The process that deals with flow reversal and also the regulation of My home, my life has been a concern protocols for DG market photovoltaic (distributed generation).
O Canal Solar is following the actions of ABSOLAR (Brazilian Association of Photovoltaic Solar Energy) on such topics, with oral arguments and meetings with the ANEEL (National Electric Energy Agency).
Given this scenario, we interviewed Barbara Rubim, CEO of Bright Strategies and vice president of distributed generation at ABSOLAR, to discuss the impacts of lack of regulation on flow reversal, besides the measures that can be taken by integrators to mitigate losses.
Check out below the Full interview carried out with the executive.
What are the main negative impacts that the lack of regulation on flow reversal has caused to the solar photovoltaic sector?
Furthermore, in your , you suggested to the Agency's Board of Directors necessary improvements to the draft presented by the technical area for the regulation of Art. 73. Can you detail how these improvements resolve the current situation of connection requests being rejected due to flow reversal?
I think the main point we have is that the regulation that exists today on the subject of flow reversal, which is Art. 73, is very broad and ends up allowing the distributor to use it, whenever it identifies the existence of some flow reversal, as a justification for rejecting or limiting the connection of a distributed generation project to the grid.
So, the regulation we have, the fact that it is so broad, ends up being a mechanism that validates truly arbitrary and unreasonable action on the part of the distributors.
Connected to the second question, what have we suggested as ABSOLAR, the main point for the amendment of Art. 73, is that it be made explicit that the distributor can only claim the inversion of flow as a measure to reduce the consumer's right to generate their own energy, if it can prove that this inversion of flow is harmful to its network.
And what would be harmful to the network? Violate the quality parameters set out in module 8 of Prodist. Today, the distributor does not need to claim that the identified flow reversal is harmful to its network. So, this ends up bringing this whole spiral of consequences, of negative effects that we have seen, with a lot of concern in the sector.
I think the important point to highlight, as is known, is that not every flow reversal is harmful to the network. Flow reversal is a natural phenomenon in energy generation, especially distributed generation. And up to a certain level, it is completely able by the network, it does not cause any type of damage. This is exactly why we have been asking for this inclusion.
Director Fernando Mosna presented a proposal proposing the release of projects of up to 12,5 kW. What is your analysis of this suggestion? Can it solve the flow reversal problem?
The referral made by director Mosna does not resolve 100% of the problem, but it undoubtedly addresses a large part of the situation. In conversations with Cemig, the distributor informed us that, today, 49% of all projects presented at Cemig receive some type of indication of flow reversal that they cause in the network and that within this universe, practically all projects, or almost all, These are distributed microgeneration projects.
So, from the moment we have no need to analyze flow inversion for projects, for example, up to 12,5 kW, which was suggested by director Mosna, we can ensure the maintenance of the sector's growth, by less for microgeneration next to the load and for smaller microgeneration itself – which is what ends up allowing most companies to be able to generate revenue and manage their cash flow.
Therefore, I think it is an interesting proposal, which addresses most cases, but does not solve 100% of the problem. In our analysis, the best approach would be to resume the proposal that was put forward by the technical area of ANEEL, before the consultation was opened, which would be the exemption from flow inversion for projects of up to 50 kW.
In your opinion, what are the biggest challenges in achieving convergence among the directors of the ANEEL on this topic? The Agency has been receptive to the proposals and concerns presented by ABSOLAR?
I think the biggest challenge for the Board of Directors ANEEL Finding a consensus on this issue has to do, in fact, with the complexity of the topic and the fact that there are many different proposals on the table. All of this ends up making it really difficult to reach a consensus.
Furthermore, it is important to that when the topic was discussed on other occasions, the general director was absent. So, in a Board that has a natural quorum of five directors, we only had three. However, we are convinced that, given that the process is back on the agenda and without the reservation of a partial deliberation, that this deliberation will actually happen, and we believe from the conversations we have had, that it should converge to something close to the initial proposal that was presented by director Fernando Mosna.
If this does not happen or if the sector understands that the decision of the ANEEL is insufficient for us to actually resolve this issue of flow inversion, which has caused harm to so many consumers, ABSOLAR will continue to act, especially to ensure the approval of Bill No. 624 of 2023, which has already been approved in the Chamber and is being processed in the Federal Senate under the report of Senator Petecão.
In fact, we were present at an event in Acre, which is the senator's home state, last Wednesday (17), to discuss the benefits of approving this project with the local population.
What additional measures can the solar photovoltaic sector take to mitigate losses while awaiting regulation? Is there anything the integrator or the end consumer can do?
From the point of view of additional measures that can be taken by the sector, what we recommend is that the path of understanding really be followed. Most of the denials, or limitations that we see due to a reversal of flow, do not even meet the requirements of Article 73, however flawed it may be.
Therefore, we recommend that the integrator demands that the distributor send the study and actually analyze what is included in this study. We have seen many cases of studies that are carried out insufficiently or that actually indicate alternatives that do not match the technical data that are presented.
Finally, he believes that this issue can be resolved by the National Congress, since the ANEEL Is it taking a long time to complete the matter?
Regarding the entry into the National Congress, we have sought the approval of Bill No. 624, which will address some other issues in addition to this one. We do believe in the possibility of approval of this project within Congress, even if there is a deliberation on this issue by the ANEEL, and we will vote to make it happen.
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