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Republic of the Philippines

ENERGY REGULATORY COMMISSION


San Miguel Avenue, Pasig City

IN THE MATTER
OF THE
APPLICATION FOR APPROVAL
OF THE RENEWABLE ENERGY
SUPPLY
AGREEMENT
BETWEEN SOUTH COT ABATO
II ELECTRIC COOPERATIVE,
INC.
AND
ASTRONERGY
DEVELOPMENT GENSAN INC,
ERC CASE NO. 2015-148 RC
SOUTH
COTABATO
II
ELECTRIC
COOPERATIVE,
INC. AND
ASTRONERGY
DEVELOPMENT GENSAN, INC.,
Applicants.

DOCKliiITMll
DEC 2,...........
2, 2015
DIIte:'.;.";7
".
~~,

_.lClt.

x- - - - - - - - - - - - - - - - - - - - - - -x
ORDER
On August 4, 2015, South Cotabato II Electric Cooperative, Inc.
(SOCOTECO II) and ASTRONERGY Development Gensan, Inc.
(ASTRONERGY) filed an application for the approval of R~newable
Energy Supply Agreement (RESA), with motion for confidential
treatment of information and prayer for issuance of provisional
authority.
In support of their prayer for the issuance of a provisional
authority, SOCOTECO II and ASTRONERGY alleged, among others,
that:
1.

SOCOTECO II has an urgent and pressing need for an


additional generating capacity as its franchise area has
been experiencing power interruptions and electricity
rationing in view of the existence of a region-wide power
supply deficiency problem in Mindanao;

2.

Such a predicament will be partly addressed by the power


supplied under the RESA between SOCOTECO II and

ASTRONERGY;0

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 2 of 17

3.

To prevent delay in the implementation of the RESA, a


provisional authority is prayed for, considering that it is
necessary for financial closing. Once financial closing is
accomplished, it is estimated that ASTRONERGY will be
able to supply power to SOCOTECO II after six (6)
months;

4.

It will also help in promoting the development and


utilization of renewable energy resources as tools to
effectively prevent or reduce harmful emissions and
thereby balance the goals of economic growth and
development with the protection of health and the
environment, as expressly enunciated in the Renewable
Energy Act of 2008, R.A. No. 9513; and

5.

Public interest as well as the declared government policy


encouraging the development and utilization of renewable
energy resources therefore compels the immediate
issuance of a provisional authority subject to final
authority that may be subsequently issued by the
Commission.

Relative to the prayer for a provisional authority,


Commission initially reviewed the application, as follows:
I.

the

Parties to the Contract

SOCOTECO II is an electric cooperative duly organized and


existing under and by virtue of the laws of the Republic of the
Philippines, with principal office address at J. Catolico, Sr. Avenue,
Lagao, General Santos City. Pursuant to Presidential Decree No. 269
(PO 269), SOCOTECO II holds an exclusive franchise issued by the
National Electrification Commission (NEG), to operate an electric light
and power distribution service in the City of General Santos, in the
Province of Saranggani, particularly in the Municipalities of Alabel,
Glan, Kiamba, Maasim, Maitum, Malapatan, and Malungon, and in
the Province of South Cotabato, particularly in the Municipalities of
Polomolok and Tupi (Franchise Area);
ASTRONERGY is a renewable energy generation company
duly organized and existing under the laws of the Republic of the
Philippines with principal address at Unit 201, Midway Court Bldg.,
241 EDSA, Mandaluyong City, Metro Manila~

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 3 of 17

II.

Mindanao
Scenario

Grid

and

SOCOTECO

II's

Supply-Demand

The Mindanao Grid is currently facing a deficit in its power


supply, which may worsen over time. The generating capacity in the
Grid is no longer sufficient to meet the power requirements of
Mindanao.
The table below shows the 2014-2020 supply-demand
in the Mindanao Grid as published by the DOE:

MINDANAO SUPPLY-DEMAND
2014
3000 Apr: 13.6 MW TUdaya
15 MW Mapalad 0'''"
2800 J sep: 26.1 tv'MI Peak Pmver
Nov: 150 MW Therma South 1

OUTLOOK (2014-2020)

--.~-~-~-

2015
Mar: 150 IIlN Therma South 2
. Jun: 112 Sa!1anQan HE?
: Jul:30 MW Puyo HE?

outlook

2016

Mar: 25 MW lake Mainl HEP

2017

\ Jan: 9 MW Umbata~n

I 5'1':405 MWFDC COO1

HEP

Sep: 200 MWSatall9ani Coal


, Dec: 40 MW Biomass

2600 '

,,.--.,. ..,"._'

"'"

,~
...

.',.....",.... " ....

2000 .,
1800 -

1400 ~
1200 .

At present, SOCOTECO II sources more than fifty percent of its


power requirements from the Power Sector Assets and Liabilities
Management Corporation (PSALM) under a Contract for the Supply
of Electric Energy (CSEE) which will expire on December 31, 2016.
Shown below is SOCOTECO
demand scenario:

Peak Demand, MW
Suppliers:
1. PSALM/NPC'
2. SEC
3. FDC-GEO

II's annual forecasted

Forecasted
2015 2016 2017 2018
171
179
142
150
30

10

15
70
10

supply-

2019
188

2020
197

15
70

15
70

15
70

15
70

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 4 of 17

5
30
30
19.6
15

30
15

10
5

10
5

10
5

10
5

30

30

30

30

1 It is assumed that PSALM will continue to supply at a level of 15 MW.


2 Contract with TMI will expire on September 2016.
3 Contract with MPC will expire on February 2016 or upon entry of SEC, whichever comes first.

It is uncertain whether PSALM still has the capacity to supply


power requirements beyond December 2016 as PSALM is in the
process privatizing its generation assets in Mindanao. In fact, the
contracted capacity under the current CSEE of SO COTE CO II and
PSALM is already a reduced capacity in view of the existence of a
region-wide power supply deficiency problem in Mindanao.

III.

ProcurementProcess

In the middle part of 2013, ASTRONERGY, offered to supply


power to SOCOTECO II, particularly targeting its daytime peaking
requirement.
After a series of meetings to negotiate the terms and conditions
of the power supply contract, SO COTE CO II and ASTRONERGY
executed a RESA on February 8,2014.
SOCOTECO II contracted with ASTRONERGY because it is a
relatively cheap source of daytime peaking supply. By 2016, it is
projected that the majority of SOCOTECO II's power will be supplied
by base load plants, with some peaking supply from diesel power
plants.
In addition, SOCOTECO II's utilization of a renewable energy
source in ASTRONERGY's
solar power is in furtherance of
government policy promoting the use of renewable energy so as to
reduce the emission of pOllutan~

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 5 of 17

IV.

Salient Features of the RESA

Type of Plant
Solar Power Plant

Delivery Term

The RESA shall remain in force and effect for a period of twentyfive (25) years counted from the Commercial Operation Date as
defined in Article 3.1 of the RESA.

Contract Capacity

The full generation capacity of the ASTRONERGY's Santos


Solar Project (SSP), net of all Station Service is 24 MW (DC or Direct
Current) resulting in net capacity of 20 MW (AC or Alternating
Current). This difference in capacity is due to system losses
(approximately 20%) that occur when generating in DC then
converting to AC before the delivery point. Due to the intermittent
nature of solar energy on an annual basis, SOCOTECO II shall be
obligated to receive and pay for, any product, as measured by
delivered energy that exceeds the Contract Capacity by up to ten
percent (10%) during the first five (5) years of the Delivery Term.

Must-Take As-Available Energy

The capacity to be delivered and sold by ASTRONERGY and


received and purchased by SOCOTECO II under the RESA is "AsAvailable Energy", produced by the Santos Solar Power Plant
(SSPP) [net of Station Service]. The capacity provided by
ASTRONERGY under the RESA shall be supplied from SSPP only.

Delivery Point
The Delivery Point as agreed upon by the parties shall be the

poin' of interconnectionof the Projectto 'he SOCOTECOII gr~

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 6 of 17

Energy Payment
The Energy Price shall be as follows:

V.

a)

During the first full contract year, the price for each MW/h
of energy delivered shall be PhPB,350.00 and increased,
each contract year thereafter, by four and eight-tenths
percent (4.8%). For each month, SOCOTECO II shall pay
ASTRONERGY an amount equal to the sum of each and
every megawatt-hour
(MW/h) of energy delivered
multiplied by the applicable energy price per MWh.

b)

Prior to Commercial Operation and ASTRONERGY


obtaining certification for the Project, SOCOTECO II shall
pay ASTRONERGY an amount equal to the sum for each
hour of the product in Contract Year 1 delivered by
ASTRONERGY and received by SOCOTECO II in each
hour at the Delivery Point, so long as such amount is 1
MW or more.

ASTRONERGY's

Santos Solar Project

In order to supply power to SOCOTECO II under the RESA,


ASTRONERGY shall construct, own, operate, manage and maintain
ASTRONERGY's Santos Solar Project (SSP) in Barangay Bawing,
General Santos City. The SSP will be designed and constructed
using twenty-four (24) separate, 1 MW strings (generating units) of
mono-crystalline or polycrystalline photovoltaic modules. Each string
will connect to a 1 MW inverter.
On August 18, 2014, the Department of Environment and
Natural Resources (DENR) issued Environmental
Compliance
Certificate with Reference No. ECC-R12-140B-0095 for the power
plant.

DISCUSSION
For purposes of evaluating the prayer for the issuance of
provisional authority, the Commission bench marked the FIT model
used by ASTRONERGY and found the same consistent with that of
the Commission's recently approved New Solar FIT rate under ERC
Case No. 2014-004 RM dated Macch 27,2015, to ~

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 7 of 17

PARTICULARS
Total Project Cost, US$/MW
Engineering, Procurement and
Construction (EPC), US$/MW
Project Capacity Factor, % of DC
nameplate rating
Project Capacity Factor, % of AC
nameplate ratinQ
After-tax Equity IRR, %
Local Inflation Rate
Peso to US$ FX Rate
Base Local CPI
Loan Amortization, years

ASTRONERGY
1,958

FIT
1,958

1,586

1,586

16

18.50

20

12.76
3.28
44.40:1
138.91
10

13.87
3.28
44.40:1
138.91
20

As can be gleaned from the above table, the parameters used


in the ASTRONERGY model is basically the same with that of the FIT
model except for the Equity Internal Rate of Return (IRR), the net
capacity factor and period for loan amortization.
In the said application, ASTRONERGY used a different factor
which resulted to a lower rate than that of the approved FIT.
Under the RESA, ASTRONERGY shall deliver the contracted
energy to SOCOTECO 1\ and the latter shall pay a base rate of
PhP6.35/kWh subject to price adjustment as provided in the contract.
Notably, the proposed rate of PhP6.35/kWh appears to be
significantly lower than the newly approved FIT base rate of
PhP8.69/kWh. However, the proposed base rate shall be subjected
to a fixed escalation rate of 4.8% per annum. Further, the FIT model
used a 3.28% price escalation for the 32% of the total rate while the
remaining 68% is set at zero (allocated for ForEx).
The table below shows the difference of the escalation factor
assumed in ASTRONERGY and FIT financial model, to wit

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 8 of 17

FIT
3.28% - 32%
0% - 68%
1.059%

Escalation/CPI
USD:PhP
Net Escalation
Note: 1.

ASTRONERGY
2.

ASTRONERGY
4.8%
4.8%

adjustment formula is fixed for the duration of the contract.

FIT formula is dependent of the actual result of the economic indices. It


will result to a lower or higher than the 1.059% or can even reach or
surpass the proposed adjustment escalation rate of 4.8% depending on
actual indices.

Applying the said escalation factor will result to the following


rates and found herein below is the comparative table between the
proposed rate and the FIT rate, to wit:

Year
1st
2nd
3rd
4th
5th
6th
7th
8th
9th
10th
11th
12th
13th
14th
15th
16th
17th
18th
19th
20th
21st
22nd
23rd
24th
25th

Proposed
Rate
6.35
6.65
6.97
7.31
7.66
8.03
8.41
8.82
9.24
9.68
10.15
10.64
11.15
11.68
12.24
12.83
13.44
14.09
14.77
15.48
16.22
17.00
17.81
18.67
19.56

Fit Rate
8.63
8.72
8.82
8.92
9.02
9.12
9.23
9.34
9.46
9.58
9.70
9.83
9.96
10.10
10.24
10.38
10.53
10.68
10.84
11.01
9.01
9.15
9.30
9.45
9.60

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 9 of 17

To
illustrate
further,
the
graph
below
shows
that
ASTRONERGY's
proposed rate shall have a constant upward
movement while the FIT Rate shall vary, depending on the movement
of economic indices.
25.00
20.00
15.00
-Proposed
10.00

-FIT

Rate

Rate

5.00

Note: Under the FIT model, at 21" year, the base rate will be set back to PhP7.00/kWh.

As shown above, while the proposed rate may appear to be


lower at the earlier years of the contract starting on the eleventh (11th)
year of the contract, it would be noted that the proposed rate would
be much higher than the FIT and may even reach as high as
PhP19.56/kWh on the twenty-fifth (25th) year. Since the proposed rate
will be subjected to an escalation factor fixed at 4.8%, the rate would
certainly reach PhP15.48/kWh on the twentieth (20th) year of the
contract.
On the other hand, the FIT adjustment formula is uncertain
since it is dependent of the actual result of the economic indices.
There is no assurance on the 20th year of the contrac~),the rate would
be equal to that of the projected rate of PhP11.01/kWh as the
adjustment factor will be dependent on the actual outcome of the CPI
and Foreign Exchange Adjustment. In other words, the actual rate
may be higher or lower compared to the projected rate under the FIT
model.
Below is the comparison of ASTRONERGY's submitted project
and operating cost including the derived rates and that of the New
Solar FIT.
Project Cost

The Project's"all-in"cost is summarizedas fOllOW~

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 10 of 17

"All In" Project Cost Metrics


Capital Cost

Total Cost

US$/MW

US$/kW

US$/W

Debt/Cap

US$48,867,000

US$1,958,000

US$1,958

US$1.96

70%

It should be noted that the proposed project cost amounting to


US$1,958/kW is consistent with the Commission's Decision dated
March 27, 2015 in ERC Case No. 2014-004 RM approving the new
Solar FIT.
Computation

of WACC

The proposed return on equity is as follows:

Return on Equity (ROE)


ROE - 25-year

12.76%

The project's current weighted average cost of capital (WACC)


is 8.90%. The capital structure consists of 70% debt and 30% equity,
calculated as follows:
Weighted Average Cost of Capital (WACC)
Capital

Ratio

Annual Cost

Average

Debt

0.7

7.25%

5.08%

Equity

0.3

12.76%

3.83%

WACC

8.90%

The Commission derived an adjusted Cost of Equity of 13.87%


for the New Solar FIT by using the current input parameters and the
CAPM Formula, to wit:
Particulars

Values

Market Risk Premium

8.60%

Multiply by Re-Ievered beta

1.0

Equals

8.60%

Plus Risk Free Rate

5.27%

Cost of Equity

13.87%

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 11 of 17

The Commission has computed a pre-tax WACC of 9.2% using


the 13.87% adjusted Equity IRR.
Operations and Maintenance Fee

The O&M Costs of US$1, 148,679/year includes insurance,


module washing, technical inspections, inverter reconditioning and
replacement. Shown below is the breakdown of said cost:

Land lease
Power Plant Maintenance and
Reconditioning
Module technicians; replacement and
washing
Monthly audit and technical inspection
24-hour security and remote monitoring
High voltage inspection and
maintenance
Inverter reconditioning/replacement fund
(10-year life)
Maintenance vehicle lease, fuel and
maintance
Water supply
Maintenance and Reconditioning
Subtotal
Insurance (0.6% of insured value)
Insurance Subtotal
General and Administrative
Total Cost

Cost, US$
94,829

US$/Wp cost
0.00380

124,775

0.00500

37,433
124,775

0.00150
0.00500

49,910

0.00200

249,550

0.01000

49,910

0.00200

6,239

0.00025

642,591

0.02575

281,492
129,766
1,148,679

0.01128
0.00520
0.04603

The Commission noted that the proposed O&M cost is


consistent with the Commission's Decision in ERC Case No. 2011006 RM1 dated July 27, 2013.
Derivation of the Rates
The following parameters
submitted financial model:

were

used

in ASTRONERGY's

In the Matter of the Petition to Initiate Rule-Making for the Adoption of the Feed-In Tariff
for Electricity Generated from Biomass, Ocean, Run-of-River Hydropower, Solar and

\Mod
E",~yR.,,",~ (P"moo"N,'o",' R,"~,b1. E",~yBO"d-NRE~

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 12 of 17

Parameter for Determining

and Calculating
Rate*

Solar Power

Total Pro'ect Cost, US$/MW


Engineering, Procurement and Construction (EPC),
US$/MW
Pro'ect Ca acit Factor, % of DC name late ratin
Pro'ect Ca acit Factor, % of AC name late ratin
Performance Ratio PR, %
On-site substation, US$
After-tax E uit IRR, %
Local Inflation Rate
Peso to US$ FX Rate
Base Local CPI
Loan Amortization, ears

1,958
1,586
16
20
79.5
2,000
12.76
3.28
44.40: 1
138.91
20

Stated in US$OOO's; and solar-electric generation equipment in "DC" unless otherwise noted

Considering that the Commission has structured the FIT model


in a bundled manner by setting a single FIT price for the energy that
includes
a specific,
identified
and disclosed
O&M
cost,
ASTRONERGY has taken similar approach and absorbed the O&M
charge into the proposed rate.
Thus, ASTRONERGY proposed an "all-in" energy rate of
PhP6.35/kWh escalated at a fixed rate annually resulting to a lower
Levelized Cost of Electricity (LCOE) and lower IRR than the approved
FIT program.
Further, ASTRONERGY adopted an annual escalator of 4.8%
necessary to economically offset the degradation of the solar plant
that reduces the energy output by 0.8% per annum over 25 years. In
other words, due to the solar module degradation that is inherent with
the technology, the solar power plant will generate less energy each
year - than the year before.
Corollarily, the annual reduction in electrical output increases
the cost of producing electricity because the power plant cost is static
(invested in year 1) and the capital costs (e.g. debUequity) will
continue to accrue interest with less energy revenue available each
year to repay the debt and equity.
To maintain payments on debt and recover its invested capital,

ASTRONERGYallegedthat it must graduallyincreasethe ene~

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 13 of 17

price each year. Even with the indexed price structure considered,
ASTRONERGY would just earn an IRR of 12% only which is about
85% only of the Commission-approved return on equity.
In determining the reasonableness of the proposed rate, the
Commission benchmarked the rates with the Commission's approved
rates and parameters under ERC Case No. 2014-020 RC2 and ERC
Case No. 2014-004 RM3.
Shown below is the comparison of the major parameters
approved by the Commission under the New Solar FIT vis-a-vis
ASTRONERGY's proposed parameters, as follows:

Parameters
Total Project Cost
Capacity Factor (DC)
Capacity Factor (AC)
Equity IRRNominal
Pre-tax WACC
Annual Escalator
Rate

ASTRONERGY's
proposal

Commission's
Approved New
Solar FIT

Commission's
Provisionally
Approved Rate

US$1,958/kW

US$1,958/kW

US$1,958/kW

16%
20%

18.50%

16%
20%

12.76%

13.87%

12.76%

8.90%

9.20%
(Based on FIT
Rule)

4.8%
PhP6.35/kWh

PhP8.69/kWh

8.9%
PhP8.54/kWh

The ASTRONERGY and the Commission's approved New


Solar FIT considered the same total project cost but differed on other
cost assumptions such as the capacity factor and cost of capital
except that the adjustment factor proposed in the model was
removed and thus come-up with a levelized rate instead.
The Commission believes that inclusion of said annual
escalator requires further justification. Thus, for purposes of issuance
of . provisional authority, the annual escalator as proposed is
disallowed.

4.

In the Matter of the Application for Approval of the Power Supply Agreement (PSA) Between
Cagayan Electric Power and Light Company Inc.(CEPALCO) and Kirahon Solar Energy
Corporation (KSEC), with Prayer for Provisional Authority

In the Matter of the Adoption of the Amendments to Resolution NO.10, Series of 2012, A
Resolution Approving the Feed-in-Tariff (FIT) Rates, as necessitated by the New Installation
Target for Solar Energy Generation Set by the Department of Energy (DOE)

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 14 of 17

VI.

Rate Impact

Based on the documents submitted, the Commission made a


simulation and calculated the rate impact using the Commission
provisionally approved rate, as shown in the table below:
Generation Cost (Year 2016)

Particulars
Total Energy
Cost, PhP
Total Energy
Consumed,
kWh
Blended Rate
(PhP/kWh)

Without
ASTRONERGY

With ASTRONERGY
(Commission's
provisionally rates)

Difference

630,899,205.66

633,920,802.43

3,021,596.76

90,926,400

91,443,200

516,800

6.9386

6.9324

0.0062

With the entry of ASTRONERGY, there will be a projected


decrease in the generation cost of SOCOTECO II of about
PhPO.0062/kWh.
The Commission has a mandate to protect the interest of the
electricity consumers insofar as they are affected by the rates, by
ensuring that the tariffs imposed are consistent with the principle of
full recovery of prudent and reasonable costs.
An initial evaluation of the application discloses that the RESA
entered into by and between SOCOTECO II and ASTRONERGY will
redound to the benefit of SOCOTECO II's member-consumers in
terms of continuous, reliable, efficient and affordable power supply as
mandated by Republic Act No. 9136, otherwise known as the Electric
Power Industry Reform Act of 2001 or the EPIRA [Section 2.
Declaration of Policy - (b) "to ensure the quality, reliability, security
and affordability of the supply of electric power].
WHEREFORE,
the foregoing
premises considered,
the
Commission hereby PROVISIONALLY APPROVES the Renewable
Energy Supply Agreement (RESA) between South Cotabato II
Electric Cooperative,
Inc. (SOCOTECO
II) and Astronergy
Development,
Inc. (ASTRONERGY),
subject to the following /
conditions:

/?

ERC CASE NO. 2015-148 RC


ORDER/October 13,2015
Page 15 of 17

1.

Applicable Rate shall be the base rate amounting to


PhP8.54/kWh
and not subject to adjustment
or
escalation;

2.

The final generation cost that can be recovered shall be


determined by the Commission in its Decision in the
application; and

3.

In the event that the final rate is higher than that


provisionally granted, the resulting additional charges
shall be collected by ASTRONERGY from SOCOTECO II.
On the other hand, if the final rate is lower than that
provisionally granted, the amount corresponding to the
reduction shall be refunded by ASTRONERGY
to
SOCOTECO II.

SO ORDERED.
Pasig City, October 13, 2015.

....~ ..-r--

JOSE VICENTE B. SALAZAR


Chairman

ALFR~'N

GLO~C~

Commissioner

(On Official Travel)


JOSEFINA PATRICIA A. MAGPALE-ASIRIT
Commissioner

~ 'AP-TARUC
commissi~er

RONIMO D. STA. ANA


Commissioner

;-ERC-~--.
Office of the Chairman

111I,illlllllllll!IIIIIIIII:1111I'1111111111
~III~~ III! ~ 1111~~

L-201S-016-02S72

ERC CASE NO. 2015-148 RC


ORDER/October 13,2015
Page 16 of 17

Copy furnished:

1.

Atty. ATTY. CECILlA~. LAYUG


Counsel for the Applicants SOCOTECO II and ASTRONERGY
Unit 2904, One San Miguel Building
San Miguel Avenue corner Shaw Boulevard
Ortigas Center, Pasig City, Metro Manila

2.

South Cotabato II Electric Cooperative, Inc.


(SOCOTECO II)
J. Catolico Avenue, Lagao, General Santos City

3.

DENNIS R.V. EALA


President
Astronergy Development Gensan, Inc.
Unit 201 2/F Midway Court Building,
241 EDSA, Mandaluyong City

4.

Office of the Solicitor General


134 Amorsolo Street, Legaspi Village
Makati City, Metro Manila

5.

Commission on Audit
Commonwealth Avenue
Quezon City, Metro Manila

6.

Senate Committee on Energy


GSIS Bldg. Roxas Blvd., Pasay City
Metro Manila

7.

House Committee on Energy


Batasan Hills, Quezon City, Metro Manila

8.

Office of the Governor


Province of South Cotabato

9.

Office of the Governor


Province of Sarangani

10.

Office of the City Mayor


General Santos City

11.

Office of the Municipal Mayor


Alabel, Sarangani

ERC CASE NO. 2015-148 RC


ORDER/October 13, 2015
Page 17 of 17

12.

Office of the Municipal Mayor


Glan, Sarangani

13.

Office of the Municipal Mayor


Kiamba, Sarangani

14.

Office of the Municipal Mayor


Maasim, Sarangani

15.

Office of the Municipal Mayor


Maitum, Sarangani

16.

Office of the Municipal Mayor


Malapatan, Sarangani

17.

Office of the Municipal Mayor


Malungon, Sarangani

18.

Office of the Municipal Mayor


Polomolok, South Cotabato

19.

Office of the Municipa


Tupi, South Cotabato

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