LKI POSITION PAPER ON THE 2020 FEED IN TARIFF ALLOWANCE PETITION OF TRANSCO

2019-09-29 19:52:48


2020 Feed in Tariff Allowance ( FIT -ALL ) Application by Transco, ERC CASE 2019-56 R C


In an Opposition and Intervention filed on Friday , September 6, 2019, Laban Konsymer Inc. stated that Transco had publicly declared a surplus of Php 3.0 Billion on its FIT ALL collections and has enough financial leeway to pay the current FIT All claims of all RE developers.


TransCo practically eliminated their under recoveries by end-2018 at the FIT-All rate of Php0.2563/kWh. TransCo’s numbers show that the rate of reduction of the FD Under Recovery was around Php504 million per month. The FIT program will begin overcharging by Php504 million per month from consumers nationwide. Thus, the FIT-All rate and its burden on consumers must be reduced.


To remove the Php504 million per month overcharge from consumers, the FIT-All rate should have been reduced by Php0.0688/kWh to Php0.1875/kWh.


However, the Honorable Commission approved a reduced FIT All for 2018 in the amount of Php 0.2226 , and thus further contributed to Transco healthy FIT ALL collections and financial position.


The application for a marginal increase of Php 0.0052 pkwh for 2020 should be set aside until Transco submits to the Honorable Commission an updated FIT ALL collections as of filing of the application . The updated report can show whether the 2019 FIT ALL petition as well as the instant 2020 FIT ALL applications be dismissed for lack of cause of action.


LKI also observed a 6 billion increase in the forecast national sales from 2019 to 2020 , whereas the 2018 and 2019 electricity sales are almost identical at 86 B kwh . The Commission should carefully evaluate the assumptions and basis for the forecast.


LKI added that the the 2019 and 2020 FIT ALL applications have been rendered moot and academic and should be denied as such.





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