RE Dev Phils
RE Dev Phils
RE Dev Phils
April 2017
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The Renewable Energy Policy Debate in the Philippines
Abstract
The Philippines enacted two legislations to promote RE deployment: the Renewable Energy
Act of 2008 and the Biofuels Act of 2006, in recognition of the advantages of the use of
renewable energy (RE) as energy source. However, there remain issues and criticisms on the
promotion of RE technologies and on the implementation of the RE laws. Both sides of the
debate have their justifications for supporting or not supporting the use of RE resources and
technologies. The implementation of the RE laws, rules and regulations has also been receiving
criticisms. For this paper, data and information on the areas of debate were collected and
examined. Findings provide some reference for revisiting the RE laws and regulations to
improve their implementation and produce better outcomes for stakeholders.
Keywords: renewable energy, policy debate, Philippine Renewable Energy Act, Philippine
Biofuels Act
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The author would like to thank Dr. Adoracion M. Navarro for conceptualizing this study and for providing
inputs and guidance in the preparation of the paper. The author would also like to thank Dr. Gilberto M. Llanto
for his inputs and comments, and Mr. Keith Detros and Ms. Kirsten dela Cruz for their assistance in the data
collection.
Table of Contents
1. Background ..................................................................................................................................... 4
2. Analytical Framework..................................................................................................................... 5
2.1 Socioeconomic effects of Renewable Energy (RE) technology development/ deployment ......... 6
2.2 Policy instruments in promoting RE development ....................................................................... 9
3. Profile of the RE sector in the Philippines .................................................................................... 10
3.1 Regulatory and Policy Environment ........................................................................................... 10
3.2 Renewable energy sources .................................................................................................... 14
3.2.1 Primary energy mix ........................................................................................................... 14
3.2.2 RE for electricity generation ............................................................................................. 15
3.3 Biofuels program ........................................................................................................................ 19
4. Global trends in renewable energy development and use ............................................................. 23
5. Implementation of policies and emerging issues .......................................................................... 27
5.1 General policy direction on encouraging more renewable energy development ........................ 27
5.2 Net metering for on-site RE generation ...................................................................................... 35
5.3 Feed-in tariff policy .................................................................................................................... 36
5.4 Priority dispatch policy ............................................................................................................... 37
5.5 Policies in RE Act of 2008 which are yet to be implemented..................................................... 38
5.5.1 Renewable portfolio standards ............................................................................................. 38
5.5.2 Green Energy Option ........................................................................................................... 39
5.5.3 Renewable Energy Market ................................................................................................... 39
5.5.3 Incentives that have not yet been implemented ................................................................... 39
5.5 Compliance with Biofuels Act of 2006....................................................................................... 39
6. Conclusion and Recommendations for Policy .............................................................................. 40
References ............................................................................................................................................. 42
List of Tables
Table 1: Key features of laws on renewable energy ............................................................................. 11
Table 2: Electricity Generation Sources ............................................................................................... 15
Table 3: RE-based capacity installation targets .................................................................................... 18
Table 4: RE-based capacity targets vs installed capacity as of 2015 .................................................... 18
Table 5: Summary of awarded renewable energy projects ................................................................... 19
Table 6: Biofuels registration/accreditation .......................................................................................... 19
Table 7: Biodiesel measurable targets .................................................................................................. 21
Table 8: Bioethanol measurable targets ................................................................................................ 21
Table 9: Biodiesel measurable targets vs actual production ................................................................. 22
Table 10: Bioethanol measurable targets vs actual production ............................................................. 22
Table 11: Renewable energy support policies in selected countries ..................................................... 26
Table 12: Feed-in Tariff rates in selected East Asian countries............................................................ 36
List of Figures
Figure 1: Socio-economic effects of renewable energy .......................................................................... 7
Figure 2: Philippines Primary Energy Mix, 2010, 2014-2015 (in percent) .......................................... 14
Figure 3: Electricity generation by source, Installed capacity (in percent) ........................................... 16
Figure 4: Electricity generation by source, Dependable capacity (in percent) ..................................... 16
Figure 5: Consolidated RE Roadmap.................................................................................................... 17
Figure 6: Biodiesel local production (in million liters) ......................................................................... 20
Figure 7: Bioethanol local production (in million liters) ...................................................................... 20
Figure 8: Fuel shares in world total primary energy supply, and product shares in world RE supply,
2014 ...................................................................................................................................................... 23
Figure 9: Estimated renewable energy share of global electricity production, end-2015 ..................... 24
Figure 10: Share of renewables in electricity production, 2003-2013 (in percent)............................... 25
Figure 11: Annual estimated capital costs for solar PV technologies ................................................... 28
Figure 12: Annual estimated capital costs for wind technologies......................................................... 28
Figure 13: US average levelized costs of electricity by technology, 2010 USD/MWh ........................ 29
Figure 14: US average levelized costs of electricity by technology, 2013 USD/MWh ........................ 30
Figure 15: Summary of stages of RE project development .................................................................. 31
1. Background
Like other countries, the Philippines has recognized the impact of high dependence on fossil
fuels and exposure to price fluctuations, and the importance of balancing sustainable economic
growth with protection of public health, the natural ecosystem and the environment, on matters
concerning energy production. These in mind, two important legislations were passed:
Republic Act (RA) 9367 or the Biofuels Act of 2006, and RA 9513 or the Renewable Energy
Act of 2008. The Biofuels Act aims to reduce the dependence of the county on imported fuels
by promoting the development and mandating the use of locally-sourced biofuels. Under this
law, entities that conduct activities related to bio-fuels development – such as production,
storage, and handling, enjoy incentives such as exemption from specific tax and value added
tax, and shall be eligible for financial assistance from government institutions. Complementary
to this, the Renewable Energy Act seeks to accelerate the exploration and development of the
country's renewable energy resources such as biomass, solar, wind, hydro, geothermal and
ocean. One major incentive under this law is the Feed-in-Tariff (FiT) scheme for renewable
energy developers.
While laws and policies on the implementation of RE technologies are being executed
worldwide in view of the advantages/benefits, there remain issues on the promotion of the
renewable resources as source of energy. An inherent quality of RE sources (wind, solar, hydro,
geothermal, ocean, biomass, and biofuel) is that they will not run out (replenishable) and have
minimal negative impact on the environment (National Association of Regulatory Utility
Commissioners (NARUC), 2011). Conventional energy sources (e.g. coal, fossil fuel), on the
other hand, can be quickly depleted as natural replenishment/replacement is slow, and its
carbon and greenhouse emission levels have received criticisms. However, RE sources can be
variable or intermittent – dependent on weather (e.g. rain, wind and sunlight); while
conventional energy sources can provide base load power especially for large
industries/demand.
Cost-wise, RE technologies are generally capital intensive/require large fixed costs. The
Foundation for Economic Freedom (FEF), a public advocacy organization in the Philippines,
opined that instead of promoting RE projects that are expensive, it would be ‘prudent’ to
rehabilitate and improve existing hydroelectric and geothermal sources, and wait until the cost
of the more prominent but more expensive technologies such as solar and wind drops in
comparison with conventional energy sources (Fajardo F. , 2011). The Philippines, anyhow,
has low carbon foot print and is the second largest producer of geothermal energy. On the other
hand, advocates of RE technologies are quick to note that the cost of externalities should also
be included in estimating costs of using conventional energy sources, hence comparing costs
should be subject to further study/evaluation.
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of their power generation at a cost-based price with reasonable rate of return on investments
over a long period of time’ (Pacudan, 2014). The FEF likens FiT rates to a tax, an amount that
would be charged to consumers (Chikiamco, 2012). Apart from being relatively high,
especially if compared with rates in other countries (DLA Piper, 2014), the scheme of
implementing fixed rates for 20 years received criticism. One view is that advancements in
technologies for RE sources will push down costs and prices, explaining the opposition to
pegging FiT rates (Chikiamco, 2012).
In the biofuels sector, compliance with the targeted blends in fuel is a concern. One of the goals
of the Biofuels Act is to ‘develop and utilize indigenous renewable and sustainably-sourced
clean energy sources to reduce dependence on imported fuels’, but this objective appears to be
challenging to accomplish. With the reported lack of capacity of existing sugarcane distilleries,
low productivity and high production cost, bioethanol producers have been importing ethanol,
mostly from Thailand,2 to comply with the mandated 10 percent ethanol blend requirement
(E10) – prompting an UNCTAD study to conclude that the Philippines would likely remain a
net importer of fuel (Olchondra, 2014). Moreover, in biodiesel, the target of 5 percent blend
had to be assessed as biofuel suppliers are unable to meet the required demand, as of 2014.
These and other issues in RE utilization and deployment are discussed in this paper. Collecting
and analysing data and information on the areas of debate may provide some reference for
revisiting the RE law and regulations to improve its implementation and produce better
outcomes for stakeholders.
2. Analytical Framework
Environmental impacts of conventional energy sources, limited fossil fuel supply and volatile
price of fossil fuel are some of the motivations of many countries in pursuing RE development.
In a country like the Philippines which has limited local fossil fuel resources, there is high
dependence on imported fuel, exposing the economy and the general public to price
fluctuations. The promotion of RE development, through issuing laws and regulations, has
become the government’s measure to achieve self-sufficiency and energy security (Pacudan,
2014). As in other energy sources, the use of RE has both benefits and costs. The framework
for analysis in this study builds on the concepts covering socioeconomic effects and policy
mechanisms in promoting RE technology deployment.
2
Thailand is reported to be consuming more of its own ethanol, hence it is possible that the Philippines would
have to start importing from the US or Brazil, leading to higher cost due to transportation. (Olchondra, 2014).
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2.1 Socioeconomic effects of Renewable Energy (RE) technology development/
deployment
One of the ways to understand renewable energy use is to look at costs and benefits. IRENA
& CEM (2014) presented an analytical framework (Figure 1), based on existing literature and
on-going research that examined the socio-economic effects of RE implementation/
deployment through different categories: macroeconomic effects, distributional effects, energy
system-related effects, and additional effects (e.g. reduced risks). The macroeconomic effects
include value-added, GDP, welfare, employment, and trade balance-related issues such as trade
in energy products and equipment and domestic production. On one hand, these effects can be
assessed in terms of gross impact by looking at how the RE sector or RE deployment affects
the economy, without considering the possible negative effects on other sectors in the economy
(e.g. fossil fuel sector). On the other hand, net impact assessment can also be done to determine
whether there are positive or negative effects on the economy as a whole.
Value added of the sector can be assessed at the firm, industry or economy-wide level. Welfare
can be viewed through how RE deployment will be able to provide clean alternatives and
address issues in different dimensions of well-being such as those related to the environment
and health.
Employment may be examined in terms of direct and indirect jobs created in the RE sector.
Direct employment are those jobs in the RE sector itself, while indirect employment refers to
jobs in supporting industries such as steel or software. There is debate on whether RE
deployment leads to net job gains or losses: job creation vis-a-vis the extent wherein possible
increases in electricity prices related to renewables could lead to employment losses.
Trade balance may refer to trade in energy products (e.g. fossil fuels) and trade in goods and
services related to RE (e.g. solar panels, components, consulting services). Trade in energy
products covers trade in final energy (e.g. electricity) in primary energy (e.g. crude oil) or in
other natural resources needed to produce energy (e.g. raw uranium ore). For fuel-exporting
countries, RE deployment minimizes the domestic use of fuels and maximizes amount
exported. On the other hand, for fuel-importing countries, RE deployment can substitute for
imported fossil fuels, thereby decreasing imports which may lead to savings. Trade in goods
and services include exports and imports of RE technology equipment, such as those for
building manufacturing plants/production of RE equipment. Impact on trade balance may be
negative or positive, depending on the level of reduction in imports of fossil fuels and increase
in importation of RE equipment.
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Figure 1: Socio-economic effects of renewable energy
Note: In this framework the widely used concept of “energy security” or “security of supply” is divided between
aspects related purely to the trade balance (classified within “macroeconomic effects”) and those related to
technical geopolitical or financial risks (classified within “additional effects”).
Source: Figure 1.1 in IRENA & CEM (2014).
Distributional effects refer to allocation effects (benefits and costs) to different stakeholders
within the whole energy sector. IRENA & CEM (2014) describes distributional effects can
occur: (i) among stakeholders within the renewable energy sector itself (e.g. among types of
owners of renewable energy plants); (ii) within the energy sector as a whole (e.g. between
renewable and conventional energy sources and among different types of energy consumers);
(iii) throughout the economy at the municipal, sub-national, national, regional or even global
level; (iv) between different sets of agents (e.g., households of different income levels, firms,
governments); or (v) more generally between different generations (in view of the
intergenerational equity debate in the framework of sustainable development). Positive effects
are expected for beneficiaries and negative effects for those who are disadvantaged by RE
implementation (‘bear the corresponding burden’).
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even inspire public support. There is challenge though on the availability of empirical analyses
at these levels due to data availability concerns.
Depending on the national energy policy, some stakeholders in RE deployment benefit and
some may bear the burden or the additional costs. Additional costs may be passed to the tax
payers or final electricity consumers. For instance, feed in tariff that are implemented in some
countries are paid by the final electricity consumers. The challenge is to implement a system
of burden sharing that is consistent with the energy policy and acceptable to all stakeholders.
On the fiscal benefit/burden perspective, there are at tax revenues, subsidies and charges
associated with RE deployment. Tax payments come from the individuals/companies that own
or implement the RE projects. For cities, regional or other levels of government, local
executives find interest in knowing how much the locality will benefit such as from tax revenue
that is expected to be generated from setting up and operating RE technology in their area.
Energy system-related effects refer to the additional costs or benefits of RE-based system
compared to conventional power generation system. This category includes the direct and
indirect benefits and costs of RE deployment, for instance: the additional generation cost, e.g.
due to more frequent ramping, hence more frequent maintenance; additional balancing costs,
e.g. need for backup capacity; additional grid costs, e.g. to accommodate power generated in a
newly developed offshore wind farm; additional transaction costs, e.g. cost of wind forecasting;
benefits of reduced energy losses (some may also be classified within the trade balance issues);
benefits of reduced negative environmental externalities.
Under this category, additional generation and balancing costs refer to costs related to
electricity generation from RE technologies, including installation and operations and
maintenance, which occur when electricity generation from RE technologies replace that from
conventional sources. A known simplistic method of capturing this is by calculating levelized
costs of electricity from the different technologies. Balancing costs, in particular, refer to the
need for ‘balancing intermittent generation from RE sources in the short run to ensure system
stability, and for providing sufficient firm generation capacity in the long run to ensure security
of supply in times of peak demand.’
Additional grid and transaction costs refer to costs incurred at the level of distribution or
transmission grids related to extension, reinforcement or technologically upgrading of grids
associated with RE deployment. Transaction costs refer to RE-induced costs between market
participants such as forecasting, contracting, and to policy implementation costs, for instance
due to reporting and monitoring obligations.
Externalities can be positive or negative. RE technologies are said to have the potential to avoid
negative externalities that would have been acquired in conventional energy sources.
Establishing a cap on CO2 emissions and emission trading systems have been used as
instruments to capture and internalize externalities such as climate change, for instance in
Europe and OECD countries, in an attempt to influence the decisions of companies and
consumers.
Additional effects cover all remaining benefits and costs that may be associated with RE
deployment and can be classified under more than one category (cross-category). One of the
examples is risk reduction. It can refer to mitigation or reduction of possible accidents
associated with conventional energy sources (e.g. nuclear accidents, oil spills, etc.); lower
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technical risks associated with a more decentralized energy system; reduction of geopolitical
and financial risks associated with energy dependence in importing countries (covers energy
security and trade balance effect).
There are financial risks mitigated by using RE technologies whose costs are more predictable
as opposed to fossil fuel-based system whose cost/price is volatile. However, in RE
technologies, there may be high dependence on imported equipment, components or raw
materials used for domestic production; hence posing both financial and geopolitical risks
(effect of supply disruptions and price fluctuations).
Different policies have been implemented by governments to promote and support the
development of renewable energy, such as the feed-in-tariff (FiT), bidding system, quota
system, green certificate trading, and fiscal incentives (e.g. rebates, tax exemptions).
Menanteau, Finon, & Lamy (2003) classified three of these policies into quantity-based
scheme: bidding system and green certificate trading; and price-based scheme: feed-in tariff
(FiT). Under the bidding system, an amount of renewable energy to be generated is defined by
the regulator who then organizes a competition to allocate the amount among renewable energy
producers. Selected producers are awarded with long-term contract to supply electricity at the
pay-as-bid price. Electric utilities are obliged to purchase the electricity from the selected
energy producers. The cost of support/subsidy to producers is covered either by adding in
electricity bills through a special levy or cross-subsidizing among all electricity consumers.
Under the quota obligation scheme, also referred to as renewable portfolio standard (RPS) or
renewable energy target, the obligation, i.e. to source a minimum percentage of electricity from
eligible renewable energy, is imposed on energy producers, suppliers or distribution
companies. Following this policy, electricity from renewable energy sources may be produced
either by investing in projects, purchasing electricity through long term contracts from
specialized RE generators, or by purchasing traded green certificates from other generators
(IRENA & CEM, 2014). The implementation of this scheme would also involve penalty for
non-compliance to ensure that obligated parties meet the renewable energy purchase
obligations. The approach that has been used by some countries to simplify the burden of
validating compliance and to enable flexibility in achieving compliance is to incorporate green
certificate trading in the quota obligation system or RPS (Linden, et al., 2005; Brick & Visser,
2009). In the Philippines, under the Renewable Energy Act, renewable energy certificates will
be issued to electric power industry participants (indicating energy sourced, produced, sold or
used), and which may be traded in the renewable energy market in complying with the RPS.
Green certificates, in particular, are issued by renewable electricity generators by selling them
in the network at market price or by selling them in the green certificates market. Having a
certificate system enables quotas to be allocated in an efficient way, as the mechanism results
in equalized marginal production costs among operators and possible entry of specialized
producers in the market.
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The Feed-in Tariff (FiT) system is considered as the most popular policy instrument (IRENA
& CEM, 2014). Under this scheme, eligible RE producers are guaranteed a standard rate or
purchasing price for a specific period of time for electricity that they produce. The FiT system
operates as a subsidy allocated for renewable electricity producers. The cost of subsidizing
producers of the electricity from renewable energy sources is covered by: cross-subsidies
among all electricity consumers, or the customers of the utility obliged to buy green electricity,
or the taxpayers (Menanteau, Finon, & Lamy, 2003).
Compared with the bidding scheme, the FiT scheme is said to be more efficient (green
certificate trading scheme theoretically appears to be most efficient, but has to be proven more
in practice (Menanteau, Finon, & Lamy, 2003). International experience confirms that the FiT
scheme is the most cost effective measure to deploy renewable energy technologies (Pacudan,
2014). The FiT system is used in countries like the US, Japan and selected ASEAN countries
such as Thailand, Malaysia and the Philippines. In the Philippines, the FiT payment is
guaranteed for 20 years, with rates differentiated by type of technology. As a guaranteed rate,
the FiT is expected to be effective in mitigating market and price volatility risks thereby making
renewable energy development attractive and economically and financially feasible for
investors to venture into (Guarin, 2013).
Apart from the regulatory policies mentioned above, fiscal incentives are offered by
governments to encourage investments in RE development (IRENA & CEM, 2014). These
types of incentives take the form of tax exemptions/reductions, subsidies, grants, soft loans, or
rebates. Tax exemptions or reductions, for instance in equipment importation, value-added or
sales, are said to be effective in encouraging investment especially in countries where tax rates
are relatively substantial and where there is high dependency on imported RE equipment and
technology. On the other hand, monetary assistance such as capital subsidies and rebates, have
been applied to help reduce RE system costs including purchase of equipment for RE projects.
The Philippines has two major policies on the renewable energy: the Biofuels Act of 2006 (RA
9367) and the Renewable Energy Act of 2008 (RA 9513). The Biofuels Act aims to reduce
dependence on imported fuels by mandating utilization and promoting the development of
locally-produced biofuels. It covers regulations on ‘production, blending, storage, handling
transportation, distribution, use and sale of biofuels, biofuel blends and biofuel feedstock in the
country’. In the same vein, the Renewable Energy Act aims to accelerate the exploration and
development of renewable energy resources and reduce the country’s dependence on fossil
fuels to ‘minimize exposure to price fluctuations international markets.’ The Act provides for
fiscal and non-fiscal incentives to promote efficiency and cost-effectiveness of renewable
energy systems. The Feed-in Tariff (FiT) scheme is a major feature of this law.
The Department of Energy (DOE) is the lead agency in implementing the provisions in both
renewable energy laws and their respective implementing rules and regulations (IRR). Key
features of the two laws on renewable energy are presented in Table 1. Key provisions of these
laws will be discussed in more detail in the succeeding sections.
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Table 1: Key features of laws on renewable energy
Title Key features
Biofuels Act of 2006 (RA 9367) Mandatory use of biofuels. All liquid fuels for motors and engines sold in the country
shall contain locally-sourced biofuels components, following the mandated proportion or
blend. The initial mandated blend is minimum of 2 percent by volume for biodiesel, and 5
percent for bioethanol.
Phasing out of the use of harmful gasoline additives and/or oxygenates.
Fiscal incentives: zero specific tax on local/imported biofuels component per liter of
volume; value-added tax rate (VAT) exemption for sale of raw materials used in the
production of biofuel (e.g. coconut, jathropa, sugarcane, cassava, corn, sweet sorghum).
Exemption from wastewater charges (under the Clean Water Act) for all water effluents
as they are considered ‘reuse’.
Financial assistance: Government financial institutions (GFIs) will extend financing with
high priority to Filipino citizens or entities (at least 60% Filipino-owned shares) involved
in biofuel activities from production to transport, including blending of biofuels with
petroleum.
Creation of the National Biofuel Board (NBB). The NBB will monitor the
implementation of the National Biofuels Program; provide recommendations to the DOE
on matters concerning supply/production and utilization of biofuels and biofuel-blends.
Security of domestic sugar and feedstock supply. The Sugar Regulatory Authority (SRA)
will formulate guidelines in ensuring sufficient supply of sugar to meet the domestic
demand and stable price of sugar.
Security of domestic biofuels feedstock supply. The Department of Agriculture (DA) will
ensure reliable supply of biofuel feedstocks.
Development of a social amelioration and welfare program for workers in the production
of biofuels.
One-stop Shop is created for processing applications for feedstock production, biofuels
and biofuel blends production and distribution.
Renewable Energy Act of 2008 (RA Renewable Portfolio Standards (RPS), which is set by the National Renewable Energy
9513) Board (NREB).
Feed-in Tariff (FiT) System- for electricity produced from wind, solar, ocean, run-of-
river hydropower and biomass. The Energy Regulatory Commission (ERC), in
consultation with NREB, will formulate the FiT rules and set the FiT rates.
Renewable Energy Market (REM), which will be operated under the Wholesale
Electricity Spot Market (WESM). A Renewable Energy Registrar will be established by
the Philippine Electricity Market Corporation (PEMC) that issue, keep and verify RE
certificates used for compliance with the RPS.
Green Energy Option program that provides end-users the option to choose RE resources
as their source of energy.
Net Metering agreements with qualified end-users who will be installing the renewable
energy system.
Fiscal Incentives: income tax holiday; duty free importation of renewable energy
machinery, equipment and materials; special realty tax rates on equipment and
machinery; net operating loss carry-over; accelerated depreciation; zero percent VAT;
cash incentive of renewable energy developers for missionary electrification; tax
exemption of carbon credits; tax credit on domestic capital equipment and services.
Exemption from universal charge for renewable power and electricity generated for the
generator’s own consumption and/or for free distribution in the off-grid areas.
Fiscal incentives for farmers engaged in plantation of biomass resources.
Fiscal incentive for end-users in renewable energy system hosts communities/LGUs
whose monthly electricity consumption does not exceed 100kWh.
Financial assistance: GFIs will provide preferential financial packages for the
development, utilization and commercialization of RE projects (with endorsement from
DOE).
Creation of the Renewable Energy Management Bureau (REMB) under DOE. The
REMB’s function include among others: develop, formulate and implement policies,
plans and programs to accelerate the development, utilization and commercialization of
renewable energy resources and technologies; develop and maintain a database; conduct
technical and impact studies; information, education and communication services.
Creation of the National Renewable Energy Board (NREB), assisted by a technical
secretariat from the REMB. The NREB is primarily tasked to recommend policies to
DOE and monitor the implementation of the Renewable Energy Act.
Renewable Energy Trust Fund to enhance the development and greater utilization of
renewable energy.
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Source: RA 9367 (2006) and implementing rules and regulations (IRR); RA 9513 (2008) and IRR.
The DOE and its bureaus are not the only government agencies that are working towards the
implementation of the RE laws. Other agencies are also involved, such as in terms of technical
and procedural (e.g. certification/accreditation) activities. The following lists down key
agencies based on the RE law provisions and IRR.
For the Biodiesel Act:
Department of Finance (DOF) – monitor production and importation of biofuels through
Bureau of Internal Revenue (BIR) and Bureau of Customs (BOC).
Department of Science and Technology (DOST) – coordinate with DFA in identifying and
developing viable feedstock for the production of biofuels; develop research and
development program for sustainable biofuel production and utilization.
Department of Agriculture (DA) – develop a national program for the production of crops
for use as feedstock supply, that would also guarantee sufficient and reliable supply of
feedstock are allocated for biofuel production; undertake biofuel feedstock research and
development; coordinate with Philippine Coconut Authority (PCA) and Sugar Regulatory
Administration (SRA) to identify and publish potential areas for expansion and production
of raw materials as feedstock, and other policies in support of the biofuels program; certifies
whether the proposed feedstock may be utilized for biofuel feedstock production.
Department of Agrarian Reform (DAR) – approves conversion of agricultural lands to
biofuel production site.
Department of Labor and Employment (DOLE) – recommend policies and programs that
will enhance social impact of the National Biofuels Program, including promotion of
gainful livelihood and employment opportunities and social protection coverage.
Department of Trade and Industry (DTI) – promote development of alternative fuel
technology for vehicles, engines and parts in correspondence with the requirements of the
mandated minimum biofuel blends; in coordination with Department of Transportation and
Communication (DOTC) and DENR, formulate and implement a national motor vehicle
inspection and maintenance program as a measure to reduce emissions from motor vehicles
pursuant to the Philippine Clean Air Act of 1999.
Department of Environment and Natural Resources (DENR) – issues Environment
Compliance Certificate (ECC).
National Commission for Indigenous Peoples (NCIP) – issues Certificate of Precondition
(Certificate of Non-Overlap for sites outside ancestral domain; Certificate of Compliance
if area is within/overlaps with ancestral domain).
Philippine Coconut Authority (PCA) – develop and implement policies and programs
within the coconut industry in support of the National Biofuels Program, such as: formulate
and implement necessary regulatory measures to ensure availability, sufficiency, quality
and sustainability of supply of coconut raw materials for the National Biofuels Program,
require the accreditation/registration of reputable and credible oil mills that will supply
coconut oil (CNO) requirements of coco biodiesel products.
Tariff Commission – create and classify a tariff line for biofuels and biofuel-blends in
consideration of WTO and AFTA agreements.
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For the Renewable Energy Act:
Board of Investments (BOI) – register RE developers, manufacturers, fabricators and
suppliers of locally produced RE equipment to qualify for availment of fiscal incentives.
Department of Environment and Natural Resources (DENR) – member of the National
Renewable Energy Board (NREB); issues Environment Compliance Certificate (ECC),
Forest Land Use Agreement (FLAg)/Special Land Use Agreement (SLUP)for area in
public domain.
Department of Finance (DOF)/Bureau of Customs, Bureau of Internal Revenue – formulate
guidelines/mechanisms to implement fiscal-related provisions such as: exemption from
duties on RE machinery, equipment and materials; zero percent VAT; tax rebate for
purchase of RE components in consultation with Department of Science and Technology
(DOST), Department of Trade and Industry (DTI), DOE; member of the National
Renewable Energy Board (NREB).
Department of Trade and Industry (DTI) – member of the National Renewable Energy
Board (NREB);
Department of Agrarian Reform (DAR) – approves conversion of agricultural lands to
industrial sites.
Energy Regulatory Commission (ERC) – formulates the FiT system rules
National Commission for Indigenous Peoples (NCIP) – issues Certificate of Non-Overlap
for sites outside ancestral domain; Free and Prior Informed Consent/Certificate of
Precondition if area is within/overlaps with ancestral domain.
National Transmission Corporation (TRANSCO) – provide necessary mechanisms for
physical connection and ensuring safety and reliability of electricity transmission; member
of the National Renewable Energy Board (NREB).
Others: Maritime Industry Authority (MARINA), Bureau of Fisheries and Aquatic
Resources (BFAR), Philippine Navy, Philippine Coast Guard, etc. – for necessary
clearances.
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3.2 Renewable energy sources
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Data in recent years indicate that total RE sources make up over a third of the Philippine’s
primary energy supply, i.e., sources of energy for electricity, transport, etc. (Figure 2).
Renewable sources reached almost 40 percent of total primary energy supply in 2010 and 2014.
This level of utilization of RE sources may imply that the Philippines is taking advantage of
the indigenous resources available that can be tapped to help meet the country’s energy needs.
Under renewables, geothermal energy remains to be the major source of renewable energy in
the Philippines, and close to coal as second largest source among all energy sources (oil-based
technology ranks top energy source). The high generation of energy from geothermal sources
makes the Philippines the second largest producer of geothermal energy globally (DLA Piper,
2014). Meanwhile, biomass and hydropower comes in as second and third largest renewable
primary energy source.
For electricity generation, latest data indicate that the RE sources combined produces about a
third of the Philippines’ electricity supply (33.9% installed capacity, 32.4% dependable
capacity). Among all sources, coal-fired generation is the largest source of electricity,
producing 34.2 percent in dependable capacity (Table 2, Figures 3 and 4).
On a per technology basis, hydropower produces the most electricity among the renewable
energy sector at 19.3 percent in installed capacity and 18.7 percent in dependable capacity;
followed by geothermal power at 10.3 percent in installed capacity and 9.7 percent in
dependable capacity. Among all sources, hydropower comes second to coal in electricity
generation.
Capacity (MW)
Fuel Type
Installed Dependable
Coal 5,893 5,632
Oil Based 3,610 2,734
Natural Gas 2,862 2,759
Geothermal 1,917 1,601
Hydro 3,600 3,073
Wind 427 379
Solar 165 125
Biomass 221 146
TOTAL 18,695 16,451
Note: As of December 2015; total no. of plants = 155;
excluding off- grid electrification
Source: Department of Energy
15
Figure 3: Electricity generation by source, Installed capacity (in percent)
16
In power generation, the government has set installation targets and milestones for the
country’s National Renewable Energy Program (NREP). Milestones were set for specific RE
technologies for specific years (Figure 5). The NREP’s overall goal is to increase RE-based
capacity for power generation to 15,304 MW by 2030 (almost triple of the 2010 capacity level
of 5,438 MW), by institutionalizing a comprehensive approach to address the challenges and
gaps that would prevent and/or delay wider application of RE technologies in a sustainable
manner, and outlining the action plans necessary to facilitate and encourage greater private
sector investments in RE development.
On an per technology basis, the goals targeted to be achieved by 2030 include: increase
geothermal capacity by 75 percent; increase hydropower capacity by 160 percent; deliver
additional 277MW biomass power capacities; attain wind power grid parity with the
commissioning of 2,345 MW additional capacities; mainstream an additional 284 MW solar
power capacities and pursue the achievement of the 1,528 MW aspirational target; develop the
first ocean energy facility for the country.
The government also set RE-based capacity installation targets, with details on target capacity
additions per RE technology for every five years starting from 2011 leading to the total aimed
capacity of 15,304 MW by 2030 (Table 3).
Source: Adopted from National Renewable Energy Program (NREP), Figure 3, page 26.
Note: The NREP is a live document and will be subject to public consultation. Figures presented may
change based on regular updates of the NREP.
17
Table 3: RE-based capacity installation targets
Installed Target Capacity Addition by: Total
Capacity, Total Capacity Installed
(MW) as of Addition (MW) Capacity
Sector 2010 2015 2020 2025 2030 2011-2030 by 2030
Geothermal 1,966.0 220.0 1,100.0 95.0 80.0 1,495.0 3,461.0
Hydro 3,400.0 341.3 3,161.0 1,891.8 0.0 5,394.1 8,724.1
Biomass 39.0 276.7 0.0 0.0 0.0 276.7 315.7
Wind 33.0 1,048.0 855.0 442.0 0.0 2,345.0 2,378.0
Solar 1.0 269.0 5.0 5.0 5.0 284.0 */ 285.0
Ocean 0.0 0.0 35.5 35.0 0.0 70.5 70.5
Total 5,438.0 2,155.0 5,156.5 2,468.8 85.0 9,865.3 15,304.3
Notes:
Figures may differ with those in tables by location due to rounding off
*/Based on existing RE Service/Operating Contracts awarded and being evaluated by the DOE. The
aspirational target of 1,528 MW solar power capacity will still be pursued.
Source: Renewable Energy Plans and Programs 2011-2030, DOE publication
Data suggest that actual installed capacities per RE technology (as of December 2015) did not
meet the targeted capacities for 2015, but the figures are rather close except for wind (Table
4). Looking at the awarded RE projects as of March 2016 (Table 5), it appears that there is high
potential capacity from 51 wind projects at 1,168.0 MW. Once the wind projects become
operational, installed capacity at such level is expected. For the RE sector as a whole, the
potential capacity of 13,574.7MW as of March 2016 (based on 682 awarded projects) is
approaching the 15,304.3MW targeted installed capacity by 2030, implying that the
government would have to ensure the timely launch of the projects to achieve the targets.
18
Table 5: Summary of awarded renewable energy projects
Biofuels in the Philippines refer to bioethanol and biodiesel. Bioethanol is derived from
sugarcane, cassava, and sweet potato and blended with gasoline; while biodiesel is derived
from coconut oil and is blended with petrodiesel. The biofuels sector is composed of 21
companies with 21 projects and registered annual capacity of 867.02 million liters, as of March
2016 (Table 6).
Actual production of biofuels sector has been increasing from 2012 to 2015 (Figures 6 and 7),
but the sector does not appear to be producing at the expected level of capacity. Biodiesel
production increased at an average annual of rate of 14 percent during this period. On the other
hand, bioethanol production increased at an average annual rate of 70 percent. However as of
2015, biodiesel produced was only 35 percent of registered annual capacity of the sector, while
bioethanol produced was 59 percent of registered annual capacity of the sector.
Registered
No. of No. of annual capacity
Resources
Companies Projects (million liters)
Bioethanol 10 10 282.12
Biodiesel 11 11 584.90
Total 21 21 867.02
Source: Department of Energy
Note: As of March 31, 2016
19
Figure 6: Biodiesel local production (in million liters)
20
Conforming to the Biofuels Act provisions, the Philippine Energy Plan (PEP) 2012-2030
released biodiesel and bioethanol measurable targets from 2012 to 2030 (Tables 7 and 8). Based
on these targets in the PEP, the biodiesel blend is at 5 percent by volume (B5) by 2015.
However, the target blend remains at 2.0 percent (B2) by volume, and increasing it to 5 percent
is being reviewed. While, bioethanol target is at 10.0 percent (E10) by volume blended into all
gasoline fuel sold and distributed nationwide.
Data suggests that actual biodiesel production was rather far from the 2015 supply requirement
to achieve the targeted blends. Though the local biodiesel production in 2012 achieved the
targeted B2 blend, the production in 2015 covered only 3 percent of the supply requirement
(Table 9). There was, however, a moratorium on the B5 blend; hence the prevailing blend is
still at 2 percent. A study by Alonzo (2016) indicated that increasing the blend from 2 percent
to 5 percent would lead to an increase in biodiesel price, hence will incur loss for consumers.
21
In addition, the upward world price trends in coconut oil and crude oil prices and weak
domestic coconut production show signs for postponement of increasing the target blend at
least in the short run, according to the author.
For bioethanol, actual local production is relatively far from the supply requirement based on
the mandated blend of 10 percent in 2012 and 2015 (Table 10). In 2012, local production was
only 0.9 percent of the supply requirement; while in 2015, production increased but covered
only 4.4 percent of the supply requirement.
Supply
Requirement/ Actual
Fuel Local
Gasoline Bioethanol Displacement Production
Demand (in Blends (in million (in million
Year million liters) (Targets) liters) liters)
2012 3730.67 10% 373.07 35.09
2015 3794.72 10% 379.47 167.39
2020 4301.8 20% 860.36 -
2025 4682.81 20% 936.56 -
2030 5052.26 20% 1010.45 -
Note: Total supply requirement of bioethanol is equal to total gasoline to be displaced.
Source of data: PEP 2012-2030; Department of Energy.
22
4. Global trends in RE development and use
Statistics indicate that world RE supply has grown from 1990 to 2014, with an average annual
rate of 2.2 percent (IEA, 2016). The highest average annual growth rates were recorded in solar
PV (46.2%) and wind power (24.3%), and relatively modest growth in geothermal and
hydropower (3.1% and 2.5%, respectively).
In 2014, RE sources contributed 13.8 percent of the world’s total primary energy supply
(TPES), a significant portion of which was produced from biofuels and waste (Figure 8-a).
Solid biofuels/charcoal were largely used in developing countries for residential heating and
cooking, making up 66.2 percent of world RE supply (Figure 8-b). Moreover, among RE
sources, hydropower came in second, providing 2.4 percent of TPES and 17.7 percent of RE
supply. Meanwhile, liquid biofuels and geothermal power produced smaller shares in world
RE supply with less than 5 percent.
Figure 8: Fuel shares in world total primary energy supply, and product shares in
world RE supply, 2014
(a) World total primary energy supply (TPES) (b) World RE supply
Notes: 1/ Other includes electricity from energy sources not defined above such as non-renewable wastes,
peat, oil shale and chemical heat; 2/ Other renewables includes geothermal, wind, solar, tide;
Total in graphs might not add up due to rounding.
Source: International Energy Agency (IEA), Key Renewables Trends 2016, Figures 1-2, page 3.
In terms of electricity generating capacity, the RE sector achieved its largest annual increase
so far in 2015 (REN21, 2016). Total global capacity increased by almost 9 percent from 2014
(estimated 147 GW of RE capacity added). Wind and solar PV recorded their highest capacity
additions in 2015, comprising about 77 percent of new RE installations; while hydropower
contributed about 19 percent of additions. The REN21 (2016) report also claimed that ‘the
world now adds more renewable power capacity annually than it adds (net) capacity from all
fossil fuels combined’, with an estimated more than 60 percent of net additions to global power
generating capacity.
23
By the end of 2015, the global RE capacity was sufficient to supply an estimated 23.7 percent
of global electricity, with hydropower providing about 16.6 percent and the rest of the
renewables combined providing 7.3 percent (Figure 9). In end-2014, the share of RE-produced
electricity was 22.8 percent (REN21, 2015), suggesting an improvement in RE contribution
within a year.
Source: REN21, Renewables 2016 Global Status Report, Figure 3, page 32.
On a regional level, Asia contributed most of the renewable power installations in 2015
(REN21, 2016). China, Japan and India were top countries for solar PV installations. Moreover,
China and India were among the top countries for hydro and wind power capacity additions,
with China leading the region and the world for hydropower. As for the level of geothermal
capacity, Philippines continues to rank second to the US; while Indonesia ranked third in 2015.
In Asia in general, countries have become important markets for more than one RE technology.
Share of electricity production from renewables in the region in 2003-2013, particularly for
ASEAN, has been generally steady, averaging 15 percent annually (Figure 10). ASEAN
average during this period was around 4 percentage points lower than the world average. Its
Asian neighbors on the other hand, i.e. China, Korea, Japan and India, showed an increasing
trend in share of RE electricity production.
Among Asian countries, Viet Nam and the Philippines had the two highest shares of renewables
in electricity production in 2003-2013, with annual average of 36.8 percent and 31.5 percent
respectively. While Viet Nam’s share is increasing across the years, the Philippines’ share is
decreasing, though still higher than other countries in the region. South Korea and Singapore
posted the lowest shares (annual average of 1.8% and 2.6% respectively), but showed an
increasing trend in recent years.
24
Figure 10: Share of renewables in electricity production, 2003-2013 (in percent)
In the area of policymaking, there has been a surge in RE support policies in the last decade in
response to energy related challenges such as climate change, air pollution, volatile fossil fuel
prices and growing demand for electricity from industry (UNEP, 2012). As of 2015, REN21
(2016) reports that at least 173 countries had RE targets and an estimated 146 countries had
RE support policies at the national or state/provincial level. Feed-in policy is the most
commonly implemented regulatory mechanism to promote RE with 110
countries/states/provinces adopting this policy in 2015. RPS/quota policies follow second with
100 countries implementing. In the same year, 52 countries were found to adopt net
metering/net billing policies, and 66 countries had enacted biofuel mandates. Fiscal policies,
on the other hand, continue to be an important mechanism in promoting RE deployment and
development in many countries. Among the RE policies, tendering3 (also called auction or
public competitive bidding) is currently gaining popularity in developing and emerging
countries, as well as in Europe. At the end of 2015, at least 64 countries have adopted tendering
schemes and record bids in terms of low price and high volume have been observed.
Countries use a combination of the policies mentioned above in developing their RE sector,
with some of them implementing more than one regulatory policy and fiscal incentive. Table
11 presents selected countries and their policies in support of RE. Among the regulatory
policies, FiT is most commonly adopted, followed by tendering and RPS/quota scheme. The
popularity of FiT schemes is being attributed to their success in promoting RE generation,
particularly in Europe (UNEP, 2012). Public investment/loans/grants are also common among
3
Tendering is a procurement mechanism by which renewable energy supply or capacity is competitively
solicited from sellers, who offer bids at the lowest price that they would be willing to accept. Bids may be
evaluated on both price and non-price factors (REN21, 2016).
25
the selection of countries. Public investments support RE development when they finance RE
projects that are risky and not financially viable for private investors and where markets are
not yet capable of delivering appropriate technical systems for projects, such as grid
infrastructure (GIZ, 2012). Moreover, among financial incentives, reduction in taxes and
capital subsidies/grants/rebates are most common.
Compared with the selection of developed and developing countries (Table 11), the Philippines
(aside from India) appears to be the most ‘generous’ in policymaking for RE, as illustrated by
the number of policies it adopted, i.e. all the policies presented in the list. In the Asian region
alone, countries have at most three (3) regulatory RE policies in place, while the Philippines
offers five of the five policies in the list. It appears, however, that the government may be
having some difficulty with execution, as not all of the policies have been implemented – e.g.
IRRs for RPS and tradable green certificates are yet to be released.
competitive bidding
Energy Certificates
Energy production
Standard/Quota
or other taxes)
Feed-in Tariff
Net metering
tax credits
or grants
payment
Rebates
Brazil
Chile
United States
United Kingdom
Germany
Italy
China
Japan
South Korea
India
Indonesia
Malaysia
Philippines
Singapore
Thailand
Viet Nam
Source: Adapted from (GIZ, 2012) and (REN21, 2016).
26
5. Implementation of policies and emerging issues
The RE laws in the Philippines offer incentives and other policies to encourage investments in
RE projects and reach its targets for RE deployment. The government issued implementing
rules and regulations (IRRs) to support these policies. However, while the government is taking
steps to ensure that the sector is moving towards its goals, there have been issues raised
regarding the government’s decision to promote RE and its implementation of the RE laws.
Reduction of cost-related barriers. Like other countries, the Philippines offers financial
incentives, e.g. tax holidays and duty free importation of machinery, to attract RE investment
and development. It is one means of reducing cost-related barriers to entry in the market. RE
technologies are generally capital intensive – developing an RE project and setting up the plant
and the whole RE system requires large fixed costs.
A public advocacy organization in the Philippines, the Foundation for Economic Freedom
(FEF), was apprehensive about the government’s promotion especially of the expensive RE
technologies when the RE law was enacted. The said organization suggested that it would be
better to rehabilitate and improve existing hydroelectric and geothermal sources, and wait until
the cost of the more prominent but more expensive technologies such as solar and wind drops
in comparison with conventional energy sources (Fajardo F. , 2011).
Data indicate that costs related to RE development have reduced in the last five years. This
trend is attributed to advances in technology, expansion into new markets with better resources,
improvements in financing conditions, and secure regulatory framework (REN21, 2016). Solar
PV and wind technologies, in particular, experienced decline in costs. For solar PV
technologies, annual capital costs estimated by different organizations indicated a decline in
trend from 2010 to 2015 (Figure 11). For wind technologies, the estimated annual capital costs
indicated an increasing trend from 2005 to 2009/2010, and subsequently, a slow declining trend
towards 2015 (Figure 12). REN21 (2016) reported that in 2015, some of the countries in Latin
America, North Africa, US and Asia Pacific found wind power to be the most cost-effective
option for new grid-based power. In addition, record-low winning bids in solar PV and wind
power auctions in India and some countries in Latin America and Middle East were also
observed.
27
Figure 11: Annual estimated capital costs for solar PV technologies
from various agencies, 2005-2015 (in 2014$ per kilowatt)
Note: EIA, Annual Energy Outlook (2003-2015); LBNL, Tracking the Sun 2014;
LBNL, Utility-Scale Solar (2013-2014); Black & Veatch (B&V), Cost and
Performance Data for Power Generation Technologies; NREL, Annual
Technology Baseline 2014; Lazard, Levelized Cost of Energy (version 3-8).
Source: Adapted from US Energy Information Administration, 2016
Note: EIA, Annual Energy Outlook (2003-2015); LBNL, Tracking the Sun 2014;
LBNL, Utility-Scale Solar (2013-2014); Black & Veatch (B&V), Cost and
Performance Data for Power Generation Technologies; NREL, Annual
Technology Baseline 2014; Lazard, Levelized Cost of Energy (version 3-8).
Source: Adapted from US Energy Information Administration, 2016
Hydro, geothermal, and some biomass power sources have also been observed to be
competitive with fossil fuels (REN21, 2016). This can be seen when comparing US average
levelized costs of electricity (LCOE)4 across different RE technologies (Figures 13 and 14).
4
Levelized cost of electricity (LCOE) is often cited as a convenient summary measure of the overall
competiveness of different generating technologies. It represents the per-kilowatt-hour cost (in real dollars) of
28
The data also indicate that solar PV and wind LCOE are also becoming comparable with
conventional energy resources. This supports the report by REN21 (2016) stating that solar PV
and wind can be cost-competitive with new fossil capacities (even if externalities are
unaccounted for), but with good resources and sound regulatory framework.
Across years, comparing particularly 2010 and 2013 (Figures 13 and 14), there have been cost
improvements in RE technologies. Data indicate that their LCOE in 2013 USD/MWh was
lower than the value in 2010 USD/MWh, with the substantial drop coming from geothermal,
solar PV and wind offshore.5 It is important to note, however, that a number of factors such as
regulatory framework and market design are crucial in attaining cost competitiveness of RE
technologies (REN21, 2016).
building and operating a generating plant over an assumed financial life and duty cycle. Key inputs to calculating
LCOE include capital costs, fuel costs, fixed and variable operations and maintenance (O&M) costs, financing
costs, and an assumed utilization rate for each plant type (U.S. Energy Information Administration, Annual
Energy Outlook 2015).
5
Wind offshore refers to wind farms constructed off the coast or continental shelf.
29
Figure 14: US average levelized costs of electricity by technology, 2013 USD/MWh
6
Based on interviews with wind, solar, run-of-river hydro and geothermal project developers.
30
Figure 15: Summary of stages of RE project development
At the first stage, project preparation, the RE developer determines a suitable location for an RE project.
Collection of data and information, desk studies, site surveys conducted by the developer. At this stage, the
developer must apply for a RE service contract (RESC)8 at the DOE to be able to acquire exclusive rights to
explore and perform a feasibility study on the identified location of the RE project.
The pre-development stage (Phase 2) involves preliminary assessment and feasibility study until the financial
closing of the RE project. The RESC is used in this stage and is valid for a maximum of 2 years. This stage
also involves securing of permits and licenses from different agencies/authorities. The following are
examples of the key requirements:9
7
This section draws heavily from Fajardo, et.al. (2014). A thorough discussion of the different phases in RE
project development can be found in the said report.
8
The RE service contract (RESC) is a service agreement between the Philippine Government through the DOE
and RE developer, allowing exploration, development or utilization of renewable energy resources and actual
operation of RE systems/facilities converting RE resources into useful energy forms, e.g., electricity.
9
Fajardo, et.al. (2014) and GIZ (2014) offer guide on other requirements.
31
---Certificate from the National Commission in Indigenous People (NCIP) is required to ensure that the
interests of indigenous people (IP) are protected. There are two types of certificates issued by the NCIP to
an RE developer: Certificate of Non-overlap (attests that the location of the RE project does not overlap with
or affect ant ancestral domain) and the Certification Precondition (attests to the grant of Free and Prior
Informed Consent (FPIC) by the concerned IP community). RE developers must secure the certificate that
is applicable to the circumstances of their project.
---Order of Conversion from DAR must be obtained if the project site is not classified as industrial land; and
depending on the location, additional clearance may be required by agencies such as the Forest Management
Bureau (FMB) and the Laguna Lake Development Authority (LLDA).
---Environmental Certificate from the DENR to confirm that the project will not cause negative
environmental impact to the extent considered as unacceptable. Certificate required differ depending on
project size: Certificate of Non-coverage (CNC) for projects smaller than 5 MW; Environmental Compliance
Certificate (ECC) with initial environmental checklist for 5-100 MW projects; ECC with an Environmental
Impact Statement (EIS) for projects with installed capacity above 100MW.
---Permit to Operate from the DENR to confirm that the power plant does not emit air pollution above the
set limit (as per the Philippine Clean Air Act of 1999 / Republic Act 8749).
---Resolution of support from the host LGU (municipality/city) to ensure acceptance by the community
(resolution from the host barangay is obtained first); some RE developers, though not required, also obtain
resolution of support from the province to ensure support from this level.
In addition, the RE developer should have secured and mobilized financial support. A financial closure
should be reached in order to begin physical construction and equipment procurement. Once financial closure
is reached, the RE developer can apply for the Confirmation of Commerciality (COC) from the DOE. The
COC indicates that a project has successfully completed the pre-development stage. It converts the RESC to
the development stage. Moreover, the RE developer should also approach power utilities to obtain the
licenses and agreement needed to connect and use their networks (do the initial steps for the Grid Connection
Permit [GCP]; obtain necessary documents from TRANSCO).
The fourth stage, registration and connection, still requires some permits and certifications, before
commercial operations of the power plant may begin. If an RE project will avail of the FiT, a certificate of
FiT endorsement (COE) should be obtained from the DOE. If under a power supply arrangement, the RE
project should get approval from the ERC (power purchase agreement). And with a CoC issued, the RE
project/power plant is allowed to generate electricity (Electricity Production License).
32
A number of factors can lead to lengthy permitting process. The cases below are based on
experience of RE developers (wind, solar, hydro, geothermal, biomass):10
Numerous permits and signatures required
Box 1 enumerated key permitting requirements, but there are other documents/permits such
as those related to business registration, those required by local governments, e.g. building
and wiring, and those required before applying for other permits or certifications (pre-
requisites). One company shared that it applied for 66 permits for a geothermal project,
around 70 permits for a wind project.
Permits require signatures from concerned government officials – it could be from the
barangay, municipal/city, provincial, regional, department (central office) level, depending
on the requirement. A solar and biomass company estimated that overall permitting may have
required around 500 signatures. A hydropower company claimed that one project took around
1,300 signatures before they could begin construction – this includes signatures from the IP
communities. It was also noted that some signatures would require other persons to affix their
initials.
Numerous permits and signatures can already lengthen the permitting process, according to
the companies interviewed. It can be further prolonged by cases with pre-requisite permits
wherein delay in one permit would cascade to other permits and would cause delay in the
overall project. Affixing initials of additional personnel also lengthens the process further.
Connected to this case is the bureaucratic manner that documents are signed by, for instance,
the Department Secretary. The documents would pass through different bureaus/divisions
before it reaches the Secretary for signature, including when the said head of agency has
inquiries or clarifications. The companies interviewed are on in suggesting that streamlining
of the system, including reduction of signatures and bureaucratic procedures, can help speed
up the process.
Varying interpretation of rules
One of the problems identified by interviewed RE companies is the varying interpretations
of the implementing rules and regulations – among offices (local, regional) of the same line
agencies, and also across different agencies. They said that interpretation of the rules can be
very subjective, dependent on the interpretation of the regional heads/officers. One RE
company shared that the permitting process at the NCIP, for instance, in the northern regions
differs from the process practiced in the southern regions.
Under this circumstance, there is uncertainty as to whether different interpretations will be
given which will then require re-filing of documents, thereby cause delay in the process (one
company experienced around 2 days of delay). One RE company added that the changes or
rotations of directors and officers in the middle of the permitting process increases the
probability of receiving different interpretations of the rules.
Change of guidelines/policies upon assumption of new head/officer
The RE companies interviewed also shared that there is tendency for the permitting
guidelines to change, especially when a new administration/head assumes office (national,
10
Four RE companies were interviewed.
33
department or local levels). Developers have experienced being confronted with changes in
policy in the middle of complying with requirements. One company related this experience
while applying for water permit.
Another company recounted a case wherein new applications were stopped during transition
to a new agency head and new guidelines were released after 6 months of taking office. The
new guidelines entailed new requirements, hence lengthening the permitting process.
One guideline raised was the permitting process in projects located in ancestral domain. The
past guidelines stated that an RE project developer should secure permission from the
barangays where the project is located, e.g. if the project is located in two barangays,
coordination will be done with these two barangay. In the new guidelines, securing of
permission depends on the ancestral domain title. If the ancestral domain includes barangays
other than the location of the RE project, the developer should also coordinate with them. In
this case, instead of coordinating with just the barangays affected by the RE project, the
developer will have to talk to all the barangays covered by the ancestral domain title.
‘First come, first served’ policy
To be eligible for the FiT scheme, one of the steps is to secure the certificate of endorsement
(COE) for FiT eligibility. However, only a limited number of RE developers can be issued
with COE (Fajardo, et.al, 2014). The government sets installation targets per RE technology,
and COEs will only be issued until the target is fully subscribed.11
The COE is issued on a first-come-first-serve basis. When the installation target is fully
subscribed, RE developers can no longer apply for a COE, hence they cannot be eligible to
avail of the FiT scheme (after issuance of the COE, the ERC gives the final approval for FIT
enrolment).
The issue for RE companies is that the key requirement for COE puts them under high risk.
The guidelines indicate that COE can be obtained only after the construction of the power
plant reaches 80 percent and the plant has confirmed 100 percent electromechanical
completion. In such case, there is no guarantee that a developer will be eligible to avail of the
FiT rate even if the RE facility has already been constructed. Developers compete with each
other in qualifying for the COE until the installation target is reached. The guidelines also
indicate alternative options for developers to sell their electricity should the installation
targets already be reached: enter into a bilateral agreement with a distribution utility (DU) or
any off-taker; export the power generated directly to the WESM, subject to the FiT guidelines
on ‘must dispatch’. But while there are alternative schemes, FiT would be the better incentive
as of the moment because this scheme guarantees payment for generated power at price set
by the government.
This policy may have been implemented to get rid of speculators and invite only the ‘serious’
developers who will be able to construct and operate RE projects. But, according to one RE
company, the policy poses a barrier especially to the relatively small companies with genuine
interest to develop RE projects but are concerned about the uncertainty of FiT eligibility even
after construction of power plants. The suggestion given by RE companies interviewed is to
11
Installation target: Run-of-hydro – 250MW; Biomass – 250MW; Solar – 500MW (from 50MW before April
2014); Wind – 400MW (from 200MW); Ocean – 10MW.
34
have clear and strictly implemented requirements, and have FiT eligibility determined before
the development stage and not after completion of power plant construction (electro-
mechanical completion).
The fourth stage in RE project development (as shown in Figure 15), particularly grid
connection, is also a lengthy process, based on the experience of one RE company. It will take
about 15 to 17 months from the application for (including waiting/processing time) and actual
conduct of a Grid Impact Study, conduct of a facility study, up to the application for grid
connection to the ERC.
12
Renewable Energy Act of 2008 (RA 9513).
13
Rules Enabling the Net Metering Program for Renewable Energy, Energy Regulatory Commission, 2013.
14
http://www.adb.org/news/adb-opens-hq-solar-power-project-setting-clean-energy-example.
15
Iris C. Gonzales, Feb 21, 2015philstar.com.
35
4 million in heat insulation, and ensure uninterruptible power supply for its services.16 Like the
ADB, utilization of the RE technology also meant less carbon footprint.
Manila Electric Co. (Meralco) reported that the net metering program is growingly attracting
participants. As of May 2016, it has 392 participating customers, from having its first customer
in 2013.17 Meralco suggests that factors such as the price of electricity and the declining cost
of solar PV systems may have prompted more customers to install RE systems and avail of the
net metering program.
16
Lenie Lectura, February 22, 2015. UA&P installs solar-power facility. www.businessmirror.com.ph.
17
Rooftop installations by its customers have an average capacity of four (4) kW. Danessa Rivera, June 25,
2016. More Meralco customers shift to net metering.
http://www.philstar.com/business/2016/06/25/1596294/more-meralco-customers-shift-net-metering.
36
JPY/kWh 25.92 to 36.72 23.76 to 59.4 30 to 37 14.04 to 42.12
USD/kWH 0.25 to 0.36 0.23 to 0.58 0.29 to 0.36 0.14 to 0.41
Malaysia
MYR/kWh 0.00 Yet to be introduced 0.00 to 3.46 4.05
USD/kWH 0.00 Yet to be introduced 0.00 to 1.09 1.27
Mongolia
MNT/kWh 64.69 to 143.75 115 to 215.63 215.63 to 431.25 Yet to be introduced
USD/kWH 0.03 to 0.08 0.06 to 0.11 0.11 to 0.23 Yet to be introduced
Philippines
PHP/kWh 5.9 8.53 9.68 6.63
USD/kWH 0.14 0.20 0.22 0.15
Thailand
THB/kWh 0.8 to 1.5 3.5 to 4.5 6.5 0.3 to 0.5
USD/kWH 0.03 to 0.05 0.11 to 0.14 0.20 0.01 to 0.02
Viet Nam
VND/kWh Yet to be introduced 1, 614 Yet to be introduced Yet to be introduced
USD/kWH Yet to be introduced 0.08 Yet to be introduced Yet to be introduced
Implementation of this policy implies two scenarios: (1) As price takers, RE resources may
displace expensive conventional energy resources, which may possibly result in lower
electricity prices, especially during peak period, and also assuming that there are no changes
in the behavior of trading participants. (2) During off-peak hours, electricity may increase due
to the thinning of demand for which the generators would compete. With a thin market for
competition, there could be temptation to exercise market power via collusion.
The two scenarios above refer to the merit order effect, which according to a PEMC study, can
affect the energy costs of end-users. The PEMC study (De La Vina, 2015) simulated and
compares energy costs under scenarios with and without intermittent RE resource in the grid
(particularly, comparing cost of energy purchased from the WESM with or without the FiT-
eligible generating plants). In their study, the difference between these costs corresponds to an
estimate of the financial impact to the end-user. For instance, if the cost of energy purchased
from the WESM is lower with the FiT-eligible generating plants than without them, then the
18
DOE Department Circular No. 2015-03-0001, “Promulgating the framework for the Implementation of Must
Dispatch and Priority Dispatch of RE Resources in the Whole Electricity Spot Market (WESM)”.
37
difference in costs is considered as the benefit of the integration of the RE resources to the grid
(and vice versa). One of the methodologies in the study is the simulation/analysis of WESM
payments of end-users from November2014 to October 2015) under two scenarios: (1) 337
MW wind capacity and (2) combined 337 MW wind and 500 solar capacities are available.
Results of the analysis indicate that in Luzon, the large private distribution utility would be
paying 4.9 centavos per kWh less than it what it would have paid if there was no scenario 1,
and 9.5 centavos per kWh less than what it would have paid if there was no scenario 2. For the
rest of Luzon and Visayas, WESM payments would be 12.5 centavos per kWh less than would
have been paid without scenario 1, and 24.7 centavos per kWh less than would have paid
without scenario 2. As for Mindano, no impact from the merit effect is identified as WESM is
not implemented in the region.19
In sum, the PEMC study findings (which refer to the period of November 2014 to October
2015) indicate that integrating FiT-eligible generating plants (wind and solar technologies were
used in the analysis) resulted in lower overall energy costs; in particular, a reduction in average
rate in the WESM (at 11.65 centavos per kWh or P8.29 billion), thereby translating to an
avoided cost by consumers (5.67 centavos per kWh or P4.04 billion).20
19
End-user impact depends on spot exposure of the end users.
20
Lenie Lectura, RE plants kept power rates steady at WESM, PEMC says, January 19, 2016,
www.businessmirror.com.ph.
21
Renewable Energy Act of 2008 (RA 9513) implementing rules and regulations (IRR). DOE Department Circular
No. DC2009-05-0008. May 25, 2009.
22
Renewable Energy Act of 2008 (RA 9513) implementing rules and regulations (IRR). DOE Department Circular
No. DC2009-05-0008. May 25, 2009.
38
The RE law’s IRR states that the RPS rules should be formulated and disseminated within six
months of its (IRR) effectivity. The IRR took effect sometime in June 2014. Two years later,
in June 2016, the draft RPS rules and guidelines was issued by the DOE.23
The IRR of the Renewable Energy Act defines Renewable Energy Market (REM) as the market
(to be set up as a sub-market of the WESM) where the trading of the RE certificates equivalent
to an amount of power generated from RE resources is made; essentially, to expedite
compliance with the establishment of the RPS. The REM will be established by the DOE. The
PEMC, under the supervision of the DOE, will establish and operate the RE Registrar and will
issue, keep and verify RE Certificates corresponding to energy generated from the eligible RE
facilities. These RE certificates will be credited in compliance with any obligation under the
RPS.
5.5.3 Incentives that have not yet been implemented
The renewable energy laws offer fiscal incentives such as income tax holiday, special corporate
tax, duty free importation of machinery, equipment and materials, zero percent VAT and
others. An RE company interviewed shared that they benefit from these incentives. These
schemes can attract investors to shift to renewable energy technology. However, it was
suggested that the government improve on the implementation, particularly, on the zero VAT.
Though it is clear which energy projects can avail of the incentive, the concerned implementing
agencies has not yet issued rules and guidelines, hence, RE companies faced delay in VAT
recovery.
23
Danessa Rivera, DOE issues draft rules on RPS, June 24, 2016,
http://www.philstar.com/business/2016/06/24/1595976/doe-issues-draft-rules-rps.
24
Renewable Energy Act of 2008 (RA 9513) implementing rules and regulations (IRR). DOE Department Circular
No. DC2009-05-0008. May 25, 2009.
39
recent infestations in coconut producing areas were some of the reasons cited as causes of
declining production and productivity of feedstock supply for the production of biofuels.
An UNCTAD study also found that bioethanol producers have been importing ethanol, mostly
from Thailand25 to comply with the mandated 10 percent ethanol blend requirement (E10),
which then implies that the Philippines would likely remain a net importer of fuel. Moreover,
in biodiesel, the target of 5 percent blend had to be assessed as biofuel suppliers are unable to
meet the required demand, as of 2014.
Both sides of the debate on Renewable Energy deployment have their justifications for
supporting or not supporting the use of RE resources. Those that endorse RE technologies
speak of how RE resources are replenishable and have minimum impact on the environment.
Externalities, unlike conventional energy sources, are minimized as there is no fossil fuel used
to produce energy. In relation to this, use of RE resources pushes down the cost of electricity
as only operation and maintenance costs are involved, and fuel, whose prices are volatile, is
not needed. In addition, advocates argue that there is a growing demand for electricity from the
industry as well as households – why not use RE resources which are already available in the
country.
On the other hand, criticisms on RE resources include variability of supply and the high cost
of developing RE technologies. RE supply can be variable or intermittent, while conventional
energy sources can provide base load power especially for large demand. Meanwhile,
promoting capital intensive RE technologies would require policies such as incentives and
subsidies to compensate for high costs. One of the incentives is the FiT rate, which the FEF
likens to a tax, an amount that would be passed on to consumers. In view of these arguments,
the FEF had suggested that the existing RE resources – hydroelectric and geothermal, should
be rehabilitated and improved instead of promoting expensive RE projects.
The renewable energy laws have been enacted, but this does not mean that the debate has ended.
The same criticisms remained and more were raised as the laws are being implemented. What
can be done is to improve on the implementation of these laws as a way of responding to and
addressing the people’s current and potential concerns and criticisms. The following are some
suggestions:
RE technologies have been criticized for being expensive. Data presented above
indicate that the cost of RE technologies is declining and becoming competitive with
conventional energy sources. With the developments in terms of costs, the government
should consider reviewing the incentive schemes offered to RE players. For instance, a
review of the FiT rates and validity period.
The RE law achieved its objective of accelerating the exploration and development of
RE resources, with the many investments in RE projects and attainment of the
installation targets. Given the increasing interest of investors in the industry, it would
25
Thailand is reported to be consuming more of its own ethanol, hence it is possible that the Philippines would
have to start importing from the US or Brazil, leading to higher cost due to transportation. (Olchondra, 2014).
40
be important to review the ‘doing business’ procedures. RE companies that were
interviewed who experienced the lengthy and troublesome permitting process
suggested that bureaucratic reform is needed, e.g. streamlining of procedures,
establishment of a one-stop shop.
One provision of the RE law, the ‘first come first served policy’ in awarding FiT
eligibility, currently requires 100% mechanical completion of RE plants. This criteria
implies that RE companies that have already injected a lot of investment cannot be
assured of eligibility for the FiT scheme, even if the RE project is still within the
installation target. A review of the policy would be useful. One criteria that can be
considered would be completion of development stage requirements, but as a safeguard,
there should be a specific timeline for 100% completion of the project.
The priority dispatch policy, as discussed above, may have positive and negative
impacts on consumer electricity prices, hence there should be continued monitoring of
the impact of this policy on the electricity market.
The Biofuels Act aims to reduce dependence on imported fuels by mandating utilization
and promoting the development of locally-produced. It seems these objectives have not
been met as the biofuels targets have been missed as indicated in the data. The biofuels
program implementation should be reviewed and realistic targets be formulated.
41
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