PE2 asks DOE to insert specific ESCO language in IRR for gov’t EE projects
TAGUIG CITY, 23 September 2019 — The Philippine Energy Efficiency Alliance (PE2) submitted to Secretary Alfonso G. Cusi of the Department of Energy (DOE) earlier today its third position paper on the sixth version of the draft Implementing Rules and Regulations (IRR) of Republic Act No. 11285, more commonly known as the Energy Efficiency and Conservation (EE&C) Act. The latest official comments of PE2 on the IRR sought more specific language on the use of energy service company (ESCO) contracts to support government energy efficiency projects through at least three financing modalities.
In a PE2 letter to DOE signed on 23 September 2019 by PE2 president Alexander Ablaza, the Alliance recommended the inclusion of the following statement in Section 46 of the IRR: “Such modalities for the procurement, budgeting and multi-year contracting of ESCO services for public sector facilities shall include, but not be limited to direct ESCO performance contracting under the Government Procurement Reform Act (GPRA), Public-Private Partnership (PPP) transactions under the BOT Act, and Joint Venture (JV) Agreements between government and private entities under the NEDA Joint Venture Guidelines.”
PE2 believes that the IRR should specifically mention and enable the contracting of ESCOs, regardless of whether private capital is tapped for public sector energy efficiency projects through either the GPRA, PPP transactions or JV agreements.
Under the same PE2 position paper, the Alliance recommended additional language in Section 39 of the IRR, which would make it clear that the scope of the powers and functions of the Inter-Agency Energy Efficiency and Conservation Committee (IAEECC) would include inter-agency policy actions needed to enable innovative mechanisms in the way that government implements energy efficiency projects.
PE2 recommended the insertion of a new clause under Section 39: “To lead inter-agency policy actions through recommendations relating to innovative procurement, budgeting, contracting, financing and mobilization of private sector capital toward government energy efficiency and conservation projects.”
These PE2 comments were verbally conveyed by Ablaza during the DOE-led Public Consultation on the IRR on 16 September 2019, and supplement those submitted under PE2 letters to DOE dated 26 July 2019 and 7 August 2019.
