Storage systems, represented here by BESS (Battery Energy Storage System), arrived in the Brazilian electricity sector as a true wild card — capable of fitting into practically any point in the chain: generation, transmission, distribution or consumption.
Its primary function can be described as that of a time-shifter: it stores electricity when there is surplus and delivers it when needed. This role differs from that of transmission and distribution, which move energy through space, physically transporting it from one point to another.
From this perspective, the BESS can act as a transmission and distribution (T&D) asset, approaching the function of a utility. In this case, the grid planner and operator could size and operate it to make the process of connecting load and generation more efficient and cost-effective.
On the other hand, its versatility goes even further: it can also behave as a generator or a consumer. The problem is that it doesn't fit squarely into either category—and it's precisely this hybrid characteristic that creates a regulatory knot that's difficult to untangle.
This dilemma became evident in the Public Consultation 39/22 (second phase), completed in August 2025 and consolidated in Technical Note 13/25The document reinforces that, although regulation has advanced, there are still significant gaps in clearly defining how BESS should be classified and remunerated within the electricity system. Some key points of the aforementioned CP can be highlighted.
Types of SAE
When the energy storage system is directly linked to a generating plant — whether installed on the same site or operating in an integrated manner — it receives different regulatory treatment, both in terms of measurement and authorization.
The associated SAE is similar to a hybrid power plant and follows existing procedures. In the case of co-located SAE, energy can be transferred directly from the generator to the storage system, and the measurement process takes place separately. The autonomous SAE connects to the grid independently, "purchasing" energy to discharge at a later date. It still lacks clear incentives, which limits its adoption.
This lack of incentives could prevent more flexible and decentralized storage models from gaining scale in Brazil, even given the growing need for resources for system stability. SAE Utility was left to be evaluated in the next CP cycle and is in high demand from transmission companies, especially given the example of ISA Cteep's SE Registro.
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