The Argentine Chamber of Renewable Energies (CADER) presented to the National Energy Secretariat , led by María Tettamanti, a series of regulatory changes to accelerate distributed generation, unlock private investments and prevent large consumers from migrating to thermal contracts due to current restrictions.
One of the central points is the situation of the Large Distribution Users (GUDIs) who seek to move to GUMA or GUME categories, since the current scheme prevents them from maintaining a competitive strategy that combines self-generation, injection of surpluses and renewable contracting.
“ The problem with distributed generation units (GUDIs) is that they are fleeing the market because of the price they are being paid, even double the price they would pay for a power purchase agreement (PPA). And when they see the restrictions, they prefer to contract with thermal power for a year and then re-evaluate what is best. But if they had had distributed generation as an alternative, they could have contracted twice as much,” explained Marcelo Álvarez , president of CADER, in an interview with Energía Estratégica.
According to the Chamber, this point has the greatest potential impact in megawatts and is the only one of the six that requires amending the law. However, Álvarez believes a faster solution could be explored through an Emergency Decree (DNU).
“The proposal aims to ensure that the GUDIs market, which is currently rushing to enter into contracts, does not continue to do so with thermal energy, but rather with a mix of distributed generation, on-site generation, and renewable energy contracts in distribution networks,” explained the president of CADER.
The proposal is linked to an expansion scenario that CADER has already discussed with the authorities: to reach up to 3.7 GW of distributed generation in the coming years through regulatory modifications, without the need to reform the entire current legal framework .
Even in a maximum penetration trajectory, the potential scales up to 5 GW by 2030 , although that level would require deeper regulatory changes, including a possible transition from net-billing to net-metering.
“We discussed it with the Energy Secretariat, since it allows them to avoid making so many investments in infrastructure, boost private investment, accelerate the growth of distributed generation, and avoid the cost of having to pay for demand to be disconnected during peak summer times. So it's a win-win situation all around,” Álvarez emphasized.
Meanwhile, the second set of changes focuses on the Incentive Regime for Medium-Sized Investments (RIMI) . The Chamber is requesting the elimination of prior registration in the RENPER, RENPALMA, or the Generator User Certificate as a condition for accessing the benefits, and instead the existence of a prior and binding eligibility certification at the time of project submission.
“There was also talk of including the project as part of the RIMI renewables. Some tariff positions for the main components have already been liberalized, but not for the project itself,” the interviewee added.
“And the EPC, minor materials, engineering, the overall costs of installing a distributed renewable system is roughly 30% of the total. So we discussed proposing a methodology that is already being used by industry in other sectors,” he added.
For this reason, the Chamber proposes to incorporate these costs with a safeguard: a limit equivalent to 50% of the value of the equipment , to avoid overbilling.
Likewise, a change was presented to the Ministry of Energy intended for imports of components for distributed generation, requesting free access to the Single and Free Exchange Market for advance payments and an individual customs classification for components marketed by wholesale importers.
According to the sector diagnosis, the requirement of the shipping document forces the financing of advances through letters of credit , increasing the financial cost that is then passed on to the final price of the systems.
In response to these proposals, the president of CADER highlighted the government's willingness to analyze measures that do not compromise budgetary resources: "Anything that technically promotes distributed generation at zero cost to the government, they will do. Because they are committed to pursuing that path."
Energy Transition Law
The agenda with the Energy Secretariat also included the Energy Transition Bill that CADER has been working on for two years, in order to create a specific forum to explain its regulatory, financial and systemic implications.
“They are interested in holding a kind of seminar with a presentation explaining what the energy transition law means in terms of costs and restrictions. They opened the door for us to present the energy transition law ,” said its president.
The Chamber argues that the initiative does not entail a direct economic cost for the State , but rather a modification of the regulatory framework and an increase in commitments linked to nationally determined contributions.
The proposal includes seven chapters and aims to obtain parliamentary status this year , although CADER admits that it could advance in legislative stages if there is no consensus to approve the entire package.
One of the key issues is the cost of capital. According to information provided by the Chamber, financing for green infrastructure in Argentina is around 8% in dollars , equivalent to double or more than in neighboring markets like Chile.
The proposal seeks to connect the transition framework with the competitiveness of the electricity market, job creation, trade balance and the attraction of foreign capital .
“We discussed creating a forum for discussion regarding the transitional law so that we can present opportunities to lower the cost of electricity in Argentina, generate employment, improve the trade balance, and attract foreign investment,” Álvarez concluded.