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

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.