On March 7, 2025, the “Agreement A/113/2024 of the Energy Regulatory Commission issuing the General Administrative Provisions for the integration of Electric Energy Storage Systems into the National Electric System” (“DACG”) was published in the Official Gazette of the Federation, which aims to establish the modalities and general conditions under which the integration of Electric Energy Storage Systems (“SAE”) into the National Electric System will be carried out. The purpose of the DACG is to ensure that the storage of electric energy is carried out in an orderly and economically viable manner.
On March 7, 2025, the “Agreement A/113/2024 of the Energy Regulatory Commission issuing the General Administrative Provisions for the integration of Electric Energy Storage Systems into the National Electric System” (“DACG”) was published in the Official Gazette of the Federation, which aims to establish the modalities and general conditions under which the integration of Electric Energy Storage Systems (“SAE”) into the National Electric System will be carried out.
The purpose of the DACG is to ensure that the storage of electric energy (which prior to the publication of the DACG was permitted by applicable legislation but lacked specific regulation) is carried out in an orderly and economically viable manner, allowing to counteract the variability of Power Plants with intermittent technology, as well as to take advantage of the products and services that SAEs can offer in the Wholesale Electricity Market (“MEM”).
The DACG considers the implementation of the following SAE modalities: (i) SAE associated with an Isolated Supply scheme (“SAE-AA”); (ii) SAE associated with a Power Plant (“SAE-CE”); (iii) SAE associated with a Load Center (“SAE-CC”); (iv) SAE associated with an Exempt Generator (“SAE-GE”); and (v) SAE not integrated into a Power Plant or Load Center (“Non-Associated SAE”).
Below are some of the most important points included in the DACG:
1. Interconnection/Connection Point of the SAEs
The SAEs, in any of their modalities, must be installed considering the same existing Interconnection or Connection Point, as applicable, or the one defined in the Connection Studies.
2. Technical Modification of Intermittent Power Plants
Existing intermittent Power Plants with a valid permit that intend to carry out the integration of an SAE will be considered for all purposes as a technical modification. Therefore, it will be necessary to:
• Submit a corresponding Study request to the National Energy Control Center (“CENACE”), and
• Submit the permit modification request to the Energy Regulatory Commission (“CRE”).
3. Request for Interconnection and Connection Studies
• Interconnection Study. For the request of Interconnection Studies for the SAE-CE, SAE-AA, and Non-Associated SAE modalities, they must be carried out according to the Manual for the Interconnection of Power Plants and Connection of Load Centers (“MIC”).
• Connection Study. For the request of Connection Studies for the SAE-CC modalities participating in the MEM and Non-Associated SAE, as well as for SAE-CEs intending to charge from the National Transmission Network (“RNT”) or the General Distribution Networks (“RGD”), they must be carried out in accordance with the MIC.
4. Ancillary Services
The SAEs, in their various modalities, may offer the Ancillary Services established in the regulation, provided they meet the requirements of the Market Rules and as their technical and operational capabilities allow.
5. Characteristics of the SAE Modalities
SAE-CE (Associated with a Power Plant)
In the SAE-CE modality, the SAE will be part of the Power Plant, and the set will be represented by the same Market Participant. The SAE-CE load must be carried out with the resources of the associated intermittent Power Plant. If the SAE-CE intends to charge its SAE from the RNT or the RGD, it must be indicated in the Interconnection Request.
SAE-GE (Associated with an Exempt Generator)
In the SAE-GE modality, obtaining a Permit is not required and it will be governed in accordance with the General Administrative Provisions, contract models, compensation calculation methodology, and general technical specifications applicable to distributed generation and distributed clean generation power plants.
SAE-CC (Associated with a Load Center)
Regarding the SAE-CCs, the SAE Power is part of the Contracted Demand or Maximum Demand of the Load Center, as applicable, meaning that at no time can the withdrawal of electric energy from the RNT or the RGD exceed the Contracted Demand by the Basic Supply User, or the Maximum Demand of the Load Center registered in a Qualified User Registration certificate.
The Load Center connected in Medium or High Voltage that installs an SAE must notify the CRE of the incorporation of the SAE for statistical purposes on the evolution of the SAE-CCs, within 90 (ninety) business days after installation.
SAE-AA (Associated with an Isolated Supply scheme)
The SAE-AAs include the set of Power Plant and Load Center for meeting the demand of their facilities' loads or for carrying out the import or export of electric energy in an Isolated Supply modality.
Non-Associated SAEs
Non-Associated SAEs will interconnect to the RNT or the RGD at an Interconnection Point established as a result of the Studies, independently and without being integrated into a Power Plant or Load Center. They must install, at the Interconnection/Connection point, the necessary Measurement Systems for the settlement process of transactions in the MEM.
6. SAE for Legacy Schemes.
It is established that since Energy Storage is provided for in the Market Rules, under the regulatory framework of the Electric Industry Law, to install an SAE in any of its modalities, the Power Plants and Load Centers included in a Legacy Interconnection Contract must carry out a total regime change.
7. Other DACG provisions
• As a general rule, the SAE-CE, SAE-AA, and Non-Associated SAE modalities
