LKI POSITION PAPER ON VARIOUS DOE PROPOSED RULES ON ENERGY MATTERS

2019-09-29 20:09:14


On Department Circular No. DC 2019-05-0008, unbundling of the weekly adjustment on the prices of fuel products.



LABAN KONSYUMER INC. wrote the DOE Secretary on August 13, 2019 and extended LKI appreciation for the signature and issuance of the subject Department Circular.



In the light of the preliminary injunctions issued against the Department Circular by the regional trial courts, we offer another legal action that the Department could pursue against price fixing and the de facto cartel in the oil industry .


We believe that the The Department of Energy and the Department of Justice Joint Task Force should be activated now and be instructed to pursue and conduct appropriate investigation.


We had written your Department on April 16, 2018 and September 15, 2018 and we complained for an explanation on the oil industry pricing practice involving identical amounts of adjustments, price adjustments at the same time of the week, and applies across the country, as to whether these retail pricing practices are allowed by the Oil Deregulation Law.


We had written the Philippine Competition Commission and the Office for Competition of the Department of Justice on the same subject matter on June 12, 2018 with an accompanied Affidavit.


To date, no such clear public statements had been made by the Department nor the other relevant agencies that said pricing practices are not anti -competition and represent fair prices of the petroleum products.


When necessary and deemed appropriate, Laban Konsyumer Inc. can participate in such investigation for the purpose of a determination of competitive and fair prices of the fuel products.


 DOE DRAFT CIRCULAR ON REVISONS TO THE WESM MANUAL AND WESM PENALTY HANDBOOK.



Laban Konsyumer Inc . raises a fundamental issue. What is needed is the formation of  an indeendent market monitor  that can review market rules. The governance committees INCLUDE GENERATORS, DISTRIBUTION UTILITIES , GRID OWNER AND OPERATOR. There should be a third party monitor that are independent of the stakeholders..


On the Dispute Resolution Administrator, it would be best to go back to the birth of WESM when the dispute resolution was empowered to a committee of 5 professionals of different background. .


The DOE may find logic on Sen. Bill 590 of Sen Recto providing consumer representation in various regulatory agencies. .


There should be transparency thru making public the actual trading offers ( MW and Php/MW ) in a given  24 hours trading period.


The email proposals was received by the Office of Director Mario Marasigan of the DOE



DOE Draft Circular on Smart Grid Policy and Road Map


Laban Konsyumer Inc. welcomes the draft Smart Grid Policy and Road map. May we suggest to provide a clear and specific timetable of implementation . In addition, the specific activity and cost should be well established from the start.


Will the Smart grid policy eliminates system losses in the bill of the consumers?


What added cost will consumer bear when the policy is implemented?


Is it practical to phase in a reasonable transition period and by customer classification as in industrial. commercial and residential in that order ?


Likewise, in any TWG for the purpose, please consider a consumer representative .

THE proposal was acknowledged received by the Office of Director Marasigan of the DOE







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