On the Natural Gas Bill .


March  24, 2021

Senate Committee on Energy 

Pasay City

Attn. Sen Win Gatchalian

Re: Natural Gas Bill

Sir /Madam:

May we propose the following items.

1.On Incentives , the section should specify the other applicable laws. As a rule of thumb , incentives are revenue matters. The law must specify the exemption or incentives in the law itself.  Incentives cannot be lawfully extended by way of implementing rules and regulations .

Looking ahead ,the Omnibus Investment  Code may be repealed by another law. 

2. Section 30 on Treatment of Confidentiality , should be subject to the  provisions of the Franchise .The franchise provisions override any provision of a special law like the Natural Gas Bill.

3. On the Repealing Clause, it should specifically  repeal DOE  Circular 2017 -11-0012.

4. On the Transitory provisions, all existing natural gas facilities must be governed by the law . 

    This will avoid the existence of two classes of natural gas investors in the  country .

5 On the office, the law must create the office . The creation of an office cannot be lawfully delegated to an existing public office like the  DOE and the ERC.

Thank you.

Very truly yours,

Atty. Victorio Mario A. Dimagiba, AB, LLB, LLM President , Laban Konsyumer Inc.

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