Source - Energiföretagen NC DR National Conditions Webinar (2024)
Type: Webinar presentation (Energiföretagen Sverige, öppen) Presented by: Jonna Söderberg (Energiföretagen), Erik Lejerskog (Sweco) Date: 2024-04-18 Title: “EU-förordningen Demand Response och elnätsföretagens nya roll”
Industry webinar explaining the forthcoming NC DR and proposing a governance model for Swedish national conditions (nationella villkor). Organized by Energiföretagen through Eldistributionsrådet and AG Flex Elnät. Invited all Swedish distribution network companies. Deadline for responses: May 15, 2024.
Context
As of April 2024, the NC DR was expected to enter into force “beginning of 2025” (this estimate has since proved optimistic; as of June 2026 the Commission text has not been published). Energiföretagen used the webinar to:
- Explain what the regulation requires and why
- Propose how Sweden should organize the development of national conditions
Key claims
NC DR Title VII is the central chapter for DSOs
The regulation’s Title VII — TSO/DSO Coordination is described as the core chapter that shapes the DSO’s operational role. National conditions must be developed for Articles 70–77:
| Article | Requirement |
|---|---|
| Art. 70 | General principles for SO coordination |
| Art. 71 | DSO observability area definition |
| Art. 72 | Congestion and voltage forecasting using active power |
| Art. 73 | Principles for solving congestion and voltage issues |
| Art. 74 | Short-term procedures for DSO operational limits |
| Art. 75 | Grid prequalification |
| Art. 76 | Data exchange between DSOs and TSO-DSO |
| Art. 77 | System balance principles |
New national conditions obligation — timeline and structure
Under the NC DR draft:
- Within 3 months of regulation entry into force: all distribution network companies and Svk must jointly submit a proposal for a national process for developing national conditions to Ei
- Ei then has 2 months to approve the process proposal
The national conditions themselves cover:
- Market design and business models
- Coordination between markets
- Coordination between grid levels / grid companies
- Aggregation models and imbalance correction for all market actors
- Prequalification processes for resources and service validation
- National flexibility register for resources in balancing and flexibility markets
- Procurement rules for congestion management services (incl. batteries)
- Local market operator rules
- Data exchange and communication protocols
Once adopted, national conditions have the same legal status as national föreskrifter.
The national conditions process is not a one-time exercise — the NC DR requires periodic review and updates, and European harmonization requirements will increase over time.
Swedish governance challenge
Sweden has approximately 170 distribution network companies (distributionsnätsföretag). This creates several structural challenges absent in most EU countries:
- Not all 170 DSOs are members of Energiföretagen — yet the obligation to develop national conditions applies to all DSOs
- Svk is not a member of Energiföretagen
- No existing body in Sweden covers all DSOs plus Svk with formal decision-making authority
- This is the first time DSOs in Sweden have had a statutory role in developing sector regulation
For comparison, when EU network codes like RfG were developed, it was Svk that received the assignment to draft proposals — not the DSOs.
Energiföretagen’s proposed governance model (hybrid solution)
Eldistributionsrådet and AG Flex Elnät proposed a hybrid solution:
- Energiföretagen provides the organizational infrastructure
- A formal decision process is established that is open to all DSOs, including non-members of Energiföretagen
- Modeled on the EU Drafting Committee approach (stakeholder committee)
Required elements:
- All Swedish DSOs represented (fullmäktige model with all DSOs)
- Governance board (styrelse) and working groups
- Formal process for DSOs to take independent decisions and positions
- Formal joint decision process with Svk
- Transparent stakeholder dialogue (not limited to Energiföretagen members)
- Earmarked financing (“öronmärkt”) for the organizing function as a “myndighetsuppgift”
Working hypothesis: Energiföretagen hosts the process with formalized participation rights for non-members; Svk participates via a separate joint process.
Ei R2023:18 — national DSO organization study
Ei and Svk jointly recommended in report Ei R2023:18 (also referenced in Ei2025:03 with Swedac) that the government study whether Sweden needs a nationally legislated organization for distribution and transmission network companies to fulfill NC DR obligations. This option mirrors how EU DSO Entity operates at EU level.
System operation states as the technical backbone
The NC DR Title VII framework is grounded in the SO GL system operation states:
- Normaldrift — all parameters within limits; N-1 maintained
- Skärpt drift — some parameters at limits; not all N-1 failures manageable
- Nöddrift — some parameter outside limits; emergency actions
- Nätsammanbrott — blackout; ≥50% consumption disconnected
- Återuppbyggnad — restoration
The N-1 security criterion and contingency lists (felfallslistor) form the operational basis for TSO-DSO coordination and the corrective/preventive actions framework.
Key principle: system cannot be operated in an “unanalysed state”
A central design principle attributed to SO GL / NC DR: scenarios for all foreseeable problems (congestion, balancing) must be analysed and handled in a coordinated way — in advance. The system must be proactively managed, not reactively patched (“not trial and error”).
Responsibility framework
“A fault in one party’s grid must not create unacceptable consequences in its own or others’ grids” — applies to TSO-TSO, TSO-DSO, DSO-DSO. The polluter-pays principle applies to cost allocation, but resources must be used with a systems perspective.
Relevance to wiki
- Network Code on Demand Response: Adds detail on the Swedish national conditions governance challenge (170 DSOs + Svk) and Energiföretagen’s proposed hybrid model. Also clarifies the 3+2 month statutory timeline for the national process proposal.
- Energiföretagen Sverige: Documents Energiföretagen’s specific organizational proposal (Eldistributionsrådet, AG Flex Elnät) and the hybrid decision-process model.
- Ei: Ei’s role as approver (2-month window) of the national conditions process proposal is defined here.
- Svenska kraftnät: Svk’s joint role in drafting national conditions alongside DSOs; separate formal joint process needed.
- Distribution System Operator: Clarifies why the NC DR is structurally unprecedented for Swedish DSOs — first time they have a formal role in developing binding sector regulation.
- Congestion Management: System operation states and N-1 framework as technical backbone of Title VII national conditions.
Data gaps
- How has the Energiföretagen hybrid model proposal evolved since April 2024? (Ei R2023:18 recommendation on a legislated national organization — government response?)
- Has Energiföretagen expanded beyond Eldistributionsrådet/AG Flex Elnät to a broader organizational structure for NC DR work by 2026?