A year that begins and a review that will come to an end

Despite all this, we still need to pay attention to the review process
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2020 has arrived and, as we prepare to start the new year, we also know that the review process of REN 482 is coming to an end, which has already been going on for almost two years and whose main objective is to discuss what the new way of value the energy credits produced by the consumer who decides to have a micro or minigeneration system. 

As we enter the final stretch of this discussion, it is important to keep in mind what lies ahead: the fourth stage of the process. In it, ANEEL is obliged to analyze all contributions submitted in writing – until 12/30/2019 – and issue a Technical Note informing its position on each of the points suggested by the sector and society. Furthermore, the Agency will also review the previously proposed draft text (on the fateful October 17, 2019), making any changes it deems necessary. 

But in practice, what does this mean? To keep things simple, here are three key messages you need to keep in mind:

  1. We won’t have a new REN 482 overnight (literally): Many people were afraid that the end of the deadline on 12/30/2019 meant that the new REN 482 would come in the following days. This was impossible exactly because of the procedure we described above, which needs to be followed. In practice (and in our experience) these analyzes take around 3 months – that's why we say that news should come around March or April 2020.
  2. Voting on the new REN 482 is public and you can follow it online or live. After making changes to the draft text presented previously, it will be sent for consideration and voting by the Board. These meetings are public and broadcast online too!
  3. The publication of the new standard does not mean that it will come into effect immediately. In law, we have an expression that means “vacatio legis”, which is the vacancy of the law. Although REN 482 is not a law, it works in the same way: it is the deadline set out in the standard for it to come into force. In other words, we may have a new REN 482 published in April, but predicting that it will only begin to take effect six months later, or even the following year. 

Despite all this, we still need to pay attention to the review process, because, as we have already said, we are in the final stretch. There is still a lot of room for profound changes in the text proposed by the Agency and only the active participation of each of us will make this possible. 

And, by the way, did you send your contribution on the 30th?

Picture of Bárbara Rubim
Barbara Rubim
She is vice-president of the Board of Directors of ABSOLAR (Brazilian Photovoltaic Solar Energy Association) and founder of the consultancy Bright Strategies.

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