May 22, 2018
Committee on Energy
House of Representatives
Re: Draft Substitute Bill on the System Loss Cap
Our comments and recommendation.
1. The section on performance incentives scheme should contain criteria and standards to ensure that the delegation of authority to the ERC shall be valid and reasonable. The incentives should encourage pdus and ecs to fast track on a lower than the system loss cap provided in the law.
2. The statement of account should contain a statement of the actual system loss compliance of the Pdus and ecs.
3. The savings of the subscribers arising from a lower system loss cap should also be stated in the statement of account so consumers are informed of the benefits derived from the law.
4. There must be a competent, reliable third party and independent system loss surveyor or auditor who should not be a regulator that shall publish and inform the public of pdus and ecs compliance to the law. In this regard, the law should spell out the criteria and standards of such an audit or survey. The auditor or surveyor shall report to the joint oversight committee which is proposed to be provided for in the law.
Very truly yours,
Atty. Victorio Mario A. Dimagiba, AB, LLB, LLM
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