The increase in rejections of distributed microgeneration projects by the FL group has caused headaches for consumers seeking to generate their own energy through photovoltaic sources and integrators working in the request and installation of such projects.
The report by Canal Solar received numerous reports that photovoltaic installation projects for consumers with systems equal to or less than 7,5 kW have been rejected for reasons including the grid's inability to absorb the energy generated and problems related to flow inversion in the network.
With the recent publication of the REN 1.098/2024, on July 30th of this year, which defined three scenarios in which flow reversal analysis is not required, including systems with power equal to or less than 7,5 kW, known as “fast-track”, a question arises among professionals working in the sector: Can the concessionaire reject a project with power equal to or less than 7,5 kW on the grounds of flow inversion?
Before answering this question, it is necessary to observe what the aforementioned regulation establishes. REN 1098/2024 determines that to qualify as a “fast-track” project case, in addition to having a power equal to or less than 7,5 kW, such systems must be classified as “local self-consumption”.
In other words, the energy credits generated from the injection of energy into the grid cannot be offset in another UC (consumer unit) that does not have the photovoltaic system installed.
Therefore, Consumers who choose to follow this scenario will need to “give up” sharing energy credits with other CUs, by filling out the forms for this purpose. In the specific cases of FL and RGE, these are “Form Annex E – Connection Request” and “Acceptance term (Art. 73-A)”.
The wording of the Canal Solar talked to the lawyer Thiago Bao Ribeiro, GD specialist and CEO of the Bao Ribeiro Advogados law firm, on this scenario of increasing rejection of projects by the FL group.
When asked about what could be contributing to the increase in failure rates, Bao Ribeiro pointed out that despite the “fast track” being provided for in the regulation, not all distributors have prepared for the new rule.
“When requesting a system of up to 7,5 kW in the “fast track” mode, g the necessary documents and declaring that there will be no sending of credits to another consumer unit, the process should dispense with the flow inversion analysis”, commented Bao Ribeiro.
He also assessed that rejections have occurred many times because, even with the “fast track” request, the distributors continue to apply flow reversal analysis, generating rework and delays in the sector.
Another factor that has contributed to the increase in failures is that some professionals have not paid attention to correct way to fill out the documents required for the installation request.
“We noticed that some integrators, when placing orders using this method [fast track], do not correctly fill out the documents required by distributors. For example, they forget to declare that they will not send credits to other consumer units, which can lead to the order being rejected,” he explains.
Regarding this last factor, it is important to highlight that access to documents to request the installation of DG projects must be done on the distributor's official website to avoid accessing outdated documents. In the case of FL, access must be done on its official website “Mini and Microgeneration | FL” do not follow link: https://www.fl.com.br/mini-e-microgeracao.
Therefore, if a project was submitted to the concessionaire without filling out these forms with the appropriate notes, the flow inversion analysis is not waived, as per REN 1.098.
Given these facts, another question arises: how to proceed in cases where the project was rejected, with indication of flow inversion?
First, the power flow study sent by the concessionaire's technical team should be evaluated. If there are no questions regarding the study, the recommendation is to submit the project again, this time with the respective forms filled out indicating the classification as local self-consumption, and obtain the respective signature of the consumer holding the UC.
How have rejections impacted consumers and companies?
Integrators interviewed by the report of Canal Solar reported on negotiations with FL and how the rejections have impacted consumers.
“Despite the fact that we update FL’s forms monthly, we were still caught by surprise. I, at least, don’t receiving any kind of information about the change in Annex E, and the two rejections we had were related to this document,” commented Leandro Rocha, owner of Intti Energia Solar.
“Obviously our clients were not happy, especially because the project was cancelled and not rejected, forcing us to start the process from scratch. They were left with the impression that we were not up to date with FL’s new guidelines,” he added.
Another professional who has had problems with project approval is electrical engineer Eduardo Peniani Bueno, owner of Evolt Energia Solar. He reported that clients do not always understand the situation.
“Since FL started rejecting projects on October 1, 2024, the situation has become chaotic. Some customers are even calling and threatening to sue,” he said.
“In my case, I had six rejections because of Annex E. I updated it as soon as it was published, but FL didn’t accept it because it wasn’t their annex. When they rejected my projects, I called the ombudsman’s office. The attendant opened the annex and confirmed that it was updated, but the technical area didn’t accept it. So, I asked the ombudsman’s office to send me the correct annex and now I’m using that document,” he added.
“I’m hoping that these projects don’t fall under the flow inversion analysis, because they are small systems, between 5 and 7 kW. At the moment, the ombudsman’s office is the only way. If that doesn’t solve the problem, I’ll file a complaint with Aneel,” Bueno concluded.
Jonas de Melo, director at Solar.Kom Energia, also highlights the difficulty faced in making the installation of projects of up to 7,5 kW viable.
“Our reasons for rejection are all due to flow inversion. In fact, in some cases, the justification was that there were already three plants installed on the transformer where the system would be connected. We went to the site to check and discovered that there was only one,” he reported.
“We also had cases of 6 kW inverters being rejected due to apportionment. However, if the system is for the exclusive consumption of the customer, there should be no flow inversion”, added Melo.
FL Note
In a note to the Canal Solar, FL informed that it strictly follows the guidelines established by the Normative Resolution ANEEL No. 1.000/2021.
See the note in full
FL informs that it strictly follows the guidelines established by the Normative Resolution ANEEL No. 1.000/2021. In the analysis reports for distributed generation projects, whenever the customer meets all the criteria of the Fast Track option and submits the documentation correctly, the process continues without the need to go through the flow reversal, as provided for in article 73 of the aforementioned resolution.
On the other hand, when the project involves power greater than 7,5 kW or even less and the client opts for Remote Self-Consumption, the analysis considers the possibility of flow inversion. In cases where the documentation submitted presents inconsistencies or doubts about the chosen option, FL reinforces, in the rejection report, the impediments that need to be corrected for the project to move forward.
In addition, FL makes available on its website all the necessary updated documentation so that the client can make adjustments, as well as the information necessary for those responsible for the project to avoid new impediments.
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Answers of 3
Subject: Undue failures committed by FL in photovoltaic systems:
FL is violating Law 14.300 and making the approval and installation of photovoltaic systems for the population unfeasible.
Several points of the law being violated below:
-By updating GED15303, it has already put into practice a new abusive bureaucracy and violates Article 31 of Law 14.300:
“Art. 31. Any change in the standard or procedure of distributors related to microgeneration or distributed minigeneration or to consumer units participating in the SCEE must be published with a minimum period of 90 (ninety) days for its entry into force.”
And this deadline was not respected, note that projects sent within this period were automatically rejected:
Ged15303:
-Another point to be observed is that the FL prevents the project from being corrected, even if it is a simple correction of a different telephone number from the registration or anything else, it prevents the correction and forces the project to be submitted again from scratch, this again violates law 14.300:
1. Right to Transparency and Information:
• Law 14.300 reinforces that the process of connecting distributed generation systems must be transparent and predictable for consumers and agents involved (Art. 4, §3). This transparency implies that concessionaires must provide clear and objective justifications in the event of a project being rejected.
• Furthermore, the law seeks to ensure that the connection process is agile and that distributors do not impose unnecessary obstacles to the project approval process.
2. Rights and Duties of Distributors:
• The law requires distributors to comply with the deadlines and standards defined by ANEEL for the connection process (Art. 7). This reinforces the need to follow the normative resolutions of the ANEEL, such as REN 482/2012 and REN 1000/2021, which speak of transparency and efficiency.
• Although Law 14.300 does not explicitly mention the correction of projects without a new protocol, the requirement to follow the standards of the ANEEL suggests that distributors should look for ways to facilitate the process, without disproportionately burdening the consumer or the designer.
3. Principle of Efficiency and Cost-Benefit:
• The law aims to promote a regulatory environment that favors the expansion of distributed generation, taking into the efficiency of processes. Therefore, requiring a new protocol for each project correction, without a well-founded technical justification, may go against the principle of efficiency and simplicity that the law aims to promote.
-Another point is the reason for the rejections alleging Flow Inversion, even in places where there is no photovoltaic system installed, it prevents the installation, see:
Note that she simply did not give the citizen an option and with that she again violates law 14.300 in the following article:
Another factor is in relation to Ren1000/21:
Art. 73-The analysis of flow reversal referred to in art. 73 is excluded in the following situations: (Included by REN ANEEL 1.098, of 23.07.2024/XNUMX/XNUMX):
“§ 6º The flow reversal analysis must be carried out:
I – only at the higher voltage level, in the case of Group B connection via an exclusive transformer; and
II – only at the substation transformer, in the case of Group A connection via an exclusive feeder.”
Therefore, for locations in group B, where there is more than one customer being served by the same transformer, the flow inversion analysis does not apply, as you can see, FL is not complying with this:
Another point to be observed is in relation to the ANEEL instruction manual (item 13), which makes it clear and evident that “The distributor must present in item 9 of the flow inversion study the location, date and signature with identification of the professional responsible for the study and also of the competent fiscal council: Crea/Confea.
This violates law 6496/1977 by not collecting the appropriate ART, and also violates law 5194/1966, due to the lack of identification of the professional who made the technical opinion and consequently his signature:
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This is a typical procedure to hinder the expansion of solar generation. There is an increasing amount of amazing technological innovation and costs are falling considerably. Whether these electric power companies like it or not, they should greatly improve the quality of the services they provide. See the absurdity that is happening in the city of São Paulo, with consumers without power for five days. Here is a brief observation: ANEEL This is the height of ineffectiveness. Regulatory agencies have an excellent technical staff, but the political environment prevails. See the nomination of of the senior istration. Engineer, professor, master in electrical engineering science, designer of solar generation, energy efficiency and electric car charging stations.