were included. Ellevio confirmed all communicated plans were in the forecasts but cited confidentiality as reason for not naming specific connections.

Affärsverket Svenska kraftnät (response #22): Svk called the plan informative and said it offers few surprises: Ellevio’s overall conclusions on needs to 2034 confirm Svk’s own current outlook analysis, thanks to close cooperation on production and consumption forecasts. Svk’s remaining comments were clarifications: a probable error in Table 1 (Ekerö, 2028); the unclear term “svag stamnätsreserv” (§2.3.1); that only the Hallsberg–Timmersdala–Stenkullen reinforcement is finally decided while a new 400 kV line Hallsberg–Timmersdala is still under investigation (§2.3.10); that advance notice (förhandsbesked) for increased offtake at Tovåsen was given 2024-10-02 (§2.3.14); unclear units and terms in Table 3 (§3.3.1); and confusing Yes/No column wording in the §4 table. Ellevio made clarifications in the final DNDP (Table 3 now states MW and regulation of consumption or production), but said the §4 table follows Ei’s guidance and cannot be changed by Ellevio. Svk was also emailed the preliminary DNDP directly on publication.

Region Halland (response #4): Requested a different report disposition and a longer consultation period, and asked for more on energy-source diversity, redundancy and protection of critical infrastructure. Ellevio referred to EIFS 2024:1 and Ei’s guidance, which define the contents and disposition and set the consultation minimum at six weeks (Ellevio’s ran about seven); it said redundancy and security topics are not covered by the DNDP or its regulations.

Fortum Sverige AB (responses #23 and #32): Two responses, registered as Fortum Sverige AB (Hydro) and Fortum Sverige AB. The Hydro response asked for clarification of Tables 1–2 (what “överföringskapacitet” means), the VÄR and SKA investment-package names, and which delområde the Lindbacka station belongs to; Ellevio clarified the Lindbacka placement in the final version. The second response asked why Fortum was not invited to dialogue, how Fortum’s Borgvik wind farm application was treated in the forecast, where VÄR2 sits topologically, what flexibility could support wind feed-in in Värmland, and whether Vattenfall’s Borgvik transformation is a feed-in constraint. Ellevio cited confidentiality for not commenting on specific connection cases, said conditional or bilateral agreements are the main tool for large wind volumes, and said feed-in at Borgvik is currently limited by the feed-in subscription, which cannot be raised because of stamnät capacity limits.

What changed between preliminary and final DNDP

Based on consultation feedback, Ellevio made the following substantive changes to the final DNDP:

1. Falun 50 kV capacity challenge made explicit in the final DNDP (Ellevio’s reply refers to the area, not a specific section)
2. Adequacy assessment (§4) clarified with explicit short/medium/long-term decomposition per delområde
3. §3.2.1 added: supplementary information on lokalnät investment planning approach
4. Map color scheme changed (alternating green/orange instead of arbitrary distinct colors)
5. Glossary (ordlista) added to front matter
6. Clarifications in response to Svk and Fortum comments (e.g. Table 3 unit, Lindbacka delområde), a lighter colour shade for delområden where Ellevio has regionnät but another company runs the lokalnät, and minor clarifications and typographic corrections throughout

Not changed: municipal-level granularity deferred to future editions; security/resilience topics confirmed as outside DNDP scope.

Relevance to existing wiki topics