Chile published Supreme Decree No. 32 of the Ministry of Energy , a regulation that modifies the coordination and operation regulations of the National Electric System ( previously established by Supreme Decree No. 125).
The update introduces new rules for the programming, operation and valuation of energy storage systems, as well as adjustments on renewable energy plants with storage capacity, PMGD, generation-consumption systems, automatic economic dispatch, short-term market and declaration processes under construction.
One of the main changes lies in Energy Storage Systems (ESS) . With DS 32/26 , these assets are more fully integrated into the operation's scheduling and the short-term market , while opportunity cost becomes the central parameter for determining their variable cost.
Until now, in certain cases where a BESS could have a significant impact on system operation, the owner was required to submit a program of injections and withdrawals. With the new regulation, that definition changes.
“This is what had been requested. Now the Coordinator will be responsible for scheduling the operation of the storage systems. Calculating the opportunity cost is supposed to be the most efficient way to ensure that the scheduling of these resources is optimal for the system,” said Daniela González , managing partner of Domo Legal, in an interview with Energía Estratégica .
The challenge will be calculating it in practice
Beyond the regulatory definition, the implementation of opportunity cost emerges as one of the most demanding aspects of the new framework. In the case of batteries, the economic decision is not limited to production costs, but also to determining when it is advantageous to charge, discharge, or store energy for later use within the system.
In practice, production cost functions as a broader category: it allows ordering both to facilities whose dispatch is defined by variable cost and to those — such as storage systems — whose operating value depends on opportunity cost .
For González, the most complex point will not be in the definition, but in its application.
“In markets where storage systems have been incorporated, it has been seen that calculating the opportunity cost is not a minor challenge, it is a very big challenge,” he said.
He added: “The massive incorporation of storage will really test the Coordinator ’s ability to implement this design. It remains to be seen whether it will actually work out as well as one expects when designing regulations.”
Renewable energy plants with storage: three modes of operation
The decree also establishes rules for renewable energy plants with storage capacity , which will be able to operate under three modalities: charging mode , discharging mode and direct generation mode .
The charging mode corresponds to the moment when the plant's storage component is charged, either with energy from its own generation or through withdrawals from the system. The discharging mode applies when the injection comes from the BESS component, while direct generation refers to injection from the plant's renewable energy source.
The standard allows these power plants to operate simultaneously in offloading and direct generation mode, provided their connection capacity allows it.
Another relevant point is the valuation methodology. These projects can be treated as a single power plant with a fixed production cost determined according to the technical standard, or they can be valued by component. In the latter case, generation will be considered a low- cost variable component , while storage will be valued based on opportunity cost .
For González, this type of clarification confirms that the decree seeks to integrate storage more fully within the system's operating rules, removing uncertainties that until now could affect the development of projects.
PMGD: Changes in pro-rata payments amid debate over stabilized price
In addition to storage, Decree 32 incorporates relevant changes for PMGD , a segment that was already at the center of regulatory discussion due to the impact of the stabilized price on system costs.
In recent days, ACENOR again criticized this mechanism and called for its elimination , warning that it generates additional costs for independent customers. This proposal adds to the ongoing debate about how to adjust the regulations governing small-scale distributed generation without hindering their contribution to the energy transition.
In that context, one of the most sensitive points of the decree is that PMGDs may be considered in pro rata or limitations when there is no capacity to place all the available energy in the system.
“One very important aspect of this regulation—which was highly controversial—is that it incorporates these pro-rata payments or limitations into PMGDs, since previously they could only be subject to pro-rata payments in cases of contingency for security reasons and not for economic reasons or lack of placement,” González stated.
He then added: “The PMGDs submitted several documents to the Comptroller's Office asking that this not be taken into account, because they considered that it altered the self-dispatch system they have.”
Generation-consumption systems and self-consumption customers
The regulations also govern generation-consumption systems , a concept designed for production complexes that combine industrial processes, self-generation and eventually storage, such as green hydrogen or desalination projects.
These systems will be able to participate in the short-term market , inject surpluses and provide complementary services , under the conditions established by the regulations.
Nevertheless, González considered: “Generation-consumption systems have been incorporated, but the impact that this may have, at least in the short term, will not be very evident, because green hydrogen projects have already been falling through or are on hold. It is not so easy to imagine that there will be a large incorporation of this type of actor into the system.”
Furthermore, she emphasized that the regulations addressed this issue with caution. According to the expert, the rules prevent existing installations from being automatically converted into generation-consumption systems and, at the same time, create the category of self-consumption customers , aimed at consumers seeking to incorporate upstream generation to reduce their exposure to systemic costs.
Automatic economic dispatch and short-term market
Another relevant point of Decree 32 is the progress towards automatic economic dispatch , a tool awaited by the sector to modernize the operation of the system.
Its full implementation, however, will not be immediate. “36 months, imagine. Just applying or implementing these rules is already going to be a major challenge,” González stated.
The decree also introduces adjustments to the short-term market , particularly regarding guarantees. Among these, it incorporates obligations arising from capacity payments into the calculation, whereas previously these were primarily linked to energy.
Declaration under construction: a new milestone for projects
Decree 32 also modifies the declaration process under construction , mandatory for generation units seeking to connect to the system.
The main novelty is the incorporation of a new milestone: the start of the construction of the project , which must be completed within one year of the declaration of construction .
“The projects that are declared to be under construction must be projects that have a sufficient level of progress and maturity to be able to meet this requirement,” González said.
Finally, as a general parameter of the regulations, González concluded: “Regarding the regulations as they currently exist, this is a step in the right direction. It was an expected and necessary step that had to be taken.”