Our Partner Diogo Nebias commented to eixos on the cost-funding design of the battery auction scheduled for December.
The draft from ANEEL - Agência Nacional de Energia Elétrica (the National Electric Energy Agency), now in public consultation, keeps the charge on generators, as the law requires, but scales the amount according to each plant's flexibility: the most flexible plants would pay 25% of the charge and the least flexible, 100%. The underlying question (who bears the cost of the system's security and modernization) recurs in curtailment, in Ercap and in the bills now under consideration, among them PL 3.716/2026, which would change who pays for the batteries.
In practice, for those already in operation, the charge arrives after the investment decision.
- In Diogo's words, for projects already in operation, "bringing this cost in now upsets profitability," because financial models rely on rate of return and long-term financing.
- The beneficiary of storage is not only the generator: "The storage system serves the system as a whole."
- The current design carries litigation risk. In his assessment, "this could be taken to court."
- As Diogo sums it up, storage serves the entire system. As long as the allocation of cost does not follow that logic, the auction moves forward with built-in regulatory risk.




