LKI Press Statement 2022-002
February 7, 2022
Scrap or Defer implementation of the Green Energy Auction to the next administration.
I sent by email the attached
letter to Secretary A. Cusi and bared our arguments against the Green Energy Auction which we label as anti consumer . The email was acknowledged received by the office of Sec Cusi and Director Capongcol today Feb 7 .
P.O. Box 1161, QCCPO, NCR, Philippines 1100
Cell No. : +63 917-812-5546
Email : email@example.com
Facebook: Laban Konsyumer Inc.
Website : www.labankonsyumer.com
5 February 2022
ALFONSO G. CUSI
Secretary, Department of Energy
SUBJECT: Deferral and review of the implementation of the Green Energy Auction Program (GEAP) to next administration
Dear Secretary Cusi and Officials of the Department of Energy,
As early as September 8, 2021, our advocacy group, Laban Konsyumer, Inc., has expressed our vehement opposition to the hasty implementation of the Green Energy Auction Program (GEAP) as it perpetuates the Feed-In Tariff (FIT) and FIT-Allowance (FIT-ALL). While it bears a different name, the GEAP is an obvious disguise of Fit All and would still result in additional burden for electricity consumers who would eventually have to pay the charges to be remitted to the renewable energy developers in the GEAP, similar to the FIT-Allowance.
In pursuit of our advocacy for reasonable power rates, LKI has been consistent in our opposition to all unfair subsidy burdens as we even recommended that Congress immediately pass a law to repeal the FIT program since the cost of renewable energy has declined over the years and resulted in lower contracted generation costs.
You yourself, your honor has been consistently quoted in media and in the Senate categorically stating that the FIT Program is not only anti-consumer but creates a distortion on the fairness that should be the norm in the power industry. Thus, the GEAP, which would entail guaranteed rate for the renewable energy projects, should likewise be urgently recalled or cancelled.
Implementing the GEAP would contribute to the increase of the FIT-All charged to consumers nationwide. As in the original FIT, consumers would be given no choice, but to, again pay the businesses of RE developers participating in the GEAP.
Unlike the Renewable Portfolio Standards (RPS), the GEAP Rules has no provision to ensure protection of consumers against electricity prices increases. There is no assurance that the resulting Green Energy Tariff (GET) would be lower than recently approved RE-based Power Supply Agreements (PSA) of distribution utilities (DUs).
There is also no set capacity or volume for the entire program, and the limit is only set per auction round. GEAP appears to be worse than its predecessor as it appears to be an “unlimited FIT Program.” The DOE’s declaration of capacities to be auctioned off was only based on its own assessment and did not even undergo any public consultation. More importantly, any risk of over-contracting would be borne by electricity consumers, and not government.
Considering all these, the GEAP is obviously an ill-conceived program that will benefit only RE developers to the detriment of consumers.
We wrote this letter to urge the DOE to immediately put the GEAP on hold and not force its implementation during the remainder of this administration. We also encourage the deferral of the GEAP’s implementation to give more time to accommodate more discussions on the matter, which concerns us, consumers.
The State thus should refrain from enriching an already heavily subsidized industry at the expense of already burdened electricity consumers.
There is already a proposal to significantly increase the FIT-ALL, with just the existing roster of eligible plants. The FIT all will definitely grow if more plants become FIT eligible through the GEAP. As a footnote, LKI challenged in ERC the FIT increases of the existing eligible plants in Case No. 2021-001 RM which the ERC continues to sat down.
The Department can accept this letter from Laban Konsyumer Inc. as a formal opposition against the implementation of the GEAP. LKI reserves the right to take further legal steps to stop the implementation of the auction under the GEAP.
Very truly yours,
Atty. Victorio Mario A. Dimagiba, AB, LLB, LLM