David Celestra Tan, MSK
27 September 2020
Continuation
CONCERNS OF CONSUMERS
1. MSK as a consumer advocacy group is notper se againstthe idea of inter-connecting these two large off-grid islands to the main grid and Luzon. It just needs to be done right, funded right, charged to consumers’ right and implemented right over a right transition period.
2. Applicant NGCP however must properly acquire the legal right to annex these new areas to its franchise area.
3. MSK believes that a properly designed and sized interconnection will indeed enhance the power reliability in these islands by blending well with the on-island generation and that it offers access to the wholesale electricity spot market, a key source of reasonably priced supply augmentation in case of imbalances.
4. A holistic feasibility study however needs to be undertaken by the right authorities who can be objective and can assure that the inter-connection will be right for the consumers of Luzon and the islands, the government who has responsibility to craft an economic development plan for these islands and who had been subsidizing power in these missionary areas.
5. The feasibility studies should address such critical concerns as its role in the reliable power supply mix of these islands, the blending of on-island generation and imported power from the grid, the sizing of the power line, its routing, costs to consumers, and a practical transition plan to graduate these islands from a subsidized power system to a market based power generation supply on the grid.
6. An inter-connection plan should include the appropriate preparation of the receiving distribution systems on the island for the added power source, to cure the institutional, technical, and operational problems of these electric coops. Finally, the prudent use of the Malampaya gas revenues that under the law should support energy services on these affected islands.
7. Specifically, how do we make sure that an inter-connection at whatever voltage will sustainably improve the reliability of power services on these islands and that their power cost will not exceed the current P5.6404 SAGR rate. Finally, will the added transmission charge to the Luzon consumers be fair and reasonable for the benefit to them of the inter-connection?
8. There are immediate concerns on the skyrocketing costs of missionary subsidies in these off-grid areas resulting from onerous contracts, over contracting in guaranteed capacity and not energy, and continuing perpetuation of expensive and unreliable temporary power generators that are supposed to be only on interim basis of 1 to 2 years.
PRAYERS
1. For the Honorable Commission to hold in abeyance this application of the NGCP for the implementation of the 230KV Batangas to Mindoro until
a) a feasibility study is undertaken by the proper authorities, the DOE, the Transco, the NEDA, the NEA.
b) An appropriate approval by the Congressional Franchising Committee for the annexation of the two off-grid islands to the national grid franchise of the NGCP.
2. For the Honorable Commission to order in the meantime the NPC and NEA to undertake missionary subsidy reduction programs by eliminating the onerous provisions of current ESA’s and the curbing of over contracting of fixed capacities and not energies
3. When NGCP has established its legal right to annex and extend its facilities to these new off-grid islands, we pray that they be ordered to submit a 10 year transition plan that includes the phase out of the missionary subsidies, the resolution of existing power supply contracts that may be stranded as a result of the inter-connection, and the feasibility studies that will define the shape, form, and cost of the inter-connection.
These are the preliminary positions of the MatuwidnaSingilsaKuryente Consumer Alliance Inc. We reserve the right to submit further comments, ask questions, and request for data when we receive the submissions of the applicant NGCP. We also wish to reserve our right as intervenor to call witnesses for the consumers.
24 September 2020, Pasig City
DAVID CELESTRA TAN (signed)
Co-Convenor& Technical Consultant, MSK
Copy furnished:
1. National Grid Corp. of the Philippines
c/o Atty. Ronald Dylan P. Concepcion
dpo@ngcp,gov.ph
2. Office of the President of the Philippines
Rodrigo Roa Duterte
31420 Jose Laurel St.
San Miguel, Manila1005
3. Department of Energy
Energy Center. Rizal Drive, Meritt Road
Fort Bonifacio, Taguig City 1634
4. The Transmission Corp. of the Philippines
Power Center cor. BIR Road
Diliman, Quezon City 1101
5. National Power Corp.
Agham Road, Quezon City 1101
6. National Electrification Administration
#57 NEA Bldg. NIA Road
Government Center, Diliman QC. 1101
7. Oriental Mindoro Electric Coop.
Western Nautical Highway, Calapan
Oriental Mindoro 5200
8. Occidental Mindoro Electric Coop.
M. H. del Pilar Street
San Jose, Occ, Mindoro 5100
9. Congressional Franchise Committee
Philippine House of Representatives
BatasangPambansa, Constitution Hills, 1126 Quezon City
10. Joint Congressional Power Commission (JCPC)
Room 607 South Wing Bldg. House of Representatives
BatasangPambansa, Constitution Hills, 1126 Quezon City
11. Senate Energy Committee
Senate of the Philippines
Office of the Committee on Energy
Roxas Blvd, Pasay City 1300
12. Congressional Energy Committee
House of Representatives
BatasangPambansa, Constitution Hills, 1126 Quezon City
13. Office of the Governor, Oriental Mindoro
Provincial Capitol
Gov. Ignacio Street
5200 Calapan Oriental Mindoro
14. Office of the Governor, Occidental Mindoro
Provincial Capitol
Capitol West Road
Mamburao 5106
15. Office of the Governor, Palawan
Provincial Capitol
Puerto Princesa, Palawan
16. Bayan Muna Party List