EN 
PT_BR 
A ANEEL (National Electric Energy Agency) concluded, this Tuesday (5), the Public Consultation No. 30/2022, which dealt with possible changes to the deadline for adapting electricity distributors to the determinations of the REN 1,000 (Normative Resolution 1,000/2021).
The Body granted the deadline change in three articles (64, item III; 257 and 598). Resolution 1,000 consolidated, in 2021, 64 Agency resolutions relating to the rights and duties of consumers and others involved with the supply of electricity.
The changed deadlines refer to the following points:
Instruction of processes regarding measurement defect and irregularity (Arts. 257 and 598)
Implementation: until September 30, 2022 (previously until March 31, 2022)
According to ANEEL, the text of the resolution was modified to make it clear that the measurement defect and irregularity processes must be made available in the reserved internet service space by December 31st of this year.
A document will also be included to explain the consumer's right to request and receive information on measurement defect and irregularity processes during this transition period, within a period of up to 30 days (art. 409).
Issuance of the connection budget (Art. 64, III)
Implementation: until December 31, 2022 (previously until March 31, 2022)
For requests filed by December 31, 2022, the deadlines in the previous version of the PRODIST Module 3 (Distribution Procedures) for issuing the connection quote, which lasts up to 60 days for a consumer unit with distributed minigeneration, and up to 120 days for connecting a generating plant, another energy distributor, energy importing agent or energy exporter.
A Public Consultation No. 30/2022 was held from June 1st to 10th, 2022 and received 61 contributions from the 14 participants listed, including associations, agents and foundations and councils representing consumers. Of the 61 contributions, 20 were fully or partially accepted by the ANEEL technical team.
Analysis of changes
In evaluating Einar Tribuci, partner at Tribuci Advogados and legal and tax director at ABGD (Brazilian Association of Distributed Generation), such changes only hinder the sector and occurred to benefit distributors, for two reasons. “They would have to have a very transparent procedure to resolve problems related to billing and compensation, which would come into force now due to REN 1,000 of 2021”.
“However, the result of the public consultation came to change the validity of these deadlines, extending them to December 31, 2022. So, distributors get one year to provide this transparency”, he pointed out.
In the second (Art. 64, III), Tribuci commented that the deadline for the distributor to provide the budget for connecting plants was changed with REN 1,000 to 45 days, and now ANEEL is backtracking, giving a deadline of 60 days, returning to what existed before REN 1.000 in the PRODIST manual.
“In this case, the Agency is retroacting all the progress we were making in the year of the access request race, where everyone wants to see the budget for the work as soon as possible”, he concluded.
2 Responses
Henrique Prado is absolutely correct, there are still “doubts” in the calculations between Injected and Consumed, and what draws the most attention, in the last 3 months, the DG tariffs with Solar have changed, they are not described in the invoices, they claim that there were errors in the ICMS calculations, among other things, everything is very obscure, not at all enlightening, even the professionals at the concessionaires and permission holders are lost in relation to the calculations, no one can explain it.
My personal opinion, I have the impression that the regulatory agency that was created to defend the interests of users, works in defense of the interests of distributors. Given that we have numerous problems regarding incorrect measurements by distributors, between the injected volume (GD) and what is actually considered; including in this “package” the division of the same volume, which is electrical energy, into TE and TUSD. With this procedure, they remunerate with a discount of up to 48% of the injected TUSD. This is characterized as inconsistent, as there is nothing in this case to justify the discount, much less the ICMS charge. Observation is simple! There is no merchandise in the transport process, much less its circulation, as electrical energy is generated at the place of consumption and the discount is unmentionable.