Unanimously, the board of directors of ANEEL (National Electric Energy Agency) has moved forward with regulating electricity storage. The summit demanded regulatory activities to address the inclusion of storage systems in transmission, distribution and consumption in the next review of its regulatory agenda, for 2025 and 2026.
The directors also approved the holding of a second phase of public consultation to gather more subsidies and contributions for the preparation of the draft normative resolution, a process that will also include reversible hydroelectric plants.
“A ANEEL has been involved in this storage issue, following the entire trajectory of insertion of new technologies. Regulation tends to be slower than the market, and now we have to speed up this matter”, highlighted the general director, Sandoval Feitosa.
The second phase of the public consultation will last 50 days, ten less than the first stage. It begins this Thursday (12) and will continue until January 30 next year.
A ANEEL has been addressing the specificities of open-cycle reversible hydroelectric plants. Since they are not connected to a watercourse and do not interfere with the hydrological regime, they have mechanisms for storing excess energy, which is used in subsequent periods of peak demand.
Next year, the agency should also address other complex issues, such as aggregators, simulations in computational models, exploration of new business models (storage applications to mitigate curtailment and constrained-off of generation plants) and the deepening of structural definitions on revenue stacking.
Analysis of the first phase of the Public Consultation
A ANEEL released the results of the analysis of contributions to the normative (SN) and non-normative (SNN) solutions presented in the first phase of the CP. Check them out below:
SN 1 – Definition of Amounts for Use of Transmission and Distribution Systems (MUST/D)
After analyzing the contributions, the ANEEL considers that Alternative 1 is appropriate for the general case. The proposal defines that the power of the SAE (Energy Storage System) must be included in the contracted power range.
The Agency also considers it appropriate to allow the adoption of Alternative 3, except for existing installations, provided that certain conditions are observed that allow the reduction of the floor value of the power band and peak-shaving of generation.
SN 2 – Definition of the form of contracting the use of the network (CUST/D)
The option chosen was Alternative 1, which allows for association (several grants in just one CUST/D). According to the Agency, the aim is to simplify and reduce administrative and regulatory costs, so that the information is accommodated in just one contractual instrument.
It is worth noting that, in the case of SAE co-located in a consumer unit, the injection of power into the grid will not be permitted, and the contracted injection demand must be set to zero. This is because consumer units do not have a legal or regulatory grant or provision that authorizes the injection of energy into the system after connection.
In the case of consumer units with distributed microgeneration or minigeneration, as provided for in Law 14.300/2022, the use of SAE is already regulated in Resolution 1.000/2021.
SN 3 – Definition of the network usage tariff to be applied (TUST/D)
Regarding the form of contracting the network usage tariff (TUST/D) to be applied to the SAE, the majority of contributions chose Alternative 1, in order to apply a specific tariff based on a dominant profile.
However, the ANEEL identified the need for adjustments to the concept of “dominant profile”, prioritizing the assessment of the impact of SAE on the system, instead of just considering the amounts of use.
Based on this, the Agency proposes that pricing be guided by the effective costs allocated to the system, recognizing the bidirectionality of power flows and the potential overload that SAEs can generate on the grid. This approach reinforces the alignment between tariff incentives and the efficiency of the electrical system.
A ANEEL further considers adding the following developments to the alternative:
- Avoid double billing for network usage;
- Define predominant portion, as generation or as consumption;
- Calculate predominant burden share; and
- Calculate the additional installment, depending on the difference between the amounts of generation and consumption usage.
SN 4 – Granting method for reversible plants in closed or semi-closed cycle
After analyzing the contributions, the ANEEL chose to maintain the adoption of Alternative 1. According to the Agency's analysis, this proposal is the one that provides the greatest technical and regulatory simplicity, and the granting of UHR will be carried out in a manner analogous to that of generating plants.
SN 5 – Definition of the granting method for the addition of reversible units to existing hydroelectric projects
The initial option of ANEEL was Alternative 2. According to the Agency, this proposal allows the addition of a reversible unit to an existing electrical project through a process of changing technical characteristics, similar to the process of expanding power that exists today. Most of the demonstrations ratified this choice.
SN 6 – Creation of a grant mode definition for the Autonomous Storage Agent
The analysis of the contributions resulted in proposing that Alternative 4 be adopted, provided that the agent's relationship with the CCEE (Electric Energy Trading Chamber) and the ONS (National Electric System Operator) is maintained.
This ensures that commercial transactions are supported and that the installation can communicate with the operations center, to monitor power flow and possibly receive commands from the operator, to guarantee systemic security.
SN 7 – Definition of the granting method for generation plant – other sources – with SAE
There was consonance between the proposal initially defended by ANEEL and most of the contributions received. Thus, ANEEl chose Alternative 1.
This proposal allows the sector agent to request the change of technical characteristics for the insertion of the SAE or the issuance of an independent grant for the SAE, even if the asset is co-located with the generator.
SN 8 – Improvement of the remuneration method involving SAE
The contributions received converged with the initial choice of ANEEL, Alternative 1, with the stacking of competitive services enabling the agent responsible for the SAE to receive multiple revenues.
This alternative aims to encourage the insertion of SAE via competitive markets (free markets), which should not be confused with possible proposals for the insertion of SAE by the Granting Authority in its sectoral planning (regulated markets).
SSN 1 – Disclosure of regulatory and market data in the Brazilian electricity system
A ANEEL chose to define which information will be subject to publicity as well as the method to be adopted after completing the regulatory stage.
SNN 2 – Encourage research projects and pilot projects
Based on the analysis of the contributions, the Agency recommends that Alternative 1 be adopted, which proposes encouraging the implementation of individual RDI projects and creating regulatory sandboxes to explore business models via learn-by-doing or solutions for critical load/flow points in the system.
SNN 3 – Bringing reference technical teams closer together
For this solution, the ANEEL understands that it should seek to establish cooperation with national and international bodies in the electricity sector to develop joint studies, share experiences, and train teams with regard to SAE (Alternative 1).
SNN4 – Expand knowledge about electrical energy storage systems
About this item, the ANEEL accepted most of the contributions received. Therefore, it understands that this Agency should seek to promote training on the topic.
SNN5 – Combine agendas between institutions and publish them
Alternative 2 was chosen: create a joint institutional agenda between several entities in order to regulate the topic in a more comprehensive way, focusing on results and deadlines
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