MSK Petitions ERC for Meralco Refund of P2.39 Billion Overrecovery

David Celestra Tan, MSK
3 October 2016

Your consumer advocacy group, Matuwid na Singil sa Kuryente Consumer Alliance had filed a petition with the Energy Regulatory Commission to compel to Meralco to refund to the consumers an estimated overrecovery of at least P2.39 billion.

The overrecovery can actually be as high as P5 billion and was discovered by MSK during its crossexamination of Meralco’s rate setting experts on the computation of the recovery from 2011 to 2015 of an underrecovery from 2007 to 2011.

It might be recalled that Meralco offered to reduce its distribution charge in July 2015 from P1.59 per kwh by P0.188 which was the component of the rate intended to allow them to recover an under recovery from a previous regulatory period. Actually Meralco’s authority to charge that extra P0.188 expired on June 30, 2015 and it would have been illegal for them to continue charging that beyond that date. Nice media spin on their part to announce it as a voluntary reduction.

The P0.188 per kwh was computed by assuming an energy sales level in kwh for the years 2011 to 2015. That forecasted energy sales was based on an annual growth rate of 3%. Meralco itself had been announcing that its energy sales growth actually has been 6 to 7% per year.

MSK had filed for intervention to determine that the P0.188 per kwh reduction that Meralco volunteered and publicized was actually correct and sufficient.

Evidently Meralco had recovered almost double the amount it was authorized to recover. We believe that Meralco should not be allowed to profit from recovering an under recovery that was authorized by the ERC. It could be as high as P5 billion.

MSK had petitioned the ERC to compel Meralco to submit the true figures for the amount of the authorized underrecovery for 2007 to 2011, the amount they have recovered in 2011 to 2015, and to submit a refund schedule for the excess recovery plus interest.

During MSK’s cross examination, Meralco’s rate setting expert said that if Meralco’s, actual sales are higher, like when its sales grew 6% instead of 3.7% per year, that ERC rules allow them to keep the difference as profit.

This if true is a very dangerous rate setting methodology and exposes the Meralco consumers to rate abuse and manipulation. This also means Meralco, as a regulated distribution monopoly is effectively no longer regulated in its net profit as most people still believed. Is this really now the policy? The more we learn about the schemes between the ERC and Meralco the more we see the abuse of the consumers and the total lack of safeguards.

Meralco’s lawyers responded to the ERC that MSK’s request is irrelevant to the petition and that these issues must be included in the rate setting for the Fourth Regulatory Period of July 2015 to June 2019.

With these kind of rate methodologies, Meralco consumers continue to be overcharged and abused.

Let us hope the new ERC will demonstrate more caring for the electric consumers. Let us see if they will act to correct this overcharge immediately by ordering a refund.

Matuwid na Singil sa Kuryente Consumer Alliance Inc.
Matuwid.org

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Comments on the Draft Implementing Guidelines of Section 3 of the DOE Department Circular No DC2015-06-0008

 

 

Page 8

Moving Forward with the Mandatory CSP Of Power Supply Contracts

By: David Celestra Tan, Co-Convenor
Matuwid na Singil sa Kuryente Consumer Alliance, Inc. (MSK)

Voluntary implementation of the CSP is like junking the policy and completely abandoning the consumers.

Meralco’s Residential and Commercial electric consumers have been paying the highest rates since the passing of the Epira Law of 2001. Big parts of that are the sweetheart power supply deals that the government allowed Meralco to negotiate with sister company generators. Now 15 years later and six energy secretary’s and four ERC Chairmen, the government is finally taking steps to protect consumers from similar burden and create competition for the pass on generation charges to the captive electricity customers. Thanks to the patriotic move of recently resigned Energy Secretary Carlos Jericho Petilla who passed DOE Circular 2015-06-008 before he left on June 30, 2015.

One would think that a rule that clearly will benefit the captive electric consumers would get the full and unequivocal support of the government officials at the Energy Regulatory Commission, the Department of Energy, the JCPC, and Malacanang. And the enabling regulatory rules will be passed by the ERC without wasting time.

Yet, indications are that the Energy Regulatory Commission is now wavering on the CSP process, perhaps capitulating to the intense lobbying by the Metro Pacific and Aboitiz groups that together control 75% of the distribution utility market of the Philippines. Surprisingly even the DOE that passed the enlightened pro-consumer circular is now considering making the competitive bidding only voluntary instead of mandatory.

What a tragedy. Backing down on mandatory bidding would be a betrayal of the Filipino electric consumers. Here we are at the throes of correcting a decade long injustice and we would not have the fortitude to finally make amends to the long suffering consumers.

The Epira Law of 2001 was supposed to result to lower power rates. It provided for promotion of competition in each unbundled service of generation, transmission, distribution, and retail services. It professed to ban anti-competitive behavior and market domination. On the generation side the DOE and ERC put in place a complex Wholesale Electricity Spot Market where anti-competitive and market manipulation is prohibited with supposed severe penalties. Now it is working hard to set up a system for open access where large users called contestable customers can have a choice of generation suppliers. So why is the ERC hesitating to provide the captive consumers that provide 50% of the energy sales of Meralco their right to competitive power?

Reason for CSP and its basis in law

Right off the bat, allow us to state our position. The most important issue is that Competitive Bidding (or competitive selection process or CSP) would result to fairer and more reasonable rates. This is good for the consumers and for the country. There should be no argument on this truth and reality.

CSP is also good for the power generation investors because it will open the generation market instead of being closed to only the affiliates and majority owned projects of the DU owners. What remains to be debated only are execution and mechanisms on how best to achieve them.

The consumer benefits of CSP is supported by facts and empirical data. 1) An analysis of the Meralco generation cost in a study period early this year showed Meralco was passing on to consumers 23 to 33% higher prices to former sister company generators compared to non-affiliated and truly independent generators. This is to the tune of P13.68 billion a year. 2) Meralco’s new negotiated contract for the 460mw Mauban expansion, where Meralco PowerGen negotiated a 51% ownership with original proponent EGAT of Thailand, was for P4.30 per kwh. In contrast, a CSP conducted by eight (8) electric cooperatives in Northern Luzon last year for only 110mw got a bid of P3.78 per kwh, a P0.52 per kwh difference, or approximately P1.5 billion year more. The winning bidder was a globally established independent power producer.

“After rigorous regulatory review” by the ERC the rate of the Mauban expansion was shaved to only P4.26 per kwh which supported our organization’s position that competition beats regulation in reducing costs to consumers.

The legal duty of the Department of Energy and the Energy Regulatory Commission to enable this law is enshrined in their mandates under the EPIRA to promote the public interest. The Constitution even provides for this. Government officials and employees have similar obligations to protect the public.

The DU’s like Meralco, Davao Light, Visayan Electric themselves have the legal obligations under Section 23 of the EPIRA Law to supply power in the least cost manner, which can be had only by market-testing the price and not by arbitrarily determining the price between sister companies. It is part of their franchise obligation as a public service provider. Finally, as Filipinos, it is their patriotic and Christian duty to treat their countrymen and brethren fairly and not take advantage of them.

Meralco’s and Aboitiz’s counter arguments

What has been interesting in this debate is that Meralco and Aboitiz, other than making general statements, have not been presenting evidence that their negotiating power supply contracts with sister companies had actually resulted to the best rates to consumers.

Instead they have only been arguing that it will be difficult and raising all sorts of smokes and mirrors to scare everybody. Remember when we were kids and our parents and uncles would tell us “there is mumu there” if they don’t want us to go in a part of the house?

That is what Meralco has been doing in a desperate effort to retain their money maximizing rights and to deny the consumers their basic right to competitive and reasonable power. The DU’s privilege to self-negotiate how much generation rate Metro Pacific and the Aboitiz want to charge their customers. This is like taxation except the latter goes through more legislative debate and more oversight and audit. With due respect, historically an ERC review does not match the sharp-pencils in true competition.

At issue is the appropriate dipping into the public’s money whether it is comingled as taxes and government money or in their individual pockets. Many have gone to jail for misappropriating these public pockets. Pass-on electricity charges to consumers is no different. It is still dipping into their pockets and hence must be assured by the government to be fair and reasonable and safeguarded against those who will abuse the opportunity.

“Reasonable” rates can only come from a reasonable competitive procurement and contracting process. Even the ERC professes to want to let the interplay of market forces to determine power rates. And they do so in the WESM spot market, in the elaborate rules for aggregation, open access and right of choice. Why deny the captive consumers the benefit of true market interaction in the even more important basic generation rate that compromise 60% of electric consumers monthly bill?

So let us go down the list of objections and obstructions that the Aboitiz and Meralco group have been posing:

Concerns of the Aboitiz Group.

1. How do you set the rules so that the utility can use direct negotiations when conditions best suit that method?

Direct negotiations can be allowed if there has been a failure of bidding per procurement laws. Even in an emergency situation or urgent need, a DU can still resort to the international practice of “RFP’s” or request for proposals where the DU will invites known potential providers of the service that it needs specially existing IPP’s.

2. How could they set up a fair bid that does not favor a particular technology?

Most bids will be limited to the appropriate technologies that are feasible in the country. If you want base-load, the DU’s will bid coal, geothermal, and natural gas. Wind, solar, biomass, hydro, and even diesel have their roles in the energy mix and can be invited accordingly.

3. How to prevent strong utilities from subsidizing the weak ones?

Aggregation of power requirements should be voluntary. If Meralco and the Aboitiz group do not want other DU’s to be part of their CSP, it should be okey. If they want to share the benefits of their buying power in the name of patriotism or brotherhood, it is also okey. Joint bids can be proposed but it should not be mandatory.

4. If DU’s are under obligation to contract up to their peak demand levels, they could be saddled with excess capacities which will then punish the consumers.

The rules will need to rationalize the level of mandated contracted energy. Obviously it cannot be 100% of the peak demand. There has to be a provision for demand fluctuations especially in the face of open access. Also a level of market give should be allowed to provide liquidity to the WESM so that it can sustainably perform its market role.

For his part, Mr. Oscar Reyes, Meralco president, has these concerns:

1. Our position is it should be voluntary and co-exist with bilaterally negotiated contracts so that you can have the best of both worlds.

Voluntary means side stepping the spirit of CSP and an effective denial of the consumers rights to competitive and market determined power. CSP under Mr. Reyes proposal would be reduced to token biddings for the crumbs of Meralco’s power requirements. Palubag loob?

2. It has not been tried!

CSP may not have been tried by Meralco but it has been done by truly public service oriented and patriotic DU’s in the world. Even in the Philippines many DU’s specially customer centric Electric Coops have undertaken CSP’s with wonderful results for consumers

3. Its forced-fitting to the 150 electric cooperatives and utilities nationwide and that is not easy to carry out?

It will obviously not be one size fits all. There will be standard provisions to assure a level playing field and clear rules. There will be a template for standard and mandatory contract terms like transparent and verifiable indexing, fuel price and consumption, downtime allowances, and replacement power obligations, and performance monitoring. But each bid will be fine-tuned to adapt to the unique requirements of the power demand, service area, and even the technology that is deemed suited.

4. You have to have financing almost completed before you bid. Some Gencos may not want to participate because they have to invest in preparing for the bid?

Tenders for greenfield projects need to allow for completion time. Bidders though must have an identified location at time of bidding with a firm agreement. Completion time can be 3 to 4 years. Power supply that is needed within 2 years can be among those who are able to deliver it like the existing or expandable capacities of current IPP’s.

As to the cost and effort of preparing the feasibility of a project, we can understand Meralco has been spoiled by the fact that they only do project studies that are sure to be theirs to win. That is why they are against bidding. But the costing and feasibility of projects for bidding purposes is a standard business development and marketing costs of truly independent power generators.

5. Highly reliable and highly efficient GenCos may not participate because they don’t know who will bid against them.

Truly independent GenCos are in the business of generating power, providing a service, and making a reasonable profit in the process. They will go after this business depending on the rules of the game as long as it is fair and reasonable and objectively adjudicated.

They would know who they are bidding against because there will be a prequalification process. Open competition only means opening the DU generation market from the current clutches of its controlling stockholders.

6. Is the playing field even? Are we of the same competitive standards?

If the bidding rules are properly done, the level of service would be clearly specified, the criteria for qualification would apply to everyone, and clear methodology for determining the winning bid is established, the playing field should be even. This would be a vast improvement for the consumers from the current system at Meralco where there is NO playing field at all, let alone it being even.

7. Tapping a third party to undertake the auction of the PSAs is a cause for worry? They don’t have accountability and how do we know if they are even qualified.

The main job of the Third party is to assure the integrity of the bidding process, the objective evaluation, and the decision of the award. The DU and DOE will of course participate in the determination of the need.

This will also enable the policy making DOE to have some implementation influence in the energy mix, locational, environmental, and technological strategy of the country and not just the whim and “doable” preference of the DU that also owns the new genco projects.

The government through the DOE can even exercise eminent domain on strategic project sites and energy zones and lease them to the winning bidder. It will make way for the introduction of new technologies when they become available.

In the case of electric cooperatives, the right to negotiate power supply contracts had been resulting to bickering, corruption, and financially damaging ill-conceived power supply obligations that threatens their financial standing. Mandating a CSP will enable the DOE and NEA to provide energy contracting guidelines to protect the electric coops from themselves.

A Moving Forward Compromise

Why don’t we move forward for sake of people and country to demonstrate the benefits of competitive bidding. Let us start with mandating that at least 50% of the base-load power intended to serve the captive market of Meralco to be subjected to CSP? That is estimated to be about 1,200mw. Since Meralco already negotiated 1,060mw of base-load supply with Meralco PowerGen for the 600mw Redondo Power and 460mw Mauban Coal expansion, let us bid the next 1,060mw of Meralco’s requirements. Then we can really see which of the worlds, competitive bidding or negotiated sister company contracts, will be best for the consumers.

On the other hand, all electric cooperatives must be mandated to subject to CSP all their base-load power supply requirements. They however must be provided power planning and contracting guidelines by the DOE and NEA.

The ERC, DOE, and the DU’s should focus on giving the consumers their entitlement to competitive power and not allow us to be discombobulated by scary “mumu” tactics of the two vested interests. Let us move forward with the CSP.

David Celestra Tan is a founder and former President of the Philippine Independent Power Producers Assn. A CPA, He was a utility economist in power generation projects and a co-convenor of the Matuwid na Singil sa Kuryente Consumer Alliance Inc. an advocacy group seeking fair and reasonable rates and a reduction in the Meralco rate by P3 per kwh. Email: david.mskorg@yahoo.com.ph, http://www.matuwid.org

MSK clarifies

by Elinando B. Cinco as it appeared on Manila Bulletin, September 1, 2014\
Link to original: http://www.mb.com.ph/msk-clarifies/

(This is a rejoinder sent by Matuwid na Singil sa Kuryente Consumer Alliance, Inc. (MSK) in reaction to my piece – The need for legitimate NGOs – last April 15, 2014.)

MSK is duly registered with the Securities and Exchange Commission as a non-profit organization and has made annual reportorial requirements since its organization in 2011. “For financial reporting purposes we have been declaring that the organization is “non-operational” because we have not been soliciting and receiving donations from private donors.  Most of our research and work have been donated time of volunteers who also pay for their own expenses,” David Celestra Tan said.

Tan, an early practitioner in the power industry, is  co-convenor of  MSK. He said  his    consumer group has deep knowledge in power deregulation and is pushing for reforms to reduce power costs in the Meralco area that everyone is complaining about. Its  members are legitimate Meralco consumers who have rights to voice out their concerns on power costs and propose solutions.  “We are not seeking to do work on behalf of the government,” Tan said.

Tan   said he is aware that there is a need to obtain “done certification” from the Philippine Center for NGO Certification (PCNC).  He, however, said  the group will do so when they  see the need to receive donations from local and foreign cause oriented sources.

He said MSK does not see itself seeking government funding because this is not the organization’s  agenda, and MSK does not wish to compromise its  objectivity in pushing for reforms that will involve government action.  Neither does it have any aspiration to become a party-list group.

MSK is proud of its contribution in 2011 when it acted as Intervenor in  ERC Case No. 2011-108RC (in the Matter of the Application for Approval of the Batangas-Mindoro Interconnection Project (BMIP). This involves a  deeper review by the ERC of a P11.9 billion transmission line project that would have cost Luzon consumers P0.025 to P0.04 per kwh. Instead of an easy approval, the Energy Regulatory Commission is now still evaluating the cost-benefit of this added burden to the Luzon Consumers.

Tan revealed the purity of the advocacy of MSK for the electricity consumers would be evident from the group’s proposed changes in the rules and their implementation.  According to Tan, at the DOE Multi Sectoral Task Force To Find Ways to Reduce Electricity Prices, MSK has so far been the only consumer group that has submitted concrete and precise proposals for power cost reduction. “We have reached out to the other consumer groups and offered to educate them on the workings of the power sector so that their groups can make informed decision on their own position papers.”

Tan said there are groups with  vested interests that would be affected by the pro-consumer reforms MSK is pushing for at the DOE Task Force and running a campaign to stigmatize MSK and get the DOE to remove MSK’s  participation in the national debate for ways to reduce power costs.

Tan said his group, composed of a lawyer, a seasoned advocacy campaigner,  and legitimate Meralco consumers– only wants reforms in rules and industry practices so that the electricity consumers will be charged only fair and reasonable rates and will be pursuing its power cost reduction advocacies through various legal avenues available to it.

“We will be true to our name Matuwid na Singil sa Kuryente,” Tan  affirmed.

An Open Letter to Meralco and Metro Pacific

23 August 2014

Dear Sirs:

The Issue for Electric Consumers is whether monopolization of power supply and negotiated self-dealing projects will result to lower power rates. Why don’t you answer this issue and not whether David Celestra Tan is a saint and had a perfect career.

Don’t waste your time because I am not. I am just a duck-raisers son from Binangonan, Rizal. I pay my Meralco bill monthly. Now it is P12.44 per kwh which at $0.29 per kwh is among the highest in the world.  Last December you tried to increase it to P16.59! This is a serious problem and you should recognize it.  I am retired from power and just want to share the expertise that God happen to bless me with in the national search for solutions to high power cost.

Kindly understand that MSK and David Tan’s Advocacy is Pro-Consumers and, believe it or not, is not Anti-Meralco Per Se.

Meralco as the public utility institution is imbued with public interest and must view itself, not as the target, but as the natural arena for this public interest debate, the crucible for balancing private and public interest.

Our consumer advocacy group, Matuwid na Singil sa Kuryente Consumer Alliance Inc, is working for the lowering of electricity rates which is one of the highest in Asia.  This it hopes to achieve by promoting true competition in the power generation sector and rectifying distribution and transmission rate making methodologies that are not fair and reasonable to consumers.  We will also push for more overall  safeguards for consumers including at the WESM.

We are asking Meralco to be faithful to its mandate as a public service utility to truly deliver least cost power to its customers. This it can deliver only if it conducts business on “arms-length” basis and devoid of conflict of interest.

We assure Meralco and their media operators that we have no other agenda than these.  We will not financially or politically benefit from these advocacies other than as electric consumers.  Neither are we working with parties who are players in the industry. Our advocacy rides in the spirit and genuine concern of Filipinos who want to work for lowering of power costs that have been undermining the competitiveness of our country and overburdening our people. MSK’s strength is not in the money this non-profit organization has but in the burning advocacy in our hearts.

It is sad that our country has grown cynical of the motives of people who speak for the public and the consumers.  But yes Virginia there are still truly caring Filipinos.

In this debate we ask Meralco to address the issue of whether monopolization and self-negotiated power supply contracts that will be passed on to the consumers would be fair to the public and would result to lower rates than openly bidded bilateral power supply contracts. Later we will be tackling the unfairness and legality of the Performance Based Rate Making Methodology (PBR) and other regulated charges.

We realize that when the Metro Pacific group took over Meralco, they may have a misconception on the nature of the business and its public service obligation and the limits of the return on investment.  Meralco is a monopoly in the national capital region and serves 74% of the energy needs of the country.

No one should begrudge Metro Pacific for making gargantuan profits in the telephone business in the same manner no one begrudges the SM Group for being the largest mall operator.  That goes for the moneys being made in the real estate sector.  All because there are competition in these sectors. The consumers have choices on whether to use Smart Celfons (we miss you Sun!) or to go to the SM Malls or which condo unit to buy.

That is not the case in power sector where most of us are called Captive customers even by the Epira Law. Meralco as the public service utility has a simple mandate. Provide reliable power at least cost to the consumers.  It can deliver that only if it procures power supply and its equipment and services in a competitive, transparent, and arms length manner.

The Epira law and the ERC allow Meralco stockholders to have a regulated fair and reasonable returns on the investments you incur.  But this is not the place to squeeze every ounce of profit because all of those come from captive consumers who are hapless and have no chance to choose.  Meralco is a public utility monopoly already in distribution. There is no competition. It will work against the interest of consumers if Metro Pacific also monopolizes the generation supply on top of what already have been negotiated with  the Lopez group, its previous controlling owners.

If you wish to argue that Meralco is actually using its hulk and buying power to the advantage of its consumers and that by negotiating with itself and monopolizing power procurement the consumers will be charged less, then present your case to the public. If you disagree with our recommendations to the DOE Task Force for lowering electricity rates present your own and let’s debate. Instead you are mobilizing your massive media machinery to malign those who are raising the issues and trying to protect the consumers.  If you are trying to crush us and not bothering to address the issues , it only means you want monopoly and want the privilege of self negotiating the rates and terms that you want to pass on to the consumers.

These are the messages of consumers crying for reprieve and fairness. Internalize them a little. Most of you are also Filipinos and electricity consumers. Don’t shoot the messengers.

MSK and the David Tan’s among us should not even be raising these issues and risk getting your immense wrath.  You should be doing these in the first place if you are true to your public service mandate. It would also not be necessary if those who are mandated by law to protect the consumers, the Energy Regulatory Commission, the PEMC, and the JCPC are doing enough to protect the electricity consumers.

MSK can only be perceived to be Anti-Meralco if Pro-Consumerism is. Are these two mutually exclusive? Meralco as a franchised public service distribution utility must look after the consumers. If this idea is inconsistent with its investors profit goals, then it may have to choose between being a distributor or generator, but not really both because there is inherent conflict of interest that is inimical to the interest of electric consumers and the national competitiveness.

These notwithstanding, in a national win-win compromise, if you are able to continue with your 400mw Mauban expansion, your 600mw Redondo coal project in Subic, and your 500mw Pagbilao expansion as negotiated contracts, would you insure that the pass on rates to the consumers are in the P3.80 to P4.30 per kwh range? And would you demonstrate a true commitment to least cost power by opening Meralco’s future requirements to competitive bidding and cooperate to put the country on the road towards a more competitive generation sector?

The issues of monopolization, self-negotiated power supply contracts, conflict of interest from cross ownership, and lack of open bidding for generation cost that will be passed on to the captive consumers are serious matters for the consumers. Meralco’s posture to dismiss this as a mere media propaganda by a consumer group that can be extinguished with a vicious smear counter-campaign is an indication that you don’t really get it,  regard your captive consumers are people you can charge however and how much you want, and do not really take seriously your obligation to supply power in the least cost manner.

I am doing my duty as a Filipino and concerned electricity consumer. I hope Meralco will do its own duty as a public service utility that is faithful to its obligation to provide least cost power to its customers.

We hope Meralco can experience a public service epiphany.

God Bless.
David Celestra Tan
Matuwid na Singil sa Kuryente Consumer Alliance, Inc.

Email: david.mskorg@yahoo.com.ph

Letter to Sec. Petilla of Department of Energy (DOE)

Matuwid na Singil sa Kuryente Consumer Alliance Inc.

30 July 2014

Hon. Carlos Jericho Petilla

Secretary, Department of Energy

Subject: Concerns on the Proposed Structure of the new Independent Market Operator for WESM

Dear Sec. Petilla:

The Department of Energy’s initiative on the proposed transfer of the WESM market operator duties from government owned PEMC to an Independent Market Operator (IMO) is welcome and long overdue and one sure way to make way for consumer-protective reforms in the WESM trading rules. The composition of the new IMO board certainly would make it independent depending who are appointed.

We are concerned however that under the draft reorganization, a Market Participants Group (MPG) is being designated as the main recommending body for rule changes in the WESM.

MPG appears would be composed of the same group of “stakeholders” that had put in the current WESM rules that have turned out to be detrimental to the consumers. This will defeat the purpose of making the WESM’s market operator as meaningfully independent.

Instead we propose that a new truly independent technical committee reporting to the IMO Board should act as recommending body for rule making changes in support of the IMO Board.  The MPG can be a sub-committee that can provide its input in rules and changes to the IMO Board and its rule evaluating and recommending TWG.

 

The assertion of PIPPA that the IMO must be subjected to competitive bidding as envisioned by the Epira law is inaccurate. Rule making bodies and its objectives cannot be subject of competitive bidding with a price in the same way that the tariff making duties of the ERC cannot be subjected to competitive bidding. The government cannot auction ideals and public policy objectives.

We hope these concerns can be considered in the final organizational structure of the IMO.

More power in your power supply improvement initiatives.

Very truly yours,

David Celestra Tan

Co-convenor, Matuwid na Singil sa Kuryente Consumer Alliance Inc.

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