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NATIONAL TRANSMISSION
CORPORATION (TRANSCO),
Applicant.
x--------------------------------------x
ORDER
6. Under the FIT Rules, the FIT System guarantees all eligible
renewable energy plants an entitlement to the applicable FITs for
a period of twenty (20) years.2
7. Further, Section 2.2 of the FIT Rules provides that the ERC shall
approve technology-specific FITs based on such FITs to be
ERC-APPROVED FIT
TECHNOLOGY RATES ERC-APPROVED DEGRESSION RATES
(PhP/kWh)
WIND 8.53 0.5% after year 2 from effectivity of FIT
BIOMASS 6.63 0.5% after year 2 from effectivity of FIT
SOLAR 9.68 6% after year 1 from effectivity of FIT
HYDRO 5.90 0.5% after year 2 from effectivity of FIT
16. On 19 November 2012, the ERC issued Resolution No. 15, Series
of 2012, designating TransCo as the FIT-All Fund Administrator
tasked with the establishment, management/ administration,
and disbursement/settlement (thru the Trustee Bank) of the FIT-
All Fund.
19. TransCo has so far made the following petition for the FIT-All
rate. TransCo requested for extension of its filing of the
application in certain years and the same were favorably granted
by the ERC.
Where:
DESCRIPTION
FIT-All is the Feed-in Tariff Allowance to be implemented in
Yeart+1 in PhP/kWh, as provided for in the FIT Rules
and the Guidelines.
FD is the estimated Total FIT Differential required for
Yeart+1 in PhP, and as further described in Section
1.4.1 of the Guidelines.
WCA is the estimated Working Capital Allowance required
for Yeart+1 in PhP, and as further described in Section
1.4.2 of the Guidelines.
AA is the Administration Allowance to be implemented in
Yeart+1 in PhP, and as further described in Section
1.4.3 of the Guidelines.
DA is the Disbursement Allowance to be implemented in
Yeart+1 in PhP, and as further described in Section
1.4.3 of the Guidelines.
ERC CASE NO. 2020-020 RC
ORDER/16 NOVEMBER 2020
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25. The FNS, in kWh, shall be equal to the latest available Electricity
Sales as stated in the Philippine Power Statistics, excluding
Utilities Own Use and Power Losses, or as otherwise certified by
the DOE and as adjusted by the historical growth rate published
for the immediately preceding three (3) years.
26. From the historical data provided by the DOE covering years
2016 to 20194, TransCo computed the compounded annual
growth rate (CAGR) of Electricity Sales for a 3-year period using
the formula:
Where:
V(t0) = beginning value
V(tn) = end value
tn-to = number of years
4The DOE letters dated 10 May 2018, 07 June 2019 and 20 May 2020 providing data on the
Historical Electricity Sales and Power Consumption, in MWh for years 2012 to 2017, 2018
Electricity Sales and Power Consumption (MWh) and 2019 Electricity Sales and Power
Consumption (MWh) are attached respectively hereto as Annex “A” to “A-7” to form an integral
part hereof;
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ORDER/16 NOVEMBER 2020
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2020 2021
90,525,566,639 95,642,839,642
2020 2021
81,549,061,150 90,991,584,020
29. The Total FIT Differential represents the difference between: (1)
the forecast applicable FIT Rate for Yeart+1 that each Eligible RE
Plant is forecasted to receive for each kWh delivered, and (2) the
forecast applicable cost recovery rate as determined under the
Guidelines, multiplied by the projected annual energy generation
from Eligible RE Plant for yeart+1. In setting the FIT-All for
Yeart+1, the FIT Differential is represented by the following
formula:
Where:
DESCRIPTION
Forecast RE is the Forecast RE Generation of Eligible RE Plantx
Genx,t+1 (in kWh).
Forecast FIT is FIT Rate, as degressed (if applicable) and adjusted
Ratex,t+1 for local inflation and foreign exchange (FOREX) as
forecasted for yeart+1, in PhP/kWh, that Eligible RE
5The computation of Forecast National Sales (FNS) for 2020-2021 is attached hereto as Annex “B”
to form an integral part hereof;
6 The computation of Forecast National Sales (FNS) under COVID-19 Scenario for 2020-2021 is
31. TransCo primarily used the most updated list of RE Projects that
are projected to be eligible/already eligible under the FIT System
in 2014-2021 and corresponding forecast data as provided by the
DOE7. TransCo likewise tapped its own database containing
historical information and the available submissions of RE
Developers on actual/forecast generation.8 Actual billing data
invoiced to the FIT-All Fund up to May 2020 billing period were
used where available.
32. Given the list from DOE which provides the best estimate of the
timing of entry of Eligible RE Plants, TransCo aims to be able to
adequately provide for the corresponding payout requirements.
However, the list does not in any way give preemptive right to the
identified projects to be counted under the final FIT-eligible
projects or limit the payment of FITs to these projects. Only
Eligible RE Generators providing actual generation to the grid
will be paid the FIT according to actual volume of generation.
7The DOE transmittal letter dated 05 May 2020 and its attachments are hereto attached as Annex
“C” to “C-16”.
8The 2020 to 2022 energy forecast generation per Eligible RE Plant are summarized in the “List of
FIT Eligible RE Generation Forecast Submission as of July 20, 2020” and its attachments marked
hereto as Annexes “D” to “D-64” to form an integral part hereof.
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ORDER/16 NOVEMBER 2020
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The 2022 levels are needed for the determination of the WCA.
9 Monthly Seasonality indices for Hydro and Biomass Plants are hereto attached as Annex “E”.
10The 2012 to 2020 levels are a mix of actual and forecast values.
11 Section 1.4.1.1, Guidelines.
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41. In the absence of new FIT rates to date associated with the
extended availment of the installation targets for Biomass and
Hydro until 2019, TransCo in the meantime applied further
degression to the 2017 degressed rates. And thereafter,
computed for the corresponding Adjusted FITs until 2021.
44. Simply put, the Forecast Cost Recovery Rate (FCRR) is the
projected generation rate that the Eligible RE Plant would likely
receive if it were not under the FIT System.
45. Under Section 1.4.1.2 of the Guidelines, the manner by which the
FCRR is forecasted and applied to a particular Eligible RE Plant
shall be based on whether or not the Eligible RE Plant operates
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46. Where WESM is operational (Luzon and Visayas), the FCRR for
the Eligible RE Plant shall be equivalent to the average of the
monthly system Ex-Ante Load Weighted Average Price (LWAP)
of the WESM for the Luzon and the Visayas Grids for the thirty-
six (36) months immediately preceding the filing of the
application for the setting of the FIT-All.
50. For the FCRR for Mindanao, potential Host DUs were identified
from the line-up of projects and their location. For current Host
DUs, namely, Davao del Sur Electric Cooperative, Inc.
(DASURECO), South Cotabato I Electric Cooperative, Inc.
(SOCOTECO I), First Bukidnon Electric Cooperative, Inc.
(FIBECO), South Cotabato II Electric Cooperative, Inc.
(SOCOTECO II) and Sultan Kudarat Electric Cooperative, Inc.
(SUKELCO), TransCo referred to the FIT-All Fund database of
Actual Cost Recovery Rates (ACRRs). For Manolo Fortich 1 & 2,
TransCo requested the ACRRs of its Host DUs, namely,
Zamboanga del Norte Electric Cooperative, Inc. (ZANECO),
Zamboanga del Sur I Electric Cooperative, Inc. (ZAMSURECO I),
Zamboanga del Sur II Electric Cooperative, Inc. (ZAMSURECO
II), Misamis Occidental I Electric Cooperative, Inc. (MOELCI I),
Siargao Electric Cooperative, Inc. (SIARELCO), Bukidnon
Second Electric Cooperative, Inc. (BUSECO), Surigao del Sur I
Electric Cooperative, Inc. (SURSECO I), Davao Light and Power
Co., Inc. (DLPC) and Cotabato Light and Power Co., Inc. (CLPC).
12The PEMC letter dated 28 April 2020 on the “Data on Load Weighted Average Price (LWAP) for
Luzon and Visayas” for the period 26 March 2017 to 25 March 2020 including its attachment are
hereto attached as Annexes “G” to “G-1” to form an integral part hereof.
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ORDER/16 NOVEMBER 2020
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Similarly, as for the FIT rates, the 2021 FCRRs were adopted for
2022 since these are merely intended for the determination of
the WCA, a buffer fund, as discussed below.
13Printouts of the 12 months Weighted Average Generation Rates of Host DUs are hereto attached
as follows: Annex “H” – Weighted Average Generation Rate for Mindanao Host DUs based on FIT-
All Fund Administration Database; Annex “H-1” to “H-17” – Weighted Average Generation Rate
from RE Plant Host Distribution Utilities and Annex “H-18”-Average Generation Rate of Mindanao
Host DUs in 2019.
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ORDER/16 NOVEMBER 2020
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54. It is estimated that total FIT Differential for 2015, 2016, 2017,
2018, 2019 and 2020 generation, amounting to
PhP113,932,987.66 PhP340,556,132.26, PhP70,296,337.88,
PhP62,813,311.87, PhP181,380,869.47 and PhP809,152,559.41,
respectively, will be due in 2021.15
14Table showing the details of computation of the 2020 FIT Differential (Over) Under-Recovery is
hereto attached as Annex “I” and made an integral part hereof.
15Summary of FIT Differential charged to 2020 and 2021 is shown as Annex “J” to form an integral
part hereof.
16 Copy of TransCo clarification letter on the Implementation of ERC Resolution No. 6 Series of
Again, the 2022 levels are shown only for the purpose of
computing the WCA which is discussed below.
58. It is worthy to note that the average effective ACRR from January
2020 to May 2020 billing months as derived from the FIT-All
Fund database is much lower than the FCRR in the 2020 FIT-All
application following the formula in the FIT-All Guidelines. If
this ACRR rate will continue until the December 2020 billing
month, additional FIT Differential requirement will be needed.
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ORDER/16 NOVEMBER 2020
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Wind
Luzon 2.1480 3.0161
Visayas 2.3101 3.1108
Solar
Luzon 2.2207 3.0161
Visayas 2.1112 3.1108
Mindanao 6.4167 5.7172
Biomass
Luzon 2.3652 3.0161
Visayas 2.3810 3.1108
Mindanao 5.3453 5.6324
Hydro
Luzon 2.6311 3.0161
Visayas 2.5511 3.1108
Mindanao 5.2656 5.2875
*based on 2020 FIT-All Application
59. The WCA is part of the FIT-All and serves as buffer to address
any default or delay in the collection and/or remittance of the
FIT-All and/or Actual Cost Recovery Revenue including, but not
limited to, the following:
ii. The timing difference of the collection and billing cycle for
the FIT-All and Actual Cost Recovery Revenue; and,
Where:
62. For the purpose of computing the WCA, the FCRRs used by
TransCo for 2022 were set at the same level as the 2021. The
same holds for the FIT Rates.
63. Summarizing Table 8 and Table 10, we have the following inputs
in computing the Forecast Annual Payout for 2022:
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ORDER/16 NOVEMBER 2020
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69. The Guidelines then provide for the use of a Factor Rate that will
be multiplied to the Forecast Annual Payout for 2022.
71. Further, the Guidelines define the WCA Ending Balance to be the
balance of the WCA component account for the immediately
preceding month prior to the month of filing. However, TransCo
17Document showing the 2021 and 2022 FIT-All Administration Allowance is hereto attached as
Annex “M” to form integral part hereof.
182021 Factor Rate computation using the formula recommended by NREB in its Resolution No. 3
Series of 2014 is attached hereto as Annex “K” to form an integral part hereof.
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ORDER/16 NOVEMBER 2020
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73. From the given information, the combined buffer required for
2021, which is equivalent to the 2022 fund requirement
multiplied by the Factor Rate, less the WCA ending balance, is
PhP2,420,118,687.64 derived as follows:
74. The table above shows the derived PhP/kWh level of the WCA for
2021, which is PhP0.0253/kWh.
75. As provided for in Section 2.5 of the FIT Rules, the FIT- All shall
also take into account the Applicant’s administration costs to
defray expenses of the Administrator in connection with the
performance of its functions as FIT-All Fund Administrator
(Administration Allowance).
78. From the Trust Agreement entered into by Land Bank of the
Philippines (LBP)-Trust Group and TransCo on 03 March 201520
and subsequently approved by the ERC, TransCo shall pay a fixed
fee of PhP720,000 per annum plus some variable components.
19Document showing the WCA Ending Balance is hereto attached as Annex “L” to form integral
part hereof.
20Copy of the Trust Agreement dated 03 March 2015 is hereto attached as Annex “N” to “N-23” and
made an integral part hereof. Also appended as Annex “N-24” is the list of additional Collection
Agents from the time the Trust Agreement was executed to present.
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80. Applying the above components to the formula for FIT-All, the
FIT-All rate for 2021 in PhP/kWh is:
82. On the other hand, the 2021 FIT-All under the COVID-19 FNS
scenario will be as follows:
21Details
of the 2021 Projected LBP Service Fee computation is hereto attached as Annex “O” and
made an integral part hereof.
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FIT-ALL Rate, P/kWh 0.1263 0.0619 0.1881 0.0209 0.2090 0.0122 0.2212
84. TransCo would like to limit its application to cover only the list
of RE projects with Certificate of Endorsement (COE) from the
DOE. This list already covers most of the potentially eligible
Biomass plants. The RE plants comprising the list of plants with
Nomination from the DOE are mostly hydro plants, and to date,
there is no finality regarding the policy for unsubscribed
capacities after the 2019 extension of FIT availment.
PRAYER
22“Section 3. Action on the Motion. - Motions for provisional authority or interim relief may be
acted upon with or without hearing. The Commission shall act on the motion on the basis of the
allegations of the application or petition and supporting documents and other evidences (sic) that
applicant or petitioner has submitted and the comments or opposition filed by any interested
person, if there be any.”
23A copy of the Judicial Affidavit of Ms. Rogelyn T. Ronquillo is attached hereto as Annex “Q” to
Other reliefs as may be just and equitable under the premises are
likewise most respectfully prayed for.
24The PEMC Manifestation to ERC dated 25 April 2019 to allow the Independent Electricity Market
Operator of the Philippines Inc. (IEMOP) to collect and remit the WESM proceeds of the FIT-
Eligible RE Plants as part of the market operations function is hereto attached as Annex “P” to form
an integral part hereof.
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3. One (1) set of hard copy of the Application with all the
annexes; and
4. One (1) set of soft copy of the Application with all the
annexes contained in a USB flash drive.
25A Resolution for the Transitory Implementation of Legal e-Processes Pending the Adoption of
the Interim Guidelines Governing Electronic Application, Filings, and Virtual Hearings Before the
Energy Regulatory Commission.
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Within five (5) calendar days prior to the date of the virtual
hearing, TRANSCO must submit to the Commission via electronic mail
(e-mail) at records@erc.gov.ph and records.erc.gov.ph@gmail.com,
copy furnish the Legal Service through legal.erc.gov.ph@gmail.com,
the scanned copies of their written compliance with the
aforementioned jurisdictional requirements attaching therewith,
methodically arranged and duly marked the following:
SO ORDERED.
LS: MVM/LSP/MCCG
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ORDER/16 NOVEMBER 2020
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Copy Furnished:
1. Attys. Noel Z. De Leon, Leon T. Tapel, Jr., Donna L. Caaloza-Aleria and Anne Rose
R. De Guia
Counsel for Applicant TRANSCO
Office of the General Counsel
TRANSCO Main Building, Quezon Avenue corner BIR Road
Diliman, Quezon City
OVP-Legal@transco.ph
annerosedeguia@yahoo.com