When consumer flexibility also benefits the system.

A business can reduce its bill with the White Tariff without changing a single consumption schedule. The savings may reflect a profile already concentrated outside peak hours, and not a new response to the tariff. Recognizing differences in service costs and encouraging behavioral changes are distinct functions of billing.

Therefore, paying less does not, in itself, demonstrate that joining has resulted in an additional reduction in costs for the electricity system.

I advocate separating the value that the consumer obtains from their resources from the added benefit of coordinating them with a network need. Flexibility contributes when it meets that need in the relevant place, at the relevant time, and for the relevant duration.

This alignment can result from the tariff signal itself, without direct command or specific contracting. When the aim is to ensure a contribution through availability and performance commitments, it is necessary to assess what these add to the operation that would already be taking place.

Public Consultation ANEEL Resolution 46/2025 discussed the automatic application of the White Tariff to certain low-voltage consumers with monthly consumption starting at 1.000 kWh. In this modality, the amount charged for consumption varies between peak, intermediate, and off-peak periods.

Monthly consumption figures, however, provide little information about adaptability: two establishments can consume the same amount of energy and operate at very different times. Comparing bills under each modality helps to assess the change, but it does not replace knowledge of the operation.

The ability to adjust schedules depends on the activity. In agricultural irrigation, for example, shifting consumption requires balancing management, water availability, climate, and crop risk. Before proposing a schedule, it is advisable to assess how much the operation itself allows for adjustments without compromising production.

For units billed under Group A, generally served at medium or high voltage, there is also a charge for power demand. Reducing peak demand does not automatically generate savings in this area: the result depends on the contracted demand and billing rules. These consumers can be captive or free market consumers. In the free market, the assessment includes the terms of the power purchase agreement, in addition to the network usage tariff.

Batteries illustrate how these conditions alter the value of a resource. Battery storage systems, known as BESS, can offset energy purchases, increase the utilization of on-site solar generation, or help manage billable demand, where applicable.

For those participating in the compensation system, its rules also come into play. The continued service to priority loads can justify the investment, provided that the project allows for their supply during an interruption.

In simulations of batteries behind the meter, EPE (Energy Research Company) identified greater economic potential in the management of consumption using A4 Green units, among the applications evaluated, including consumers from both the regulated and free markets.

The result depends on factors such as the tariff differential, consumption profile, and equipment cost. This does not exhaust other possibilities for application in medium voltage, where contractual and operational conditions can also alter viability. In any case, the savings obtained by the consumer does not, in itself, demonstrate an additional benefit to the network.

These uses can compete for available energy and power. Reserving power for a power outage limits what can be discharged to reduce the bill.

Power, storage capacity, required duration, and connection limits need to be evaluated together, as well as investment, operation, losses, and degradation. Benefits and revenues from different applications can be combined, provided their commitments are compatible and the operation can meet them.

The effect on distribution requires further verification. Discharging during peak hours can relieve a transformer or feeder if it reduces the flow causing the restriction at that point and time. If the problem occurs at another time, the consumer's savings may remain without addressing that local need. Subsequent recharging also needs to be considered in the analysis, as it can concentrate consumption and create a new peak.

On the scale of the SIN (National Interconnected System), the critical period can differ from both the local peak and the consumer's tariff period. In a study published in 2022, Forrester, Barbose, and Miller simulated peaks using data from approximately 1.800 North American residential consumers.

Under the conditions analyzed, the operation focused exclusively on solar self-consumption reduced bills, but made a limited contribution to the systemic benefits evaluated, partly due to the lack of surplus energy to charge the batteries on peak days.

The researchers also demonstrated that operating strategies guided by economic signals could increase this value, while respecting network constraints. The result illustrates how the way of operating can bring the interests of the consumer and the system closer together, without constituting an estimate for Brazil.

The allocation of the capacity reserve cost belongs to this systemic scale. Public Consultation MME 229/2026 proposed linking the ERCAP (Capacity Reserve Charge) allocation reference to the period of maximum net demand of the SIN (National Interconnected System).

The incentive depends on how this charge reaches those who can alter their consumption. Redistributing an already contracted expense does not reduce its total. Any future savings depend on whether the consumption response reduces operational needs or new contracts.

When the contribution requires specific commitments, it is necessary to know how much will be available, for how long, and how to verify performance. Installed capacity does not equate to operational availability.

In the distribution, the Public Consultation ANEEL Resolution 33/2026 discusses requirements for observation, communication, and control of distributed resources. These requirements must be proportionate to operational needs. However, meeting connectivity requirements is not equivalent to providing a paid service, the contracting of which depends on its own rules and obligations.

To evaluate this contribution, I propose starting with the identified operational need, verifying what the consumer's resources would already deliver without additional coordination, and comparing this result with an operation geared towards that need.

The analysis should consider availability, duration, recharge, wear and tear, opportunity cost, and coordination costs, while preserving the activity being served. When there is an additional benefit, it will be possible to assess how to recognize and compensate for it, including through commitments to reliable availability, even without activation. The contract should be compared with other solutions capable of meeting the same need.

A battery might only make sense for the savings or continuity it offers the owner. However, to secure its contribution to the system, it's necessary to demonstrate the benefit and evaluate its cost against alternatives, including operational adjustments without storage.

Compensation should take into account the additional costs, risks, and restrictions assumed by the consumer. The deciding factor in contracting should not be the presence of the technology, but the contribution it can provide and the conditions necessary to deliver it.

The opinions and information expressed are the sole responsibility of the author and do not necessarily represent the official position of the author. Canal Solar.