ICSC Position Paper on the Draft Distributed Generation Company Licensing Rules and Microgrids
ICSC sent the following position paper and detailed tabular comments on the draft rules for distribution generation company licensing last July 4, 2017, to the Energy Regulatory Commission (ERC) under the Department of Energy. The draft rules address key segments of solar rooftop business potential, the categorization and regulation of industry players, which include providers, households, commercial and industrial customers, the distribution utilities.
Many of the providers that have purchase power agreements with rooftop owners are actually in legal limbo. Thus the lack of clear rules that address the nexus of competition issues as promoted by the Electric Power Industry Reform Act of 2001 (EPIRA) and the potentials of solar rooftops as provided under the Renewable Energy Act of 2008 has impeded the utilization of the abundant resource.
This is yet another case of regulations lagging behind technological and economic developments. To cite one example, EPIRA defines contestability at the level of a customer’s peak consumption. Solar rooftops already provide contestability of slices of load regardless of a customer’s peak demand.
Viking Logarta, energy policy advisor, and Jeffrey Koon, research assistant, attended the ERC’s consultations on the issue on July 17, 2017, which was meant to address the regulatory issues impending the progress of solar rooftops in the Philippines. In attendance at the public consultations were ERC commissioners, National Renewable Energy Board chair Jay Layug, and representatives of distribution utilities, solar providers, the distribution management committee, and law firms. It was presided by ERC lawyer Deborah Layugan.