Wednesday, August 26, 2015

Remarks on the launch of Toti Chikiamco’s book “The Way Forward: The Path to Inclusive Growth”

Remarks on the launch of Toti Chikiamco’s book –
“The Way Forward: The Path to Inclusive Growth”
National Bookstore, Glorietta, Makati City
Aug 26, 2015


Launching of Toti Chikiamco's book - "The Way Forward: The Path to Inclusive Growth", August 26, National Bookstore, Glorietta. Below picture of author and FEF President Toti Chikiamco with Sen Sonny Angara, Sec. Arsi Balisacan, FEF Senior Advisers PM Cesar Virata and Dr. Gerry Sicat, and Fellows of the FEF. FEF is the Foundation for Economic Freedom






Sec Arsi Balisacan, Sen. Sonny Angara, PM Virata, Dr Gerry Sicat, Senior Advisers of FEF, FEF Fellows, fellow fans of Toti Chikiamco:

Foundation for Economic Freedom Chairman, Bobby de Ocampo’s, apos-tolic work required his presence across the seas. He therefore asked me to convey his apologies, and his happy congratulations to Toti Chikiamco.  And his warm thank you Toti, on behalf of FEF and all the Fellows,   for your kind dedication of this volume to us. And for your resolute dedication to FEF, as its President-CEO since 2011.

Bobby de Ocampo would have loved to be here.  The genesis of FEF goes back to early 90’s, when he was Finance Secretary. FEF's philosophy was shaped by the circumstances and govt thinking of that time -- the unleashing of private sector energies through market friendly reforms and good governance.  Indeed this is thinking that traces back to reforms from an earlier period pushed by PM Virata and Dr. Sicat.

Please forgive a bit of nostalgia from this new senior citizen. FEF's started as an impromptu  dinners club-- to some extent it still is--  of like minded people who came from different careers, but found themselves united by  common cause on orphaned issues of the day.  I think the catalyst was the P1 peso per litre Leung Levy in early 90's which was opposed by everyone-- communists, rightist putschists, some business groups like the Federation of Phl Industries, CBCP, you name it.

All except for guys who on their individual capacities, were writing, talking, pushing for this necessary measure to stabilize the country’s fiscal situation and nurture development. Who then decided to meet every now and then  for dinners, KKB or  with rotating host,  to see how they might be listened to more, how to educate the public, especially legislators and policy makers, and how they might help reformers inside government who badly need support and encouragement.

These impromptu dinners, included from government--we at the DOF--Ernest Leung, later Bobby De Ocampo, and at NEDA--Dondon Paderanga. The academe/UPSE then dean Philip Medalla, Raul Fabella, Ruping Alonzo, Dante Canlas.  From   the private sector, civil society—PM Virata,  Mahar Mangahas, Ramon del Rosario, Francis Varela, Alex Magno, Bong Montes, Simon Paterno, Tony Abad, Alan Ortiz,  and Toti Chikiamco. Though it was Mahar Mangahas who gave FEF its name - a Chicago boy at heart-- and ex DOF guys who made funding from bilateral grants happen, it was Toti who was the most consistent, persistent and coherent as a publicly intellectual. His weekly columns which had a strong following among “shakers and movers” as one official termed it contributed much to shed light, provide broader perspective on the issues of the day.  He likewise lent his pen on the various advocacies of the FEF.

These FEF advocacies have met with various degrees of success over the years. Raging incrementalist at heart, such setbacks under Philippine political conditions were taken as a part of the game. 

Such efforts and FEF batting scores/contribution in the reform efforts included pushing "good to haves" like adjustments in excise taxes on tobacco, alcohol, oil (check) or reform of the VAT (check) liberalization of retail trade (question mark) , privatization/PPP (notably MWSS) (check) opening up the economy to foreign investments (question mark) property rights (check with success in land patent distribution), peace and development in Muslim Mindanao (question mark).

And trying to put a stop expose such flawed policies/programs like subsidies for Napocor (check)  NFA (XXX) CARP extension (check) a central oil procurement by government (check) an overly generous Feed In Tariffs  for RE (partly check)  and  exemption of senior citizens from VAT (XXX -- something i lamented then, but now changed my mind). 

He likewise agreed to serve was our third Chairman in the early years, after Dondon Paderanga and Mahar Mangahas. More recently, we were lucky and grateful when he accepted in 2011, the more demanding job of President-CEO. Thereby breathing new life into FEF, not just as a voice for orphaned issues, or catalyst for ideas, but as an implementer of development projects. Nowhere is this more evident than in the work, that he, Elmer Mercado, Ric Balatbat and team have done in the area of property rights-land patents to be exact. The number of free patents issued before RA 10023 was only 3000 annually. After RA 10023, which he helped push through Congress, and with the 150 partnerships that FEF has forged with LGU’s in land titling, 60,000 titles each year have been issued to newly economically empowered families.

Now on Toti Chikiamco the author and on this, his third publication and compilation of works. Allow me to quote a few lines of what a few Fellow have said. Starting with our Chairman, Bobby de Ocampo.

“There are some who may think of economists as theoretical and obscure. Others may view them as simultaneously argumentative and detached. Not so economist Calixto “Toti” Chikiamco. Anyone who reads his book compiling his numerous articles and opinion pieces will probably think instead of adjectives like engaging, committed, courageous, and patriotic yet also global.

And then he ends: “Often one can feel his frustration at the country’s seeming inability to rise above mediocrity brought in no small way by political leadership that is self-serving, myopic, small minded and hypocritical, not to mention of course corrupt and bereft of vision. But still, one can equally sense his undying hope that a better day will inevitably come.”

And Professor now Monetary Board member Philip Medalla, our former long time FEF Chairman said in the foreword of his earlier work “Why We Are Who We Are": “Yet it is rather obvious that Chikiamco is neither a rent seeker nor one who has surrendered the debate to special interest groups. His columns show an intense desire to change what is wrong with our society, especially in its incentive structure. Moreover, he thinks that by writing about why many policies are so good for the privileged elite, but so bad for the most of us, he would not only be able to explain why we are who we are, but also be able to change what we are..”

And Professor Emeritus and National Scientist Raul Fabella, in his Foreword in this new book— “As some of his writings attest, he can be very eloquent on reasons for pessimism. There was a period when Toti begged to be left un-engaged, describing himself as already a “mental and emotional self-exile”.  The difference is that Toti always bounces back to fight another day.

I leave to you to read and enjoy the many sincere, engaging thoughtful words of appreciation and high esteem, in the first pages of the book, many of them from FEF fellows, including our Senior Adviser, Dr. Gerry Sicat.  He captured in a thoughtful testimonial in the book, the essence of why Toti refers to himself as a political economist in the tradition of Smith and Ricardo. "(Thus) economic problems involve the political process in order to correct them. This is one reason some of the essays carry on a political side. Solutions require convincing government and the men who compose and make decisions. The topics range from politics and economics in the large, to development issues in the small-- constitutional change, entrepreneurship, national security, wages, income and social inequity, poverty, land rights, property rights."

For those who only know Toti from his column, you should be aware that Toti has a day job as a net entrepreneur. This has enriched his writings even more—perhaps just as hardships and ordeals contribute to the shaping of an artist.  Though Toti may not quite see it gratefully that way when he rages, at times not so incrementally, against an uncompetitive exchange rate regime or public utilities especially unsatisfactory telco services, essential to BPO space where his business is.

This synergy between public intellectual and grounded entrepreneur is summed up well by former Chairman of SGV group, also a Fellow and Trustee of FEF--Glo Tan Climaco: “Toti is an economist who passionately loves his country. He is also a businessman who competes and has to survive in the real world. This rare combination makes his essays very compelling reading for me. I find his observations and suggestions realistic and practical. Many times I learn new ideas. This book has gems of wisdom.”


Let me end now on my own final gem of wisdom—“Please buy dozens of books, and give to your friends for Xmas!”

Monday, August 10, 2015

EPDP hosts forum on power supply contracting



http://www.upecon.org.ph/epdp/epdp-hosts-forum-on-power-supply-contracting/



MANILA, 7 August 2015—The ENERGY POLICY AND DEVELOPMENT PROGRAM (EPDP), a program that aims to help government develop evidence-based energy policies and programs, convened a dialogue on competitive selection in power supply contracting entitled “Promoting Transparency and Competition for Economic Efficiency in Power Supply Contracting” on 7 August at the InterContinental Manila.

The circular promotes transparency in dealings between power distribution units and power generation companies, and finding the most cost-efficient and cost-effective options that will benefit consumers.

OIC Energy Secretary Zenaida Monsada said “EPIRA aims to create competition among generating companies where prices are market-driven, competitive, and transparent.” The recent issuance of Department of Energy Circular No. DC2015-06-008: “Mandating All Distribution Utilities To Undergo Competitive Selection Process In Securing Power Supply Agreements” on 30 June 2015 is a boost to the department’s vision of energy security and transparency in rates and charges. The circular mandates all distribution utilities to undergo competitive selection in securing power supply agreements.

Monsada added, “The Department of Energy is committed to pursue the objectives of EPIRA to achieve economic efficiency, and it needs the continued support and cooperation of the power industry stakeholders to achieve these objectives. “

USAID Mission Director Gloria D. Steele said, “We welcome the initiative from the Department of Energy to improve competition in energy power supply. A decrease in the price of electricity will bring the country one step closer to achieving a price range comparable to its ASEAN peers and more importantly, contribute to the achievement of inclusive growth in the Philippines.”

Participants from the government, private sector, and academe provided input that will inform the crafting of the department circular’s implementing rules and regulations.

The forum gathered policy makers and power supply providers, including economic planning secretary and NEDA director-general Arsenio Balisacan; development partner, USAID Mission Director Gloria Steele; the academe, Wali del Mundo; and private sector practitioner Romeo Bernardo.

Download the presentations:

Bernardo-Reaction
Del Mundo-Reaction
Alonzo-Final International Experience in CSP
Bernardo-Competitive Supply Procurement
Capongcol-DOE CSP

Fabella-Market Testing of PSA

Presidential race: Continuity or change







Philippine Daily Inquirer
01:03 AM August 10th, 2015




(From left) Interior Secretary Mar Roxas, Sen. Grace Poe, Vice President Jejomar Binay, Davao City Mayor Rodrigo Duterte

The Philippine presidential election in 2016 is shaping up as a battle between “continuity” and “change” in governance with four candidates likely to vie to be the next CEO of the land but without any clear front-runner yet in sight, according to New York-based think tank Global Source.

After President Aquino endorsed Interior Secretary Mar Roxas as his successor while framing the next presidential vote as a referendum for the “straight and righteous path,” Global Source said the aspirants would likely take guidance from their rankings in scheduled September polls of voter preference.

The Global Source commentary, dated Aug. 7 and written by Filipino economists Romeo Bernardo and Marie-Christine Tang, said the presidential election was bringing “heightened uncertainty for investors,” especially as it was emerging as a multicontender race with “no clear front-runner, specifically one who can assure bureaucrats of continuity in the executive branch, key in our view to unlocking promised state spending.”

‘Only the beginning’
Toward the end of his final address to Congress on July 27, the President attempted to recast the 2016 presidential election as a vote for continuity, saying that economic progress under his administration was “only the beginning” then endorsed the candidacy of a teary-eyed Roxas four days later, Global Source said.

“The tactic is a clever one intended to translate popular support for the President, who has managed to spring back from low ratings in the wake of the Mindanao crisis early this year, into votes for Mr. Roxas, who is lagging in presidential preference polls. If it succeeded in painting the other contender, Vice President Jejomar Binay, who is hounded by allegations of corruption, as one taking the ‘crooked’ path, so much the better,” the think tank said.

More mass appeal
But Global Source said Binay—who says he has never backed out of a fight—would not take all this sitting down.

Between Roxas and Binay, the think tank deemed Binay the one with more mass appeal.
Despite the much-publicized investigations of charges of past wrongdoing, the think tank noted that Binay continued to enjoy relatively high popularity scores and in the last presidential preference poll, had a significant 11-point lead over Roxas.

“Even as the administration is trying to frame the 2016 contest as one between continuity (straight) and change (crooked), Mr. Binay, an astute politician who grew up in poverty, is playing the rich versus poor card to the hilt,” Global Source said.

Binay and Roxas had long been gearing up for this rematch since 2010 when Roxas gave way to Mr. Aquino as the Liberal Party standard-bearer only to lose the vice presidency to Binay.
“Although Mr. Binay heretofore has had the upper hand in imaginary matchups between the two, many believe that with continuing unveiling of ‘evidence’ of Mr. Binay’s vast accumulated wealth that would make his rich versus poor cry sound hollow, Mr. Roxas would quickly catch up and with the support of the administration machinery, he could soon gain the advantage,” Global Source said.

“In fact, some believe that the only thing left for Mr. Roxas to do to secure his bid is to persuade Sen. Grace Poe to be his running mate. But as Philippine presidential elections go, it is very unlikely that it will be a two-man race,” the think tank said.

Grace factor
At the moment, Global Source said Poe did not appear too keen to be Roxas’ running mate.
“After all, she scores the highest in presidential preference surveys and it seems that some in the administration party favors her over Mr. Roxas, seeing in her the same commitment to the straight path while offering a refreshing change from traditional politicians,” Global Source said.
Poe, a junior senator, is widely expected to team up with Sen. Francis Escudero on an independent ticket.

There has been bad blood between Escudero and Roxas, as Escudero supported Binay in the 2010 vice-presidential race.

Escudero has had a falling out with Binay afterward.
Several political parties have reportedly offered to adopt the Poe-Escudero team but nothing has been concluded.

“Clearly though, [Poe’s] entry into the race will benefit Mr. Binay, as she and Mr. Roxas will split the votes of those supportive of the administration. To date, she remains noncommittal about her plans and with legal issues raised about her citizenship/residency eligibility, her decision may well depend on her assessment of vulnerability to disqualification down the road,” Global Source said.

Global Source was the first institution to predict that Poe, an adopted daughter of movie actors Fernando Poe Jr. and Susan Roces, could be one of the presidential contenders in 2016 after topping the senatorial election in 2013.

Duterte
Davao City Mayor Rodrigo Duterte could be another “credible challenger” to Binay and Roxas, Global Source said, citing the media buzz created by Duterte while “supposedly not campaigning.”

“For a mayor from the South who has denied interest to seek the presidency, he seems to be in the national limelight quite a lot. Rumors persist that he is just waiting to see how he will fare in the next voter surveys (in September) and if the numbers turn significantly up, he can be prevailed upon to join the fray,” Global Source said.

Priority reforms
As the Aquino administration heads into its last mile, Global Source said reform efforts were likely to “slow to a crawl.”

In his final address to Congress, the President mentioned five priority bills—Bangsamoro Basic Law (BBL), rationalization of fiscal incentives, antidynasty law, unified uniformed personnel pension reform bill and the 2016 budget.

A sixth proposed measure, freedom of information bill, was not mentioned in the speech but was cited by the President a day later.

“While we are confident that the President has enough influence over Congress to ensure the timely passage of the budget and Congress itself may want to support pensions for uniformed personnel, we are less optimistic about the other bills,” Global Source said.

“If ever, the executive may need to accept watered-down versions of its proposals, like what happened to the recently enacted Cabotage Law, which limited foreign ships’ cargo handling to those coming also from foreign vessels. The BBL, meant to be this administration’s legacy, remains controversial and difficult for legislators facing reelection to support,” it said.

Overall, Global Source said, external risks have increased for the Philippine economy.
“Our outlook, which sees GDP (gross domestic product) growth at 6.1 percent in 2015 and 6.5 percent in 2016, is one of guarded optimism that considers robust domestic demand growth alongside softer export demand, increasing foreign investor caution, more volatile global financial markets and risk of a stronger El NiƱo weather disturbance,” Global Source said, adding that political uncertainties were likewise adding to the “unpleasant brew.”


http://newsinfo.inquirer.net/711549/presidential-race-continuity-or-change#ixzz3iksDnBUY




Friday, August 7, 2015

Reaction: Energy Policy and Development Program Forum "Demand Aggregation and Supply Auctioning of Power in the Philippines"

Promoting Transparency and Competition for Economic Efficiency in Power Supply Contracting: An EPDP Policy Forum 
7 August 2015

by: Romeo Bernardo

Secretary Balisacan, Secretary Monsada ( and her all women power team), USAID Director Gloria Steele, Dean Solon, Prime Minister Virata, my former boss and mentor. Friends in the industry, academe and civil society.

Organizers asked me how I should be identified. I opted for my jobs as consultant, which I have been since leaving the Dept of Finance a long time ago. In the early 90’s, addressing the power crisis was one of the major challenges for government.

In the interest of full disclosure, let me mention my affiliations in the power sector—to establish my credibility (or perhaps in the eyes of some, my lack of it).

I serve as an independent director in Aboitiz Power, a diversified power company active in generation, distribution and retail. I am also an Independent Director in Phinma, a diversified holding company with interests in Trans-Asia, a power generation company.  I am Connected with the Ayala group, as a Director in BPI and Globe. AC is now quite active in power generation, fossil fuels and renewables.

I likewise hold the post of Vice Chair of the Foundation for Economic Freedom, which has been a loud voice in pushing least cost approaches for the benefit of consumers and taxpayers in embracing renewable energy.

Finally, I serve as the Private Sector representative in the Steering Committee of the EPDP, the organizer of this forum.  I was invited in that capacity, and I guess as a panellist in this forum, based on my broad even if not intensive exposure in power.  Hopefully, with biases cancelling each other out. I apologize for any remaining ones. Let me state the obvious – I speak only for myself.

2.  I congratulate economics gurus  Raul and Ruping for their very comprehensive, insightful, balanced, clear presentations.  And Prof Wally del Mundo, my co-panel reactor.  Commendations to Secretary Monsada for her presentation, and for now carrying the burden to make this Circular work. Frankly, I thought the Circular could have benefited from waiting for these studies of Prof. Fabella and Alonzo,  and more public consultations. 
Nonetheless, it is an improvement vs.  an earlier version.  In any event perhaps should be read  as general guidance—and it is up to the ERC and others to flesh it out,  and all industry players to work together in crafting  architecture that best meet  the objectives  of secure, reliable, quality, least cost  electricity for our country.

I will make two general points:

a)   We need to be careful in our diagnosis of why our power cost is relatively high. And what we need to do to bring it lower.

b)   While there can be no disagreement on the value of more competition in supply contracting, the question is, what is the best way of achieving this? I bring out some issues with the way the Circular has approached this.

3.  Why is Philippine power cost high?  Things to be done. And not done.
A table in the presentation of Raul shows Philippines’ power cost is much higher,  especially for the residential sector, even after removing taxes and subsidies.  I have come across another study by International Energy Consultants, an Australian firm, that Philippine power prices are aligned with the region and elsewhere after correcting for subsidies, taxes etc.
The differences could perhaps be explained by differing capture or assumptions on taxes, and especially subsidies,  which can be non-transparent. In several neighbouring countries government policies provide subsidies in excess of 50 percent to consumers. They also provide subsidies in the form of frozen tariffs, sale of fuel to utilities at below market rates and utility losses shouldered by government.

In doing such country comparisons, we should also be mindful of the ff:
a)     Load factor – the country with the higher load factor for demand will have lower rates. In general, the more industrialized the country, the higher the load factors.
b)     Scale and plant mix—Indonesia, Malaysia and Japan have grids and demand growth that is large enough to accept larger, more efficient supercritical plants. The first supercritical plant in the Philippines will only be built three years from now (Quezon Power 2).
c)     No Flexibility – regulatory rules require supply provided by a plant to a regulated entity to come from that plant only unless the plant has a forced or planned outage. If allowed, suppliers can mix and match, and then costs could be lowered by P 0.15-0.20 /kWh.
d)    Geographical challenges-- Adjustments for density for a country like Singapore vs. archipelagic like Philippines.        
In addition to these, we need to be aware of the evolution of the sector since the introduction of EPIRA that have added to costs and delayed supply, with adverse power tariff consequences.
e)     Growing pains from regulatory uncertainty, and contracting, approval and construction bottlenecks have delayed new plants.  The average time it takes to build a baseload  power plant in the Philippines is probably double elsewhere.  Just getting approvals, coupled with overcoming NIMBY opponents, is an ordeal.
















f)  Legacy costs of stranded assets, delays in privatization of assets, compounding interest costs.
g)     Sharp increases in the price of coal and oil, until quite recently, have pushed up power rates and led observers to think EPIRA is not working. 
















We also need to be aware of remaining constraints that need to be addressed: putting in place the enabling infrastructure like WESM (including an independent market operator), building up the transmission system, strengthening NEA guarantees and support for rural cooperatives, etc.


Most importantly, we look to more progress in rolling out open access. This will encourage more competition, eventually down to the household level – the holy grail for a competitive electricity sector.  A supportive regulatory environment is essential.

We should recognize that amidst the challenges, there has been progress.  Much  more competition is in play. New entrants have been coming in.

This chart shows how much of the new plants are coming in from new players, I have counted around two dozens, from a handful pre-EPIRA. 



















Finally, not only should we build on this progress, we should not add unnecessarily to the cost of power. I have in mind expensive renewables supported by FIT. 

Right now this adds an additional P 0.04 per kWh to our power bill. With a) the drop in the average WESM prices from P 5 to P 3 expected to prevail with lower cost of oil and coal, b) the second batch of installation targets, and c) reserve power and transmission outlays needed to support RE; FIT all can easily add P 0.20 per kWh to our bill. 

Our Foundation for Economic Freedom, which counts both Professors Raul and Ruping as Fellows, has been noisily advocating for auctioning these FIT subsidies since over four years ago.  If ever a case existed for more transparent and competitive award process, this was it as this involves allocating subsidies – an entitlement from the public. And selling to only one party, government.   I am delighted to hear the DoE and ERC now finally committed to this course for any future FIT installation.
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The point of all of this is to say  that we need to study more carefully the  causes of the observed high cost of power, continue to address those issues.  

4. Let me now go to some observations on the DoE circular, echoing, amplifying issues raised by Dr. Fabella.

a)  Demand aggregation.  Demand aggregation only works when aggregating the same kind of demand, and even then, some combinations will give you better outcome than a single plant type. Let me illustrate this point with a chart on the cost curve of types of plants—coal, LNG and oil.



As you can see, depending on plant capacity factor and volume, the economics of what is the least cost changes.  Lowest cost is not least cost.  And that a portfolio of plants may be needed to arrive at least cost. And this portfolio will differ depending on the size of the DU, customer base. And the DU’s requirements will differ at various points in time, as individual supply contracts lapse.

The demand profile of the various DUs can be very different—think of MERALCO, electric cooperatives, or DUs serving economic zones with cement and other manufacturing plants.  

Some utilities are so large relative to their grids that aggregating with any other utility will not benefit them. They are likely to end up indirectly subsidising other utilities. Meralco is such a case. It represents 70% of the Luzon grid.

 The differences among DUs are not just in their demand profile, but also their financial health.  Aggregating a financially weak DU’s demand with a strong one, will result in a less advantageous deal than if the latter contracted on its own. What does this mean in terms of guarantees that government will need to provide, and loosening of disciplines on electric cooperatives?

Where this leads me is to encourage voluntary aggregation but not mandate it. It can certainly make sense for the electric cooperatives and smaller DUs with similar customer profiles to band together.  And indeed this is happening with the support of government/USAID. Prof Wally and his team have  been instrumental in this, deserving of commendation.

b) How about compulsory auctions under a “uniform template”?

I am unsure how such a template can be formulated given: a) the differences in  situations of DUs –  demand profile, credit profile, timing of  lapses of contracts, etc., and  b)  the basic  heterogeneity of supply contracts. As well defined by Dr. Fabella, the commodity is a bundle of characteristics –  price, duration, delivery dates, risk-sharing, reliability, high cost of failures. 

Or what is the role of the Third Party which just adds a layer of cost? It is not accountable to the DU nor its customers in the event of failures or delays in the process, nor the selection of an unfit provider without back-up.   

c) How do you have a fair, unified, aggregated procurement rules and methodology for plants of different sizes (5MW to 600MW), technologies (coal, gas, geothermal, solar, wind, biomass, diesel, hydro)?  This can easily be done in the short term using Contracts For Differences (a derivatives contract covered by standard ISDA provisions ).  But wait...this is effectively not allowed under the Circular.

Let me add that there are specific issues I have read in a Meralco position paper that describes complications.  Including--

a)     Uncertainty due to shifting to Retail Competition and Open Access of captive consumers may expose DUs to stranded costs, more so if there is less flexibility as a result of a uniform contract.

b)    Implementation of demand aggregation and CSP will prevent DUs from obtaining capacities from WESM when prices are low, resulting in non-compliance to their least cost objective.

c) Lowest price bid may not necessarily be the least cost. There is also the question on the quality of the GenCo participants. ( NB. If I may add, “least cost” is not the same as “least volatile cost”. A utility aiming for least cost over a long period of time can have short term high costs like the recent Nov.-Dec  2013 price spike.)

d)  There are legal issues such as the CSP may violate the DUs’ freedom to contract and the DOE overstepping its authority. "


5.       I end up pretty much where Dr Fabella did.  I am far from sure that CSP will lower cost of power in the Philippines. It may “crowd in” new generation capacity as he said, but I think there are other obstacles that are crowding out capacity that needs to be addressed.  I enumerated them in the first part of my remarks. 
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He puts a premium on the simplest architecture on a CSP. I totally agree with such an approach.   Perhaps it is best to enhance what is in place, instead of junking it? 
And most importantly, adoption of an enhanced more transparent and competitive selection process should go hand in hand with doing away with the accounting method of verification in ERC regulatory practice.  An approach based on accounting cost and profit regulation, and not comparison against market alternatives, is completely out of sync with the whole idea of a competitive market driven power sector, the basic underpinning of EPIRA.


Thank you.