Flex›Source - Svk Träffa Balansmarknad Forum 2

Source - Svk Träffa Balansmarknad Forum 2

Presentation — Träffa Balansmarknad, Forum 2 (November 2021, published 26 November 2021). Svenska kraftnät. Presenters: Jenny Lagerkvist, Mats Elmér, Zarah Andersson, Maja Isaksson, Andrea Badano (analysts); Mikael Brask (project manager, BSP/BRP).

Internal stakeholder forum presentation explaining Svk’s position on the BSP (Leverantör av balanstjänster) and BRP (Balansansvarig part) role split, and the placement of the independent aggregator (Oberoende aggregator, OA) within this market structure. The “Träffa Balansmarknad” series was a recurring dialogue between Svk and market actors on balancing market development. Documentation was published on Svk’s “Möt Svenska kraftnät” meeting page.

Summary

The presentation covers two overlapping regulatory reform layers: the EB GL (Balancing Regulation 2017/2195) introducing the BSP and BRP roles, and the Clean Energy Package introducing the independent aggregator (OA) role. The Ei R2021:03 report on independent aggregators is described as having been submitted to the Infrastructure Ministry for further processing.

BSP and BRP — legal basis and timeline

  • BSP/BRP roles replace the previous single balansansvarig role
  • Legal basis: EB GL Arts. 16–18; implemented through Ei-approved Svk villkor
  • Timeline as of the presentation: Svk submitted terms to Ei in 2018 and 2019; Ei issued change requests in 2019 and 2020; a third version (version 3) was being consulted by Ei at the time
  • Svk’s position: balanstjänster (balance services) in the BSP context means FCR and FRR

Definitions used

  • Leverantör av balanstjänster (BSP): a market actor with units or groups providing reserves and offering balance services to TSOs
  • Balansansvarig part (BRP): a market participant (or their designated representative) responsible for the actor’s imbalances

Svk’s position on the independent aggregator (OA)

Svk holds that the OA role is not a unique market role but a function exercised through existing roles:

  • An aggregator acting on the balancing market does so as BSP
  • A BSP must take responsibility for its imbalances — either by being a BRP itself or via a BRP of its own choosing
  • The independence principle (no need for supplier consent) governs market access, not the fundamental balance responsibility obligation

Svk’s target model

The model rests on the principle that BSP delivers the balance service and is/has a BRP of its own choice; the BRP is independently responsible for the imbalance at that point; BSP and BRP are independent of one another.

Four role design principles:

  1. Roles must be commercially viable and possible to implement
  2. No negative effects between roles
  3. Must fulfil legislation
  4. Scalability

Five BSP design principles:

  1. Independent BSP
  2. No negative effect on other actors
  3. Asset owner as central party
  4. No mandatory BRP for BSP? (question mark — unresolved at time of presentation)
  5. Scalability

Four open questions explicitly listed by Svk

Svk identified four unresolved design challenges in its target model:

  1. Verification of BSP delivery: how to verify that the BSP actually delivered what was activated
  2. Compensation/information to electricity supplier (LEV): should there be one? Yes or no? Method? How?
  3. The purpose of BSP’s own BRP: what is the BSP’s BRP for, given the BSP is independent?
  4. Phased implementation: how to sequence the rollout

Question 2 maps directly onto the compensation mechanism debate in Ei R2021:03 and the KKV critique.

Ongoing dialogue

Svk ran an open discussion group for BSP/BRP questions: short meetings with 2-day advance notice, agenda and meeting link sent one week ahead, interested parties could register. The next Träffa Balansmarknad forum was scheduled for 17 December 2021.

Key claims

  • Svk’s legal interpretation: aggregator = a function, not a separate market role — it participates in balancing markets through the BSP role
  • BSP independence from BRP is a legislative requirement; Svk accepts this constraint
  • The four open questions reveal where Svk expected implementation complexity as of late 2021 — all four remained active design problems in the eventual BSP/BRP implementation years later
  • Svk’s art. 18 villkor process (Ei approval cycle) was the formal constraint preventing faster implementation

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