Can I upgrade equipment from an approved project?

In the photovoltaic energy sector, there is a general consensus that some processes can take a while. For example, you may close a sale today, but the financing will only be approved in a month.

Despite being commonplace, this can cause some headaches when it comes to purchase of equipment, as the market has frequent variation in prices and even availability of equipment.

Therefore, situations occur in which equipment sent in a connection quote request need to be changed when the time comes for installation or even after approval of the inspection, as is the case with equipment that presents malfunctions.

This raises the question: will I I can only update the equipment of an approved project, without having to send a new project to the distributor?

To answer this question, we will stick to the rules for requesting a connection quote, brought by REN 1,000/21. In it, in art. 63, ANEEL establishes the cases in which the request for a connection quote is mandatory:

“Art. 63. Requesting a connection quote is mandatory in the following situations: I – new connection;

II – increase in power demanded or increase in power injected into the distribution system; …”

In other words, we can understand that, if the change in equipment does not result in an increase in injected power, there would be no obligation to make a new connection quote request.

But in addition to REN 1,000/21, there is a basis in Official Letter No. 0185/2019 published by ANEEL on 05/13/2020.

This letter is a response to the distributor CEMIG, which questioned the Agency on some points regarding the service of units with distributed micro and mini generation, such as the modification of generating plant projects. In letter no. 0185/2019, ANEEL says the following:

“In fact, there is no reason to restart the access process when changes occur that do not imply a change in the service solution. Therefore, the distributor must accept changes to the originally approved project that do not result in significant impacts and do not influence the solutions adopted for other users.

Along these lines, it is up to the distributor to assess the complexity and impacts of changes to the project made by the accessor, requiring the process to be restarted only when the changes are relevant or affect other users.”

In other words, for simple cases of changing equipment brands or substitutions that do not significantly alter the approved system, ANEEL advises that distributors authorize the change without the need for a new quote request.

The procedures for making these changes vary for each distributor, so there is no specific step-by-step guide to follow.

However, in general, what can be done is to contact the distributor that serves you and ask about the means for this equipment update to be carried out.

In case of refusal by the distributor, the consumer is protected by the regulations mentioned above, as well as the letter issued by ANEEL, and can use them to appeal the decision. This can be done through complaints to the distributor's ombudsman or to ANEEL itself.

Although communication with distributors is not always successful, it is important that the consumer always seeks the correct means to make this change.

Under no circumstances can the consumer simply change the equipment without informing the distributor. This is because according to REN 1,000/21, art. 8, it is the consumer's duty to keep their unit's data updated with the distributor.

Therefore, consult the distributor to carry out the correct procedures, updating your equipment only with the distributor's approval.

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