
Our partner Diogo Nebias commented to eixos on the cost-allocation design of the battery auction scheduled for December.
The draft rule from ANEEL - Agência Nacional de Energia Elétrica under public consultation keeps the charge on generators, as the law requires, but scales it according to each plant's flexibility: the most flexible would pay 25% of the charge and the least flexible, 100%. The underlying question (who bears the cost of system security and modernization) recurs in curtailment, in the Ercap and in bills pending in Congress, including Bill (PL) 3,716/2026, which would change who pays for batteries.
In practice, for those already operating, the charge arrives after the investment decision.
• In Diogo's words, for projects in operation, “trazer esse custo agora desequilibra a lucratividade” [bringing in this cost now upsets profitability], because financial models rely on rates of return and long-term financing.
• The beneficiary of storage is not only the generator: “O sistema de armazenamento serve para o sistema como um todo.” [The storage system serves the system as a whole.]
• The current design carries litigation risk. In his assessment, “isso pode ser judicializado” [this may end up in court].
• As Diogo sums up, storage serves the entire system. As long as cost allocation does not follow that logic, the auction moves forward with built-in regulatory risk.
Full article: https://lnkd.in/eaTMxN89



