Advancing Energy Storage Regulation in Brazil

The Brazilian National Electric Energy Agency (ANEEL) is entering a new phase of dialogue on energy storage regulation. On December 10, 2024, ANEEL presented the results of the first phase of Public Consultation (CP) No. 39/2023 and announced the opening of a second phase for further contributions. Stakeholders can provide feedback from December 12, 2024, to January 30, 2025.

This initiative forms part of ANEEL’s 2025–2026 Regulatory Agenda, which seeks to modernize Brazil’s energy framework by incorporating energy storage systems (SAE), including reversible power plants, to support sustainable energy transitions.

Key Insights from the First Phase

The initial phase, held from October 19 to December 18, 2023, garnered 831 contributions from a diverse array of stakeholders, including consumer associations, energy generators, and regulatory experts. This engagement informed significant adjustments to proposed regulations across several normative and non-normative solutions (SN and SNN).

Highlighted Normative Proposals:

1. Transmission and Distribution System Usage (MUST/D):

ANEEL supports including SAE capacity within contracted power ranges and proposes a flexible approach for existing installations. Peak-shaving measures will also be considered.

2. Network Usage Contracts (CUST/D):

A simplified contracting model was adopted to consolidate multiple authorizations into a single agreement, reducing administrative burdens. For colocated systems, injection capacity into the grid remains restricted unless authorized by specific legislation.

3. Usage Tariffs (TUST/D):

ANEEL proposed tariffs tailored to SAE profiles, emphasizing cost alignment with actual system impact. This ensures efficient and fair network usage while avoiding duplicate charges.

4. Reversible Hydropower Plants (UHR) Authorization:

Existing hydropower plants can integrate reversible units through an updated technical approval process, streamlining integration.

5. SAE Compensation Models:

The adopted approach encourages competitive market integration, allowing operators to earn multiple revenue streams.

Non-Normative Innovations:

Data Transparency: ANEEL plans to standardize the disclosure of energy market and regulation data.

Research Incentives: Regulatory sandboxes and pilot projects will encourage innovation.

Technical Cooperation: Partnerships with national and international entities will enhance expertise in energy storage.

Phased Approach to Energy Storage Regulation

ANEEL has structured the regulatory development process into three 18-month cycles:

1. Foundational Discussions: Focused on defining energy storage resources and addressing initial market access barriers.

2. Innovative Applications: Explores hydropower storage systems and economic models for storage integration.

3. Advanced Integration: Tackles complex topics like aggregator models and new business applications.

Participate in the Second Phase

The second phase of CP 39/2023 aims to refine proposals based on stakeholder feedback. Contributions can be submitted through an electronic form on the consultation webpage until January 30, 2025.

ANEEL’s commitment to fostering dialogue and innovation is vital for Brazil’s energy future. By advancing energy storage regulation, the agency seeks to enhance system efficiency, accommodate renewable energy growth, and empower stakeholders across the energy sector.

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