Flow reversal in the electrical energy distribution network

In collaboration with Clarice Coutinho and Marcelo Tanos

The inversion of flow in the electrical energy distribution network occurs when the amount of electrical energy injected, coming from distributed generation, is greater than the demand of consumers connected to that same network, which can cause overload, voltage imbalance and interruptions in the supply of electricity. electricity.

Understand the case

As established in § 1 of art. 73 of ANEEL Normative Resolution No. 1,000/2021, if the new connection or increase in injected power from micro or mini-generation involves inverting the power flow at the distributor's transformation station or at the feeder circuit breaker, the distributor must carry out studies to identify the viable options that eliminate such inversion, namely:

• Reconfiguration of circuits and load relocation;
• Definition of another electrical circuit for connection;
• Connection at higher voltage level;
• Permanent reduction of injectable potency;
• Eduction of injectable potency on pre-established days and times or dynamically.

Pursuant to art. 83 of ANEEL Normative Resolution No. 1,000/2021, the consumer and other users must approve the connection budget and, in the case of distributed micro or minigeneration connection falling within the aforementioned § 1 of art. 73, § 9 of art. 83 provides that, when approving the connection budget, the consumer must formalize his choice between the alternatives presented to the distributor.

It should be noted that, through the recent Joint Letter No. 0017/2023-SRD/SFE/SMA/ANEEL, the Regulatory Agency expressed an understanding that distributors must carry out such studies only and only for (i) budgets of connection not yet issued; (ii) new connection requests; and (iii) in the treatment of complaints about quotes that have been rejected or with a connection alleged to be unfeasible by the local distributor.

In this context, the study of the distributor – referred to in § 1 of art. 73 of ANEEL Normative Resolution No. 1,000/2021 – must make up the connection budget and contain (i) the analysis and demonstration of flow reversal, including maximum connection and flow capacity without flow reversal; (ii) analysis of the available alternatives, identifying those considered viable and those with minimum overall cost, and (iii) the responsibilities of the distributor and the consumer in each alternative.

Important Notes

The regulation does not allow connections in progress or already completed, whose connection budgets have been issued by the distributors and approved by the accessors, to be reviewed or impacted as a result of any subsequent carrying out of the studies contained in § 1 of the art. 73 of ANEEL Normative Resolution No. 1,000/2021.

Failure to present the connection budget in situations where the distributors consider that the value of the connection works is high represents non-compliance and legal, regulatory and contractual non-compliance.

In the same sense, the lack of (i) demonstration of flow reversal and maximum connection/flow capacity without flow reversal, as well as (ii) indication and analysis of the alternatives listed in § 1 of art. 73 of ANEEL Normative Resolution No. 1,000/2021, identifying those considered viable and those with minimum overall cost, also represents non-compliance and legal, regulatory and contractual non-compliance.

This is because electricity distributors are obliged to observe and comply with the provisions of (i) in art. 15, § 6, of Federal Law No. 9,074/1995, which establishes the right of access to distribution and transmission systems for all accessors, (ii) in arts. 2nd and 18 of Federal Law No. 14,300/2022, which establish such right of access – expressly – to consumer units with distributed micro and minigeneration, as well as (iii) in the Concession Contracts for the Provision of Public Electricity Distribution Service agreed between the Granting Authority and local distributors, which establish obligations relating to the necessary expansion of the distribution system and market service.

It is important to clarify that, when it comes to the provision of essential public services, arts. 15 and 17 of ANEEL Normative Resolution No. 1,000/2021 also impose on distributors, as a general rule, the obligation to carry out the requested connections in the permanent modality, given that, by legal, regulatory and contractual force, the connection to the distribution system is a right of consumers and other users, and distributors must respond to all connection requests they receive.

What happens in practice?

Several electricity distributors, using a mistaken interpretation of arts. 73 and 83 of ANEEL Normative Resolution No. 1,000/2021, are practicing the following irregular conduct:

• Failure to issue a connection quote on the grounds that the connection is technically unfeasible, in the event that the minimum global cost alternative has a high economic value;
• Issuance of the connection quote without demonstrating flow reversal and maximum connection/flow capacity without flow reversal;
• Issuance of a connection quote containing only one of the solutions contained in § 1 of art. 73 of ANEEL Normative Resolution No. 1,000/2021, that is, without indicating and analyzing all alternatives listed by the regulation in order to identify those considered viable and those with minimum overall cost;
• Stoppage of ongoing connections, with connection quotes already issued and CUSDs / CCEARs signed, indicating subsequent identification of flow reversal and indicating solution(s) of § 1 of art. 73 of ANEEL Normative Resolution No. 1,000/2021 to enable service;
• The cancellation of ongoing connections, with connection quotes already issued and CUSDs / CCEARs signed, indicating the need for the user to formulate a new access request, a fact that is even worse when it comes to canceling connections whose access requests were made prior to 01/07/2023, which guarantees the classification of the respective enterprise in art. 26, item II, of ANEEL Normative Resolution No. 1,000/2021 – most beneficial tariff system until 2045.

Having made these considerations, in view of one of the situations reported above, it is recommended that an administrative measure be adopted, before ANEEL, and/or a judicial measure, against the local distributor, with a view to (i) ensuring the correct application of articles . 73 and 83 of ANEEL Normative Resolution No. 1,000/2021, as well as, when applicable, (ii) guarantee the classification of the consumer unit(s) with micro or minigeneration installed in art. 26, item II, of ANEEL Normative Resolution No. 1,000/2021, with application of the most beneficial tariff system until 2045.

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