Successful support of a recognition procedure under Section 12h of the German Energy Industry Act (EnWG) lays the foundation for the long-term financing of a critical grid security function.
Ensuring a reliable electricity supply does not end with day-to-day grid operation. Equally important is the question of how the energy system can be restored following a large-scale power outage. For this purpose, so-called black start-capable facilities are essential. They enable the restoration of the power system without relying on an external electricity supply and thus represent a key prerequisite for security of supply.
On behalf of SachsenNetze GmbH, E-Bridge worked together with experts from SachsenEnergie AG to analyze the costs associated with black start capability within the SachsenNetze service area, assess them from a regulatory perspective, and prepare the required documentation for the recognition procedure before the Federal Network Agency (Bundesnetzagentur) in accordance with Section 12h of the German Energy Industry Act (EnWG).
Recognition of Necessity by the Federal Network Agency
The procedure was successfully concluded: the Federal Network Agency recognized, in principle, the necessity of contracting black start capability for SachsenNetze. The assessment of the eligible costs will now take place in a subsequent procedure based on the expert report prepared as part of the project.
This decision marks an important step toward securing the long-term financing of this safety-critical function. At the same time, it provides distribution system operators with greater planning certainty when implementing measures to strengthen grid resilience.
Growing Importance of Black Start Capability for Distribution System Operators
The energy transition is fundamentally changing the structure of the energy system. As electricity generation becomes increasingly decentralized and the generation landscape continues to evolve, the requirements for grid restoration are becoming a growing focus for distribution system operators.
While black start concepts have traditionally been anchored primarily within transmission networks, distribution system operators are increasingly required to develop their own solutions to restore their grids in the event of major disruptions. As a result, regulatory mechanisms that enable the recovery of related costs are becoming increasingly important.
E-Bridge Supports Analysis and Regulatory Recognition Procedures
As part of the project, E-Bridge supported SachsenNetze in addressing, among others, the following topics:
- Analysis of regulatory requirements under Section 12h EnWG
- Identification and derivation of the associated costs
- Development of a robust justification for the recognition procedure
- Support throughout the process up to the recognition of the fundamental necessity of black start capability
The successful completion of the project highlights the importance of combining technical expertise, economic analysis, and regulatory know-how when implementing measures that are essential for security of supply.
Working Together for a Resilient Energy System
We would like to thank SachsenNetze GmbH and SachsenEnergie AG for their trust and excellent collaboration. We are pleased to contribute our expertise to strengthening the security of supply and resilience of the energy system.
Steffen Boche, Maximilian Lauer, and Dr. Baris Özalay


