IEMOP GEOP BULLETIN NO. 3.2, 14 March 2022
IEMOP Implementation of Customer Switching
under the Green Energy Option Program
pursuant to ERC Resolution No. 08, Series of 2021
and DOE Circular No. DC2018-07-0019 and DC2020-04-009
This Bulletin supersedes Bulletin Nos. 3 and 3.1 (issued on 22 December 2021 and 4 February 2022, respectively) and is being issued to provide clarifications and further guidance on switch requirements and reminders for Customer Switching under the Green Energy Option Program (GEOP).
RATIONALE
Pursuant to the Renewable Energy Act of 2008, the Department of Energy (DOE) established the Green Energy Option Program (GEOP) which provides a mechanism for electricity end-users to source their electricity supply from renewable energy resources. To operationalize the GEOP, the DOE issued Department Circular Nos. DC2018-07-0019, entitled “Promulgating the Rules and Guidelines Governing the Establishment of the Green Energy Option Program Pursuant to the Renewable Energy Act of 2008” and DC2020-04-009, entitled “Guidelines Governing the Issuance of Operating Permits to Renewable Energy Suppliers under Green Energy Option Program”. Further to these, the ERC issued ERC Resolution No. 08, Series of 2021 (the “ERC GEOP Rules”) which set out the detailed rules for the implementation of GEOP. The ERC GEOP Rules took effect on 03 September 2021.
Among the salient provisions of the ERC GEOP Rules in respect to registration and customer switching are the following:
- End-Users with average peak demand equal to or greater than 100kW are eligible to participate in the GEOP and may contract with duly licensed Renewable Energy Suppliers (RE Suppliers).
- The Central Registration Body (CRB) shall process the registration of GEOP participants such as RE Suppliers, GEOP End-Users, Retail Metering Service Providers, and Suppliers of Last Resort.
- Similar to the handling of transactions of retail market participants, the CRB shall facilitate transactions among GEOP participants such as switching, customer relocation, termination of supply contracts, and transfer to a Supplier of Last Resort.
- End-users who opted in into GEOP may voluntarily revert to being a captive customer of their Distribution Utility (DU) subject to conditions and procedures set out in Section 24 of the ERC GEOP Rules.
This Bulletin is being issued by IEMOP, as the Central Registration Body (CRB), to guide GEOP Participants in their transactions with the CRB and the WESM relating to End-User’s switch to GEOP.
This Bulletin and subsequent bulletins to be issued by the CRB are for guidance only. Readers are encouraged to refer to the relevant issuances, as listed above, as well as to related provisions of the ERC GEOP Rules, WESM Rules, Retail Rules, the WESM Registration Manual, and other relevant market manuals.
PROCEDURES AND REQUIREMENTS
I. SWITCHING UNDER GEOP
1. Summary of Notice/Report and Switching Requirements
The table below summarizes the processes before the CRB that are relevant to GEOP switch. The table refers only to the processes before the CRB and excludes relevant processes that are internal to and involves GEOP Participants and other GEOP service providers.
To guide GEOP participants, the CRB also advises on the information and documents that the CRB will evaluate on the following switch-related requirements. Depending on the evaluation of the switch documents, clarifications and additional information may be requested to establish compliance. Further details on the procedures and requirements for the identified processes are discussed in the succeeding paragraphs.
1. Pre-switching Process
a. Conditions under Section 15, ERC GEOP Rules[1] Notice of the signed supply contract by the End-User and RE Supplier at least thirty (30) calendar days prior to start of supply 1. Registered mail addressed to:
Registration and Stakeholder Services Division
Independent Electricity Market Operator of the Philippines
19F Robinsons Equitable Tower, ADB Ave., Ortigas Center, Pasig City; or
2. Electronic mail sent to:
registration@iemop.ph, copy furnished concerned IEMOP Registration and Stakeholder Services Staff email address/es (maica.molina@iemop.ph; monica.tagalag@iemop.ph; jobelle.meren@iemop.ph)[2]
(Use Subject: GEOP Notice of / Submission of _________)End-User a. Notice is submitted at least thirty (30) calendar days prior to start of supply;
b. Notice shall at least include the following:
i. Contract period; and
ii. Name of parties;
c. The notices submitted to the CRB in compliance with Section 15 of the ERC GEOP Rules shall be consistent with each other. In case of inconsistency, the CRB shall refer to the agreements, during switch process proper.
Copies of signed Connection Agreement (CA) or Transmission Service Agreement (TSA), as applicable, and Metering Service Agreement (MSA) at least thirty (30) days prior to their effectivity End-User
a. Copies of CA/TSA and MSA are submitted at least thirty (30) days prior to their effectivity;
b. Submissions of CA/TSA and MSA that are already effective shall be made at least thirty (30) days prior the intended switch date;
c. Copies of CA/TSA and MSA must be completely executed and comply with the minimum elements of ERC GEOP Rules Annex “B-1”; and
d. If effectivity dates are not stated on the agreements, formal letter from the counter-parties or the NSP/MSP confirming the effectivity of the agreements must be submitted.
Notice on the required information regarding the GEOP End- User’s signed contract with the RE Supplier at least thirty (30) calendar days prior its effectivity End-User
a. Notice is submitted at least thirty (30) calendar days prior to start of supply;
b. Notice shall at least include the following:
iii. Contract period; and
iv. Name of parties;
c. The notices submitted to the CRB in compliance with Section 15 of the ERC GEOP Rules shall be consistent with each other. In case of inconsistency, the CRB shall refer to the agreements, during switch process proper.
Information of occurrence of any of the Last Resort Supply Events Upon occurrence, within the hour of discovery Electronic mail sent to:
registration@iemop.ph, copy- furnished concerned IEMOP Registration and StakeholderServices Staff email address/es (maica.molina@iemop.ph; monica.tagalag@iemop.ph; jobelle.meren@iemop.ph).[3]
(Use Subject: GEOP Notice of / Submission of _________)RE Supplier Information on the grounds of the last resort supply event
GEOP-Qualified End-Users Information every fifteenth (15th) day of the month Google form found in this link NSP Please see guidelines issued on 9 November 2021 through CRB’s email advisory with Subject: [GEOP CRB ADVISORY] Advisory to NSPs on Submission of GEOP End-Users Information, or refer to the publication in the website through this link: https://www.iemop.ph/geop/nsps-on-submission-of-geop-end-users-information/).
b. Submission of GEOP Switch Monitoring File[4] GEOP Switch Monitoring File Every 25th of the month, or on the next working day if it falls on a non-working day Electronic mail sent to:
concerned IEMOP Registration and Stakeholder Services Staff email address/es (maica.molina@iemop.ph; monica.tagalag@iemop.ph; jobelle.meren@iemop.ph).[5]
(Use Subject: GEOP-Qualified End-Users Switch Monitoring Sheet [RE Supplier Short Name]_[MSP Short Name]_[Switch Date in YYYYMMDD])
Please see Paragraph I(3) below.RE Supplier List of GEOP-qualified End-Users for possible switching (initial and regular switch) sent to IEMOP-CRB and the relevant MSP (1 email per MSP per switch date using the template and email Subject prescribed in this IEMOP Bulletin No. 3
2. Switch Request Proper
Submission of Switch Request Duly accomplished GEOP Switch Request Form (SRF) at least seven (7) business days[6] prior to the proposed effective date of the switch CRSS Primary RE Supplier[7]
The GEOP End-User, MSP, DU-NSP/SOLR, and/or incumbent RE Supplier or RES shall accomplish the SRFa. Should be submitted at least seven (7) business days[8] prior to the proposed effective date of the switch;
b. Completely and correctly accomplished;
c. All attached certifications/nominations/verifications are duly signed and notarized, as applicable; and
d. Signatories in the GEOP SRF and all the attached signed portions are duly supported by proof of authority and entities are authorized to transact under GEOP and/or IEMOP-CRB.
All applicable required documents listed in Part H of the GEOP SRF. During switch request CRSS; Part of GEOP SRF Primary RE Supplier a. Submitted during switch request as part of the GEOP SRF;
b. Duly signed and signatory is authorized with proof of authority; and
c. Confirmed by the assigned Primary Re Supplier.
at least seven (7) business days[9] prior to the proposed effective date of the switch CRSS Primary RE Supplier a. Submitted at least seven (7) business days[10] prior to the proposed effective date of the switch;
b. Copy of RE Supply Contract, Wheeling Service Agreement, MSA, CA/TSA indicating the start of supply or agreement effectivity date and the target switch date is within the duration of the contract and agreements;
c. If start of supply or effectivity date is not stated on the RE Supply Contract, the counter-parties must submit formal letter confirming such effectivity date;
d. If CA/TSA or MSA effectivity date is not stated on the contract, a formal letter from the counter-parties or the NSP/MSP on the effectivity of the agreements must be submitted; and
e. All other documents are submitted as part of switch request
Metering Requirements (for initial switch) During switch request CRSS MSP, in coordination with the Primary RE Supplier and End-User a. Metering requirements, as applicable, should contain consistent details of the End-User;
b. Metering documents contain specifications according to metering standards and the Metering Installation Registration Form (MIRF) is duly signed by counter-parties
2. Pre-switching Requirements: Conditions for Switching
The requirements listed in item 1 (a) of the table above shall be submitted to comply with the conditions for switching set out in Section 15 of ERC GEOP Rules. This shall be submitted prior to submission to the CRB of the GEOP Switch Request. These conditions are listed in the table above (i.e., “Conditions Under Section 15, ERC GEOP Rules”).
Given this, the CRB started accepting GEOP Switch Requests on 03 January 2022.
3. Pre-Switching Requirements: Submission of GEOP Switch Monitoring File
- Submission of GEOP Switch Monitoring File. To submit the GEOP Switch Monitoring File referred to in item 1(b) of the table above, the RE Suppliers shall send a switch monitoring file with the list of GEOP-qualified End-Users for possible switching (initial and regular switch) to IEMOP-CRB and the relevant MSP (1 email per MSP per switch date with Subject: GEOP-Qualified End-Users Switch Monitoring Sheet [RE Supplier Short Name]_[MSP Short Name]_[Switch Date in YYYYMMDD]. Submissions shall be made every 25th day of the month, or on the next business[11] day if the 25th day falls on a non-business day. For easier processing and to ensure that no submissions are missed, each email submission shall cover only one GEOP Switch Monitoring File for the relevant MSP per switch date.
- The email submission shall serve as the official notice to both the IEMOP-CRB and the MSP of the list of GEOP-qualified End-Users that are eligible for possible switching.
- Assignment and Provision of Grid Off-take Point and SEIN Information. The Switch Monitoring File submitted by the RE Suppliers as mentioned above shall be used as a reference by the MSP in providing the Grid Off-Take point/SEIN to IEMOP-CRB and the RE Supplier. Upon receipt of the Grid Off-Take point/SEIN from the MSP, the IEMOP-CRB shall send the designated GEOP Short Name and assigned GEOP SEIN of GEOP-qualified End-Users to the RE Supplier and MSP to be used in their submission of the switch request via the CRSS and in the creation of the electronic Metering Installation Registration Form (MIRF) in the CRSS, respectively.
- This guideline on the pre-switching process regarding the submission of the GEOP Switch Monitoring File is being implemented since 27th December 2021.
4. Switch Request Proper
a. Pending system enhancements, IEMOP shall utilize existing modules in the Central Registration and Settlement System (CRSS) that are also used for Retail Competition and Open Access (RCOA) to facilitate GEOP transactions, as follows:
- RE Suppliers shall initially be registered under the Retail Electricity Supplier (RES) or Local RES (LRES) category in the CRSS. RE Suppliers shall be differentiated from other RES through a short name that is unique for GEOP;
- End-Users switching to GEOP shall be initially registered under the Contestable Customer category in the CRSS; and
- Switching from a RES/LRES to an RE Supplier and vice-versa shall be processed as a Regular Switch in CRSS, similar to a RES-to-RES transfer for RCOA.
b. Given the pending system enhancements, the CRB shall accept GEOP switch requests only within the first fifteen (15) calendar days of each month (e.g., within February 1 to 15), which shall be processed on a first-come, first-served basis. Switch requests shall be accepted for processing during office hours within this period.[12]
c. Additionally, registration of Directly Connected Customers (DCCs) participating in the GEOP in the WESM shall only be as Indirect WESM Members to avoid a situation where they will be incurring spot trading amounts, thereby ensuring compliance with the 100% RE sourcing requirement for DCCs.
d. RE Suppliers are likewise required to verify that its bilateral counterparties are all RE Generators and it is compliant with 100% RE sourcing requirement as required under relevant rules and regulations for GEOP.
e. The seven (7) business days[13] timeline for processing of GEOP switch requests according to the ERC GEOP Rules will be followed.
5. General Reminders
The CRB shall continue to implement the processes and guidelines in relation to customer switching for the GEOP. In view of this, please note of the following general reminders:
1. Ensure that the Basic Conditions for Switching that are required under Section 15 of the ERC GEOP Rules are complied with within the prescribed timeline prior submission of switch requests. Section 16.1 of the ERC GEOP Rules states that the prospective RE Supplier shall submit a switch request once the basic conditions for switching as stated in Section 15 have been satisfied.
2. Network Service Providers shall submit every fifteenth (15th) day of the month the GEOP-qualified End-Users information with the required details as published in this link: https://www.iemop.ph/geop/nsps-on-submission-of-geop-end-users-information/
3. Day 1 of the GEOP 7-business day Switching Timeline commences only upon submission of switch requests with the complete and compliant documents via the Central Registration and Settlement System (CRSS). Section 3 (Definition of Terms) of the ERC GEOP Rules defines Business Day as “A day other than a Saturday, a Sunday or an official or declared Philippine national or local public holiday.”
4. Ensure that all the details which are indicated on the switch documents (Switch Request Form (SRF) with nominations, verifications and certifications, proof of authority, copies of contracts and agreements, metering requirements, etc.) are complete and consistent among all requirements including, but not limited to, company name of the parties, signatories of the parties, relevant addresses, contract and agreement details such as effectivity dates covering the end-user, customer threshold level and facility details such as Service ID Number (SIN).
5. Ensure that the GEOP SRF is completely signed by relevant parties, including all the nominations, verifications, and certifications that are attached to it.
6. Ensure that the representatives for GEOP are properly authorized by their respective organizations to register and/or transact under the GEOP and/or with the IEMOP-CRB and their authorization is supported by proof of authority. This also applies to the GEOP SRF and its attachments.
7. Ensure that the copies of the following documents are submitted as part of the switch documents, they contain the names of the relevant parties and it can be determined that they are valid by the switching date and the end-user being switched is covered:
- RE Supply Contract
- Wheeling Service Agreement
- Metering Services Agreement
- Connection Agreement or Transmission Service Agreement
II. PARTICIPATION IN GEOP
a. New Applicants
DUs/NSPs with end-users under their franchise area that will participate in the GEOP are required to register as Retail Metering Services Provider before the concerned end-users can be switched to GEOP by any registered RE Supplier, and shall comply with all the requirements for registration.
b. Existing Registered Participants
Retail Metering Service Providers. Entities that are already registered as Retail Metering Services Provider and have end-users that will participate in the GEOP must update their registration to cover GEOP, including the execution of relevant Market Participation Agreements before the concerned end-users can be switched to GEOP by any registered RE Supplier.
Contestable Customers. For entities that are already registered with the CRB as Contestable Customers in the retail market (i.e., RCOA) but will switch to an RE Supplier as GEOP End User, documents already on file with the CRB and are still valid shall be considered to avoid duplicate submissions. If the documents are no longer valid or have been changed or amended in the meantime, the RE Supplier shall submit the new documents.
Prudential Requirement. The prudential requirements of entities with prior registration with the CRB or WESM Market Operator shall be calculated in accordance with prevailing market rules and manuals. Likewise, the provisions of ERC GEOP Rules and WESM Rules shall apply to the re-calculation of Prudential Requirements of the RES whose customer shifted to a renewable energy supplier (RE supplier).
We wish to clarify that the calculated amount for the Prudential Requirement of a registered RE Supplier is expected to be zero since the WESM exposure of an end-user for switching is also expected to be zero, in line with the objective of ensuring compliance with the 100% RE sourcing requirement for all GEOP end-users. This is because the initial prudential requirement amount is calculated based on projected WESM or spot exposure.
However, it is possible that a registered RE supplier will incur a payable in the WESM for line rental and other charges associated with their Bilateral Contracts declared in the market, among other charges. In view of this, registered RE suppliers with successfully switched/registered GEOP end-users will necessarily have to be issued with a Margin Call Notice starting on the first covered billing month. Should a Margin Call Notice be issued, this may be remedied by a pre-payment or by providing a Prudential Requirement to cover the amount payable.
III. REFERENCES AND INQUIRIES
a. Prescribed Forms and Templates
The table below provides the list of prescribed forms and templates for the implementation of customer switching under GEOP. Copies of these forms and templates are attached to this Bulletin and may also be downloaded at the IEMOP website at https://www.iemop.ph/market-reports/geop-registration-forms-and-templates/.
The GEOP SRF was updated to incorporate the following general changes:
- Limiting the warranties of the signatories to their respective principals for Consent and Privacy Notice portion;
- Corrected references to ERC GEOP Rules provisions in footnotes 4, 5, and 6;
- Replaced the term “Contestable Customer” with “End-user” in page 3 under F. REFERENCE FOR INITIAL PRUDENTIAL / ADDITIONAL SECURITY;
- Added footnote 10 in page 3 – succeeding footnotes are renumbered;
- Clarified footnote 11 (previously footnote 10) regarding thresholds and added footnote 12 in page 4;
- Clerical correction to remove the unnecessary phrase in page 4 under H. DOCUMENTS SUBMITTED (letter c of Proof of Authority of Primary Supplier and its Representative);
- Replaced the term “Contestability” with “GEOP”, clarified that the Threshold must meet the threshold set under Section 4 of ERC GEOP Rules, and added row for juridical personality in page 4 under G. END-USER Information;
- Replaced the term “Contestable Customer” with “End-user” in page 4 under H. DOCUMENTS SUBMITTED (Additional Requirements for Initial Switch – All End-Users);
- Removal of the last sentence in page 6 under J. NOMINATION OF PRIMARY RENEWABLE ENERGY SUPPLIER;
- Clerical corrections and added date in all Certifications;
- Covered switch date under the certifications for no outstanding balance.
- Revisions in page 10 under N. CERTIFICATION BY METERING SERVICE PROVIDER (MSP) to delineate the compliance obligations of MSP based on the Section 15.4 of the ERC GEOP Rules and other requirements, as well as to reflect clerical corrections; and,
- Revisions in page 11 under O. CERTIFICATION BY NETWORK SERVICE PROVIDER (NSP) to delineate the compliance obligations of NSP based on Section 15.3 of the ERC GEOP Rules and other requirements, as well as to reflect clerical corrections.
| 1. Pre-switch Submission of GEOP Switch Monitoring File | ||
| GEOP Switch Monitoring File | Primary RE Supplier | M TOD.A04.TMP.18 GEOP-Qualified End-Users Switch Monitoring Sheet_RE Supplier Short Name_MSP Short Name_Switch Date in YYYYMMDD.xlsx |
| 2. Switch Request Proper | ||
| Nomination and Assignment of Primary RE Supplier executed by concerned GEOP End-User | End-User | (Part J of the GEOP Switch Request Form) N TOD.A04.TMP.16 GEOP Switch Request Form Version 2.docx |
| GEOP Switch Request Form (SRF) | Primary RE Supplier | N TOD.A04.TMP.16 GEOP Switch Request Form Version 2.docx |
| Proof of authority of Primary RE Supplier's representative and Main Contact Person | Primary RE Supplier | C Secretary Certificate RE Supplier.docx |
| Proof of authority of End-User's representative | End-User | O-1 TOD.A04.TMP.14 Secretary Certificate End-User.docx O-2 TOD.A04.TMP.15 SPA GEOP End-User.docx |
| Proof of authority of RMSP’s representative | RMSP | G Secretary Certificate RMSP.docx |
| Proof of authority of DU/NSP’s representative | DU/NSP | P TOD.A04.TMP.19 Secretary Certificate NSP.docx |
| Proof of authority of Incumbent Supplier’s representative | Incumbent Supplier | Q TOD.A04.TMP.20 Secretary Certificate Incumbent Supplier.docx |
| Secretary's Certificate / Board Resolution authorizing participation in the WESM as Indirect Member or authorizing change in participation from Direct to Indirect WESM Membership, and designating signatories | Grid-connected End-User | R TOD.A04.TMP.13 Secretary Certificate Grid End-User for Indirect WESM Membership.docx |
| GEOP Counterparty Confirmation Form | Grid-connected End-User | S TOD.A04.TMP.17 GEOP Counterparty Confirmation Form.docx |
The revised GEOP SRF may now be utilized for future switches. The old GEOP SRF for customer switching under GEOP shall still be accepted for switch dates until 31 March 2022 only.
Copies of the GEOP SRF and other forms and templates may also be downloaded at the IEMOP website at https://www.iemop.ph/geop/ and https://www.iemop.ph/market-reports/geop-registration-forms-and-templates/
b. References
Copies of ERC GEOP Rules, DOE DC2018-07-0019 and DOE DC2020-04-0009 are attached to this Bulletin.
c. Data Privacy Policy
IEMOP processes relevant personal information in accordance with its data privacy policy. IEMOP’s Privacy Notice may be viewed or downloaded via https://www.iemop.ph/about/legal-and-privacy/.
d. Inquiries
Inquiries may be directed to IEMOP Central Ticketing System or by email at registration@iemop.ph.
Download Here:
C Secretary Certificate RE Supplier
G Secretary Certificate RMSP
M TOD.A04.TMP.18 GEOP-Qualified End-Users Switch Monitoring Sheet_RE Supplier Short Name_MSP Short Name_Switch Date in YYYYMMDD
N TOD.A04.TMP_.16-GEOP-Switch-Request-Form Version 2
O-1 TOD.A04.TMP.14 Secretary Certificate GEOP End-User
O-2 TOD.A04.TMP.15 SPA GEOP End-User
P TOD.A04.TMP.19 Secretary Certificate NSP
Q TOD.A04.TMP.20 Secretary Certificate Incumbent Supplier
R TOD.A04.TMP.13 Secretary Certificate Grid End-User for Indirect WESM Membership
S TOD.A04.TMP.17 GEOP Counterparty Confirmation Form
[1] Please see Section 15, ERC GEOP Rules, for the complete details.
[2] If not known, or for inquiries, please send an email to registration@iemop.ph.
[3] If not known, or for inquiries, please send an email to registration@iemop.ph.
[4] For the determination of Grid Off-Take Point of End-Users and designation of GEOP SEIN and GEOP Short Name to be used for GEOP Switch Requests.
[5] If not known, or for inquiries, please send an email to registration@iemop.ph.
[6] Please see Section 16 in relation with Section 3 (Definition of Terms) of the ERC GEOP Rules which defines Business Day as “A day other than a Saturday, a Sunday or an official or declared Philippine national or local public holiday.”
[7] Section 3(oo) of the ERC GEOP Rules defines Primary RE Supplier as “The RE Supplier nominated by the GEOP End-User, in writing, as the single point of contact for the CRB, the Network Service Providers and all other service providers.”
[8] Please see Section 16 in relation with Section 3 (Definition of Terms) of the ERC GEOP Rules which defines Business Day as “A day other than a Saturday, a Sunday or an official or declared Philippine national or local public holiday.”
[9] Section 3 (Definition of Terms) of the ERC GEOP Rules defines Business Day as “A day other than a Saturday, a Sunday or an official or declared Philippine national or local public holiday.”
[10] Section 3(b) of the ERC GEOP Rules defines Business Day as “A day other than a Saturday, a Sunday or an official or declared Philippine national or local public holiday.”
[11] Section 3 (Definition of Terms) of the ERC GEOP Rules which defines Business Day as “A day other than a Saturday, a Sunday or an official or declared Philippine national or local public holiday.”
[12] This means that submissions in the CRSS time-stamped after 5:00 p.m. of a business day, or on a non-business day, will be considered as filed on the following business day.
[13] Section 3 (Definition of Terms) of the ERC GEOP Rules defines Business Day as “A day other than a Saturday, a Sunday or an official or declared Philippine national or local public holiday.”
