Categories
Posts Uncategorized

LKI POSITION PAPER ON VARIOUS DOE PROPOSED RULES ON ENERGY MATTERS

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