Svensk Solenergi Remissvar Elmarknadsutredningen (2025)

Svensk Solenergi’s consultation response (dnr KN2025/01039, 1 September 2025) on the Elmarknadsutredningen’s report (Source - SOU 2025-47 Elmarknadsutredningen (2025)). It is an industry association’s advocacy, from the trade body for solar and energy storage; its figures are its own or quoted from others and are not checked against primary sources here.

Points relevant to batteries and the connection point

• Connection sizing. One of the biggest obstacles is that grid companies often size their networks to handle both a battery’s maximum charging at high consumption and its maximum discharging at high production, so connections are stopped until reinforcement and project costs become prohibitive. It asks the government to have Svk and the grid companies produce standardised agreement forms and dimensioning principles so batteries can be connected conditionally and quickly, citing the Netherlands.
• Queue figures (as quoted). E.ON, responsible for about a quarter of the Swedish grid, reports over 12 GW of large-scale batteries in its queue, and about 3.5 GW have applied for direct connection to the transmission grid according to Svk. The association thinks 10 to 15 GW and 30 to 60 GWh could be in operation by 2030 if connections are enabled. It asks for statistics on grid-connected batteries.
• Conditional agreements. It supports permanent villkorade avtal with a fixed (prima) and a conditional (sekunda) power, as an emergency brake used only for downward regulation when market-based alternatives are insufficient (Art. 13.3 of Regulation 2019/943).
• Tariffs. It wants symmetric, more time-differentiated network charges and says that high effektavgifter in periods of good supply weaken the price signal and the willingness to deliver ancillary services, “which is already visible in batteries’ run strategy in networks with blunt power tariffs”. It asks Ei to define the effektavgift method more sharply, and for network charges to be published in a machine-readable API so battery and EV charger controllers can read them. It cites Ei2025:06 as a good first step.
• Other: no CfD support for specific power types; a fossil-free strategic reserve; capacity maps and queue information in machine-readable form; market-based procurement of flexibility as the first tool.

Relevance

Industry-side view on why battery connection and tariff design interact. See Power Tariffs and Home Batteries, Flexible Connection Agreements and Capacity Maps. The official proposals it responds to are on Source - SOU 2025-47 Elmarknadsutredningen (2025).

Limits of this summary

Read in full (7 pages). The association’s claims, including the queue figures, are not verified against E.ON or Svk sources.