Netnod comments on models for contingency supply and planning

Netnod sees some advantages to the proposal for models for contingency supply and planning, especially the fact that the inquiry took place and that these issues are continuously being investigated. However,  Netnod believes significant investigation is needed to properly handle issues related to contingency support and planning for privately held infrastructure, such as the electricity grid, electronic communications infrastructure, and similar large scale national infrastructure interests.

Specifically, the inquiry does not delve into how private entities handle investment costs, which means the incentives for infrastructure investment are not covered in the inquiry. This is of concern, especially given the finding of earlier inquiries such as the following statement related to the initial privatization of Swedish electric power sector:

[the privatization of the electric power sector] can result in postponement of investments, a higher return requirement, a lower fixed cost share and increased small-scale investments.

(translated from SOU 1995:14, pp 63-64)

The current inquiry (SOU 2023:50) does not examine how private corporations should be incentivized to make significant infrastructure investments over accepting higher margin costs for the production of services.

There are minor comparisons between the coordination of contingency planning for the electronic communications sector and the electric power sector in the inquiry, where thorough investigation and comparison are needed

Netnod is positive to the fact that electronic communications are given a larger focus. However, the inquiry does not seem to consider the full extent of the dependencies on functional electronic communications, and specifically the Internet, for many important and critical functions.

The full response is available below.