When the rule gets calculated before the parameters are published

In the Chilean power market, the rule changes that have worked share two conditions: they went through the right channel, with the parameters on the table.

In the Diesel Fuel Availability Uncertainty Factor procedure, the second condition is still pending — and the timing makes that sequence matter well beyond diesel.

The technical diagnosis is correct

Worth starting there, because the debate isn’t about the diagnosis: a unit that is technically available but lacks the fuel to sustain its output is not real backup. ACERA, the renewables trade association, quantified it — on the order of 3,500 m³/day of replenishment capacity against the ~25,000 m³/day that running the full fleet at full load would require.

That gap is real and deserves a methodology that recognizes it. The debate isn’t whether the gap exists.

The issue is sequencing

On July 31 Chile’s grid operator (Coordinador Eléctrico Nacional, CEN) extended the comment period. Companies had asked for until August 21; they got a week.

Alongside the extension, something else had been requested: publishing a worked example of how the factor would be applied, along with the supporting material for the Diesel Report. That didn’t happen. The replenishment zones and their capacity remain undefined — deferred to a later technical study.

The result is that additional days were granted to analyze something that still isn’t calculable. No company can estimate its exposure without the zones or that worked example. The extension addressed the form of the request; the substance is still pending.

Why the schedule matters more than the deadline

The methodology enters the initial capacity calculation, with first application in October. From there it flows into the five-year average behind 2027’s Sufficiency Power.

That means 2026 will be calculated under a methodology whose parameters have yet to be published. And a year that enters a five-year average doesn’t get corrected afterward: what’s decided in October isn’t amended in November. It carries for five years.

The process, moreover, is far from closed even after the comment period closes: the replenishment zones are still missing, as are verification of the contractual taxonomy against real portfolios, the first application, and the carry-through to the five-year average.

What can be done without the worked example

There’s a practical difference between waiting for that worked example and sizing one’s own exposure using the mechanics already published. The latter is possible today, and it’s what makes it possible to enter the conversation with a number rather than a procedural objection.

That, concretely, is the distance between following a regulatory process and anticipating its effect on one’s own revenue.

The reading goes beyond diesel

If an internal procedure can redefine the capacity revenue base of a technology without publishing the parameters that determine it, the same mechanism can apply to storage tomorrow.

At that point it’s no longer about amortized assets, but about the pipeline currently being financed — where a shift in the capacity revenue base doesn’t just adjust a margin: it decides whether the project closes.