O Canal Solar held, this Tuesday (06), a live with renowned professionals from the national photovoltaic market to talk about the main technical, legal and regulatory aspects of Resolution 1.098/2024, published by ANEEL (National Electric Energy Agency) on July 31st.
The document provides definitions and scenarios where the need for flow reversal analysis by electricity distributors for micro and mini distributed generation systems will be eliminated. Given its complexity, the new resolution still raises many questions among integrators, investors, consumers and other professionals in the photovoltaic sector, who want to know how they should behave in the market in relation to the performance of their companies and their businesses.
ANEEL publishes resolution on flow reversal in the Official Gazette
The live of Canal Solar received technical explanations from Bruno Kikumoto, CEO of the company; Bernardo Marangon, director of Prime Energy (a Shell group company); Geraldo Silveira, engineer in charge of CS Consultoria; and Pedro Dante, partner in the energy area at Lefosse Advogados.
Legal and regulatory aspects
Dante explained, in the first few minutes of the live broadcast, that the Agency's idea in publishing the resolution was to propose a simple and objective criterion, in order to reduce the dependence on major analyses to be carried out by distributors.
Dante highlighted that one of the points of the new resolution is the obligation for distributors to make complete and understandable studies available to which consumers who have their access denied due to the justification of flow reversal can oppose.
“Information about tools, parameters and conditions used must be provided (…) Consumers will have the right to complain if the studies are not presented and distributors will have 10 working days to respond to complaints”, he stressed.
Furthermore, the new resolution also requires that studies on flow inversion be signed by a technical manager within the distributor. “I am not saying that the problem will be solved, but at least the Regulatory Agency was concerned with requiring distributors to follow a standard for these analyses so that everyone can compare this information,” Dante emphasized.
Finally, the professional highlighted that the new rules of Resolution 1.098/2024 came into effect 60 days after the date of its publication, precisely so that distributors and the market in general can organize themselves to follow the new determinations.
Flow reversal: new scenarios
Silveira highlighted that the text published by ANEEL presents three scenarios where the flow inversion analysis will be ruled out, namely:
- Distributed microgeneration and minigeneration systems that do not inject energy into the distribution network (zero-grid);
- Distributed microgeneration that meets the free of charge criteria, whose distributed generation power is compatible with the consumption of the consumer unit during the generation period;
- Distributed microgeneration that fits into the local self-consumption modality, with installed generation power equal to or less than 7,5 kW.
During the live broadcast, the professional provided practical examples of real-life situations to facilitate understanding for the audience that watched the broadcast. “The first one is quite obvious, which are systems that do not inject energy into the grid. It makes no sense to issue an access report with flow inversion if the consumer will not use the distributor’s grid,” he commented.
Silveira highlighted the second item as the most complex to analyze, while in the third there will no longer be an analysis of flow inversion for photovoltaic plants with up to 7,5 kW, as long as there is no sharing of surplus credits with other consumer units.
Impacts of deregulation on flow reversal in the solar sector
Project feasibility
Regarding the viability of projects for new micro and mini distributed generation connections, Marangon assessed that the new resolution of the ANEEL will not prevent the solar energy market from continuing to develop, since the investor will still have the possibility of installing projects that do not inject energy into the grid or that respect simultaneity.
Furthermore, the director of Prime Energy pointed out that the new resolution is only valid for locations where the distributor has identified a flow inversion. In other words, in regions where the problem has not affected photovoltaic system installers, access opinions continue to be issued.
Another point raised by Marangon was the possibility of the solar energy market finding new solutions to the problems caused by flow inversion, the main one being the use of batteries in its sales portfolio. The same point of view was also defended by Kikumoto.
“I see many people receiving these three conditions and interpreting that everything that is outside (these criteria) will have a flow inversion problem and that’s it. No! That’s not what is written in the resolution. These are just the cases in which the analysis will be waived. If it doesn’t fit, there won’t necessarily be a problem,” he stressed.
Check out the full live stream
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An answer
Everything the government can do to privilege energy distributors and continue stealing from citizens will be done through rules disguised as regulatory rules and to put an end to solar energy and investors who have already shown that prices can fall. More regulation will come.