Since 1 April 2025, the system service ‘Utilisation instead of curtailment’ under Section 13k of the Energy Act (EnWG) may be applied not only by transmission system operators (TSOs) but also by distribution system operators (DSOs) to prevent -related curtailments of renewable energy in independent DNO relief regions. This is possible provided that the requirements under Section 13k(8) of the EnWG are met and coordination with the TSOs has taken place.
The key requirements under Section 13k(8) of the EnWG are as follows:
- The distribution system operator must operate a network with a nominal voltage of 110 kilovolts to which more than 100,000 customers are connected, either directly or indirectly.
- The DSO must not be affiliated with an operator of a load shedding facility or an aggregator of switchable loads for the purposes of participation under Section 13k of the Energy Act (EnWG), or with a facility as defined in Section 3(41) or (48) of the Renewable Energy Sources Act (EEG).
- The amount of active power reduction from installations under Section 3(1) of the Renewable Energy Sources Act in accordance with Section 13a(1), the cause of which lay within the operator’s own electricity distribution network, must have been at least 100,000 megawatt-hours in each of the last two calendar years.
- The distribution system operator must be able to make appropriate generation and curtailment forecasts.
- The relief region designated by the DSO must not overlap geographically with a relief region designated by a TSO.
- The further requirements pursuant to Section 13k(2) to (7) of the Energy Act (EnWG) shall apply accordingly.
In order to enable initial implementation from 1 April 2025, the TSOs have, at an early stage, requested written expressions of interest from DSOs that meet the above requirements and wish to designate a relief region in accordance with Section 13k of the Energy Act (EnWG).
Expressions of interest from DSOs that meet the above requirements are still welcome.
To do so, DSOs should please complete the following contact form and select the topic ‘Benefit instead of curtailment’.
Please provide the following initial information:
- Name of the distribution network operator (DNO), including contact person
- Voltage level of grid operation
- Number of direct and indirect customer connections
- EEG curtailment volumes and number of EEG curtailment hours over the last two calendar years
- Where might Section 13k of the Energy Economy Act (EnWG) apply in your DSO network area?
- What level of granularity is used for demand (large or small regions)?
- How many activation hours would be expected in the load-shedding region?
- Please name any potential participants or existing enquiries from stakeholders, where available.
The TSO, DSO and BNetzA have agreed that, upon receipt of an expression of interest, a separate annex to the implementation plan for application in the distribution network will be drawn up jointly by the TSO and the DSO. This will enable a standard for non-discriminatory implementation to be established in the distribution network as well, in accordance with Section 13k(8) of the Energy Act (EnWG), in consultation with the BNetzA. A lead time of at least 6 months should be allowed for implementation.