On September 30th, the Energy Regulatory Commission (the “Commission”) published the General Administrative Provisions for the Integration of Energy Storage Systems into the National Electric System (the “General Provisions”). This new regulatory framework establishes the modalities and general conditions for the integration of battery for energy storage systems (“BESS”), aiming to improve the efficiency, quality, reliability, continuity, safety, and sustainability of the National Electric System (“Grid”). This Provisions were published in the Official Gazette of the Federation on March 7th.
The main objective of the General Provisions is to establish a regulatory framework that allows for the orderly and economically viable integration of BESS into the Grid. This includes counteracting the variability of intermittent power plants and leveraging the products and services that BESS can offer.
The General Provisions have the following specific objectives:
1. General Conditions: Establish the general conditions applicable to BESS.
2. Integration Modalities: Define the modalities for the integration of BESS into the Grid.
3. General Requirements: Establish the general requirements for the integration of BESS into the Grid.
4. Interconnection/Connection Procedure: Establish the procedure to interconnect or connect BESS.
1. BESS-PP (Energy Storage System associated with a Power Plant).- This modality allows integrating an BESS into an intermittent power plant, sharing the same interconnection point. BESS-PPs must comply with the criteria of efficiency, quality, reliability, continuity, safety, and sustainability of the Grid. The BESS-PP must be charged using the resources of the associated intermittent power plant unit, and its discharge must contribute to compensating for the variability of the primary source.
2. BESS-LC (Energy Storage System associated with a Load Center).- In this modality, the BESS is integrated into a load center without including a power plant. The BESS-LC set can receive energy supply through a supplier or participate in the Wholesale Electricity Market. The capacity of the BESS is deemed as part of the contracted demand or maximum demand of the load center, and the stored energy is used to meet the demand of the load center itself.
3. BESS-IS (Energy Storage System associated with an Isolated Supply Scheme).- This modality involves integrating a BESS into a power plant whose generation is intended for isolated supply to meet the load’s own needs, or for the import or export of electricity to international power systems.
BESS projects developed for the import and export of electricity must request the corresponding permits from the Commission.
4. BESS-DG (Energy Storage System associated with Distributed Generation).- In this modality, the BESS is associated to a distributed generation facility. This modality will be subject to regulations in matters of distributed generation.
5. Non-Associated BESS.- In this modality, the BESS is independently interconnected to the Grid, without being integrated into a power plant or a load center. Non-associated BESS must comply with the corresponding connection and interconnection processes and be represented in the Electricity Market by a market participant in the generator modality.
To operate and implement a BESS in the modalities of BESS-PP, BESS-IS and Non-Associated BESS, the issuance or modification of a power generation permit by the Commission is required, as these modalities are deemed as power generation for regulatory purposes.
As it relates to BESS-LC, if their maximum demand is equal to or higher than 1MW, the load must be registered as a Qualified User with the Commission.
Interested parties must submit a request for interconnection or connection studies, including technical details of the BESS such as capacity, available energy, power, response time, charging and discharging speed, among others. These studies are necessary to determine the technical and operational feasibility of integrating the BESS into the Grid.
The purchase and sale offers of energy, capacity, and associated products made by BESS will be subject to market rules and other applicable provisions.
BESS can offer ancillary services such as secondary regulation reserves, spinning reserves, operating reserves, and supplemental reserves, provided they meet the established technical and operational requirements.
Specifically, as it relates to capacity, sale offers are subject to the following:
1. Sale offers from BESS-PP and Non-associated BESS are subject to the availability of the intermittent power plant or Available Energy in the BESS, respectively, in accordance with the hourly capacity Profile, Net Installed Capacity and BESS Capacity included in the interconnection studies.
2. Applications for the interconnection studies of a BESS-PP must consider the hourly capacity Profile under which the asset is intended to be operated, taking into account the availability of the intermittent power plant, its own-needs and the requirements to charge the BESS.
3. BESS-PP that charge solely from the associated power plant may be accredited with Capacity, provided that they have the conditions to operate at their maximum capacity or according to the value of Availability of Physical Delivery requested to be evaluated in the Interconnection Studies for at least three continuous hours, considering the BESS Power and BESS Capacity.
4. For purposes of Capacity accrediting, Non-Associated BESS will be deemed as firm power plants to the extent that they are able to deliver Available Energy uniformly for at least three continuous hours or according to the value of Availability of Physical Delivery evaluated in the Interconnection Studies, considering the BESS Degradation.
Non-Associated BESS that do not meet the conditions specified above will not be able to accredit Capacity as firm power plant units, but may accredit Capacity if they are registered with intermittent status, in which case they will be evaluated under the criteria applicable to intermittent power plant units.
The Commission may require regulated entities to submit information for supervision and monitoring purposes. Specifically, BESS-LC in medium or high voltage must be registered with the Commission within 90 business days after their installation.
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