BGWEA Participation in EWRC Public Consultation: We Call for Faster Regulatory Changes for the Balancing Marke
On August 31, 2026, the Energy and Water Regulatory Commission (EWRC) held a public consultation on a draft report related to the modernization of the energy sector. The Bulgarian Wind Energy Association (BGWEA) took part in the discussion, expressing in-principle support for the regulator’s efforts, but drawing serious attention to the need to shorten the set deadlines for implementing the defined measures and regulatory changes that the EWRC and the Electricity System Operator (ESO) must develop regarding the subsequent participation of new technologies in the balancing market.
Scope of the EWRC Report
The publication of the report is required to fulfill milestone 351, Reform C13.R3 of the National Recovery and Resilience Plan (NRRP). The document itself does not introduce new rules but provides an in-depth analysis of the current situation, the challenges, and the necessary measures and regulatory changes. It covers three main areas:
- Assessment of the regulatory conditions for the participation of energy storage systems and industrial consumers in the balancing market.
- Cost-benefit analysis of the installation of smart meters for household and non-household customers with an allocated capacity of up to 100 kW.
- Measures to remove barriers to demand-side optimization.
As we shared during the discussion, BGWEA welcomes the prepared report and believes that all three analyses are very important steps towards refining the regulatory framework and providing the necessary environment for the modernization of the Bulgarian energy sector.
During the consultation, we also highlighted an important finding by the EWRC: compared to the previous five years, there has been an increase in technological diversification and market demonopolization. This positive effect is precisely due to the active participation of renewable energy sources (RES) and battery energy storage systems (BESS) following the regulatory changes introduced in 2024.
As is evident from the aggregated data for automatic secondary regulation (aFRR) and manual secondary regulation (mFRR) in 2026 presented in the EWRC’s draft report, RES and batteries now dominate downward balancing capacities with a share of over 40%, while their share in upward regulation has increased more than 10-fold compared to 2025. This proves their growing potential and technical capabilities to participate in the provision of balancing services, which strongly argues the need for further regulatory changes to facilitate their expanded participation.
At the same time, the report makes it clear that although RES and batteries can technically provide frequency containment reserve (FCR) services, they are still unable to participate in the market due to regulatory and administrative barriers. For this reason, the provision of this system service is still carried out 100% by conventional thermal (condensing) power plants.
The measures identified by the EWRC that can be taken to address the gaps hindering the further penetration of BESS and demand-side response (DSR) in the balancing capacity market are defined as follows:
- Phased introduction of auctions for the procurement of ancillary services capacity for shorter validity periods, or secondary auctions for unallocated ancillary services capacity, as well as the introduction of two-way auctions for ancillary services capacity.
- Provision of positive and negative reserves for frequency containment reserve (FCR) services and frequency restoration reserves (FRR).
- Following a sufficient increase in market competition, measured by market concentration indices for FCR services and aFRR and mFRR reserves, a market-based model for allocating funds among different types of reserve capacity could be introduced.
- Amendment of the Electricity System Management Rules (PUEES) in order to introduce technical conditions for the new technologies.
- The Transmission System Operator (TSO) should organize a public training session every quarter for all interested parties to facilitate their participation in the balancing market.
Main Concern: Reform Deadlines Are Too Distant
BGWEA’s main concern, expressed during the hearing, is related to the deadlines set in the EWRC’s proposed implementation schedule for the identified measures. Setting a timeframe all the way to the end of 2027 for changes to the Electricity Trading Rules (PTEE), the Electricity System Management Rules (PUEES), and the TSO’s Auction Rules is too distant a horizon.
The RES sector and batteries are developing with extraordinary dynamism. Artificially delaying the regulatory framework until 2027–2028 will stall private investments in flexibility and maintain the system’s dependence on coal-fired power plants.
In this regard, BGWEA urges the EWRC to:
- Review and shorten the set deadlines.
- Define a clear mechanism for lifting price caps upon achieving a certain level of market competition.
Support for the Accelerated Deployment of Smart Meters
Regarding the second part of the report, which includes a scenario for the accelerated replacement of 3.31 million electricity meters between 2027 and 2031, BGWEA fully supports the Commission’s conclusion on the economic viability of the measure. The accelerated rollout of smart meters is a critically necessary infrastructural prerequisite for modernizing the electricity distribution networks, developing the active participation of customers, and enabling them to benefit from price incentives.
Positions were also expressed at the public consultation by representatives of ESO EAD, APSTE, ASEP, and the electricity distribution companies. BGWEA will use the established deadline for submitting opinions to formally submit its arguments and specific proposals on the report.
Companies and organizations can submit opinions on the EWRC report within 14 days; the regulator will issue a ruling at a closed session scheduled for August 21.
The draft report is available on the EWRC website at: https://www.dker.bg/index.php?mact=CGCalendar,cntnt01,default,0&cntnt01event_id=1439&cntnt01display=event&cntnt01returnid=101
