Republic of the Philippines ENERGY REGULATORY COMMISSION San Miguel Avenue, Pasig City IN THE MATTER OF THE APPLICATION FOR APPROVAL OF THE AMENDMENT TO THE POWER SALES CONTRACT (APSC) BETWEEN KEPCO SPC POWER CORPORATION (KSPC) AND CEBU I ELECTRIC COOPERATIVE, INCORPORATED (CEBECO I), WITH MOTION FOR THE ISSUANCE OF PROVISIONAL AUTHORITY ERC CASE NO. 2014-116 RC KEPCO SPC POWER CORPORATION (KSPC), AND CEBU I ELECTRIC COOPERATIVE, INCORPORATED (CEBECO I), Applicants. )( - -- -,- - -- - -- -- - -- - - - -- - - - )( D0 CJb • X 11 11 '1'\ ' t"'. " V 0, 3 ?I1H, vii ,OJ. • ••••• 'i..:;7•..~' !ftit; ,-,.----.v:~_.- - NOTICE OF PUBLIC HEARING TO ALL INTERESTED PARTIES: Notice is hereby given that on August 12, 2014, KEPCO SPC Power Corporation (KSPC) and Cebu I Electric Cooperative, Incorporated (CEBECO I) filed a joint application for approval of their Amendment to the Power Sales Contract (APSC), with motion for the issuance of provisional authority. In the said application, KSPC and CEBECO I alleged, among others, that: 1. KSPC' is a duly authorized generation company and existing under and by virtue of the laws of the Republic of the Philippines, with principal address at i h Floor, Cebu Holdi,ngs Center, Cebu Business Park, Cebu City;
22
Embed
ENERGY REGULATORY COMMISSION IN THE … ERC Case No...It has been granted a franchise by the National Electrification Administration (NEA) to distribute electric service in the following
This document is posted to help you gain knowledge. Please leave a comment to let me know what you think about it! Share it to your friends and learn new things together.
Transcript
Republic of the PhilippinesENERGY REGULATORY COMMISSION
San Miguel Avenue, Pasig City
IN THE MATTER OF THEAPPLICATION FOR APPROVALOF THE AMENDMENT TO THEPOWER SALES CONTRACT(APSC) BETWEEN KEPCO SPCPOWER CORPORATION (KSPC)AND CEBU I ELECTRICCOOPERATIVE, INCORPORATED(CEBECO I), WITH MOTION FORTHE ISSUANCE OFPROVISIONAL AUTHORITY
ERC CASE NO. 2014-116 RC
KEPCO SPC POWERCORPORATION (KSPC), ANDCEBU I ELECTRICCOOPERATIVE, INCORPORATED(CEBECO I),
D 0 CJb • X 1111'1'\ ' t"'. " V 0, 3 ?I1H,vii ,OJ. • ••••• 'i..:;7•..~'!ftit; ,-,.----.v:~_.- -
NOTICE OF PUBLIC HEARING
TO ALL INTERESTED PARTIES:
Notice is hereby given that on August 12, 2014, KEPCO SPCPower Corporation (KSPC) and Cebu I Electric Cooperative,Incorporated (CEBECO I) filed a joint application for approval oftheir Amendment to the Power Sales Contract (APSC), with motionfor the issuance of provisional authority.
In the said application, KSPC and CEBECO I alleged, amongothers, that:
1. KSPC' is a duly authorized generation company andexisting under and by virtue of the laws of the Republicof the Philippines, with principal address at ih Floor,Cebu Holdi,ngs Center, Cebu Business Park, Cebu City;
J.
ERC Case No. 2014-116 RCNOTICE/October 22, 2014Page 2 of 22
2. CEBECO I is a franchised electric cooperative organizedand existing under the laws of the Republic of thePhilippines with principal office at Bitoon, Dumanjug,Cebu. It has been granted a franchise by the NationalElectrification Administration (NEA) to distribute electricservice in the following city and municipalities: CarcarCity, Sibonga, Argao, Dalaguete, Alcoy, Boljoon, Oslob,Santander, Samboan, Ginatilan, Malabuyoc, Alegria,Badian, Moalboal, Alcantara, Ronda, Dumanjug andBarili, all in the province of Cebu (the Franchise Area);
Nature of the Application
3. Pursuant to Rule 20 (B) of the Commission's Rules ofPractice and Procedure, approved on June 22, 2006 inResolution No. 38, Series of 2006, the instant applicationis submitted to the Commission for approval of theirAPSC dated April 26, 2014. A copy of the said APSC isattached to the instant application.
Moreover, their "Motion for the Issuance of ProvisionalAuthority" is made pursuant to Rule 14 of the said Rules;
Compliance with Pre-Filing Requirements
4. In compliance with Rule 6 of the Commission's Rules ofPractice and Procedure, they have furnished therespective legislative bodies of the Local GovernmentUnits of the municipality where CEBECO I principallyoperates as well as the Province of Cebu. Copies of theCertificates from the legislative bodies are attached tothe instant application;
5. They have caused the publication of the presentapplication in its entirety in a newspaper of generalcirculation within the franchise area of CEBECO I.Copies of the corresponding Affidavit of Publication andissue of the said newspaper are, likewise, attached tothe application;
ERC Case No. 2014-116 RCNOTICE/October 22, 2014Page 3 of 22
Background and Statement of Facts
6. KSPC entered into a Power Sales Contracts (PSC) withCEBECO I on July 5, 2007. The parties subsequentlyamended their PSC (first amendment) through an APSCdated March 29, 2008 and further amended the same bythe Implementing Agreement to the Power SalesContract dated September 21, 2009 and finallysupplemented by the Supplemental Agreement (SA)dated January 27, 2014, a copy of the SA is attached tothe instant application;
7. The parties applied for the approval of their PSC with theCommission (ERC Case No. 2007-141 RC) which itapproved the same in a Decision dated December 8,2008 with a KSPC rate of PhP4.2511/kWh. They adoptall documentary evidence submitted to the Commissionin support of the previous application and the approvedPSC to form part of the instant application in so far asthe documents relates to them. They, likewise, submitthat the Commission may take judicial notice of alldocuments submitted in the previous application toprevent unnecessary duplications of documentaryevidence;
Amendments to the PSC on the Fuel Factor of theKSPC Price Adjustment Formula
8. In September 2010, the Minister of Energy & MineralResources (MEMR) of Indonesia passed MEMR No. 17,Series of 2010, regulating coal exportations fromIndonesia. The law requires that the coal price in acontract must be equal to or higher than the CoalReference Price (CRP) to be issued by the MEMR.The basic tenets of the CRP affecting KSPC's coalcontracts are as follows:
8.1 The CRP applies to all long-term contracts (contractslasting for more than 3 years) for the exportation ofcoal;
ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 4 of 22
8.2 The CRP of a particular contract is the average CRPfor the three (3) months immediately preceding theexecution of the relevant contract;
8.3 The coal price must be equal to or higher than theCRP (the CRP itself being based on FOB);
8.4 KSPC's contract price of coal is Cost and Freight(CFR), so the delivered price of coal is coal price(FOB) plus transportation price;
8.5 The CRP must be applied for one (1) year (i.e., theCRP at the time of execution of the contract, e.g.IPC contract (July 2011) is USD 56.15/ton whileJSKM contract (October 2011) is USD 54.49/ton,Quarterly adjustments under the CSC must be equalto or higher than blended CRP of both contracts atUSD 55.47;
8.6 If quarterly adjustments is lower than the CRP, thenthe price to be used for that quarter will be the CRP;
8.7 A new CRP will be computed at each anniversarydate of each contract and used until the end of thatanniversary year; and
8.8 To export coal properly from Indonesia, a suppliermust have an IUP license and must comply with theCRP.
A copy of the said MEMR No. 17, Series of 2010 isattached to the application;
9. To secure the coal requirements for the next ten (10)years and assure the customers of supply of electricity,KSPC entered into coal supply contracts with PT InkorPrima Coal (PT IPC) on July 18, 2011 and PT JayaSamudra Karunia Mining (PT JSKM) on October 13,2011. Copies of KSPC's coal supply contracts are,likewise, attached to the application;
ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 5 of 22
10. KSPC procures its coal requirements from Indonesiasince: (1) it is the cheapest and their specifications arethe most compatible with its requirement for a CFBCcoal plant; (2) China does not export coal anymore andprefers to use their own coal for their own consumption;(3) Australian coal is expensive and its calorific value istoo high for a CFBC type plant; and (4) Philippine coalcalorific value is still higher than that is required by it andthe cost is higher than Indonesia;
11. To reflect the changes in the coal (fuel) base price,KSPC has to add the fuel factor affected by theIndonesian CRP so that the actual cost of fuel will bepassed through to the distribution utilities, pursuant tothe Decisions of the Commission on the "pass through"nature of fuel in the previous applications of KSPC: "theactual fuel cost utilized in generating electricityshould be passed on to the customers [of the DUZ.There should be no cap on the fuel cost to bepassed on to the customers as long as within theefficiency set by the Commission. 11 (Emphasissupplied.) Accordingly, KSPC incorporated in the priceadjustment formula in the PSC in the instant applicationthe Fuel Base Price Factor (f.t), thus:
Old KSPC Price Adjustment Formula:
{ [FCP CF ] FX} [ LCP ]K Ad) = 0.540 + 0.065 x __ n + 0.305 x _n _n + 0.090 x __ nFCPo CFo FX 0 LCPo
New KSPC Price Adjustment Formula:
{ [FCPn CFn] FX n} [ LCPn ]K Ad" = 0.540 + 0.065 x -- + 0.305 x - x Ff - + 0.090 x --
Y FCPo CFo FX 0 LCPo
KAdj = Adjustment factor of KSPC during the Billing Month
" ERC Case No. 2014-116 RCNOTICE/October 22, 2014Page 6 of 22
FCPn = The Arithmetic average of the values of the UnitedStates Producers' Price Index for all items and theUnited States Consumer Price Index (CPI) for all items,both as last published on or before the Adjustment Date(the last day of the billing month) by InternationalMonetary Fund; provided that if the InternationalMonetary Fund ceases to publish such' indices, therelevant indices published by the U.S. Department ofLabor Bureau of Labor Statistics shall apply
FCPa = The Arithmetic average of the values as of January2008 of the United States Producers' Price Index forall items and the United States CPI for all items, bothas published on by International Monetary Fund;provided that if the International Monetary Fund ceasesto publish such indices, the relevant indices published bythe U.S. Department of Labor Bureau of Labor Statisticsshall apply
CFn = BPn + TBPn
CFa = BPa + TBPa
Where:
BPa = shall be the blended rate (FOB + insurance) of thenew Coal Supply Contracts 1
TBP a = shall be the blended transportation rate(transportation + wharfage) of the new Coal SupplyContracts2
Ff = Fuel Base Price Factor = (FBPrlFBPaJ
Where:
FBPn = New Fuel Base Price3
1 Current BPo rate as of 4th Q 2011: USD42.382 Current TBPo rate as of 4th Q 2011: USD21.143 Current New Fuel Base Price of 4th Q 2011: USD63.52
" ERC Case No. 2014-116 RCNOTICE/October 22, 2014Page 7 of 22
FBPo = Old Fuel Base Price4
FXn = Philippines Peso vs. US Dollar exchange rate aspublished by the Bangko Sentral ng Pilipinas at thelast working day of the Billing Month
FXo = An exchange rate of 40.65 Philippine Peso vs. 1.00US Dollar
LCPn = The Arithmetic average of the values of the CPI inPhilippines for all items and General Wholesale PriceIndex in Metro Manila for Mineral fuels, lubricant andrelated materials, both as last published on or beforethe Adjustment Date (the last day of the billing month)by the National Statistics Office (NSO)
LCPo = The Arithmetic average of the values as of January2008 of the CPI in Philippines for all items andGeneral Wholesale Price Index in Metro Manila forMineral fuels, lubricant and related materials, both aspublished by the NSO
Where:
Adjustments to Base Price (BPn)
BPn = shall be adjusted quarterly to reflect the increase ordecrease of the price of Global Coal FOB Newcastleas of the first day of loading as per the formula statedbelow:
BPn = BP x (BIPn_1 J or BP ~ CRPn-l BIJD n
n-2
Where:
BPn = Base Price as of current quarter; computed as performula above, or the current CRP, whichever ishigher
4 Old Fuel Base Price as of 4th Q 2007: USD52.57
ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 8 of 22
BPn-1 = Base Price as of preceding quarters. In case of a newCoal Supply Contract, the initial BPn-1 shall be theblended rate (FOB + insurance) of the new CSC
BIPn-1= Base Index Price as of preceding quarter
BIPn-2= Base Index Price as of preceding quarter to BIPn-1
CRP = the CRP provided by the MEMR as determinedannually per CSC anniversary date, which is FOBonly
• The quarter shall refer to a calendar quarter
• Base Index Price shall be the quarterly average of theGlobal coal physical index, FOB Newcastle. For thereference, the initial BIPn-2 shall be USD83.23 per ton
• The initial price adjustment shall be made on the FirstDelivery Date and which shall be effective until the end ofthe quarter of the First Delivery Date
• The next price adjustment after the First Delivery Date willbe on the next calendar quarter and the price shall beadjusted on the first day of every quarter thereafter
• Any applicable and export-related taxes, duties, and othercharges imposed by the respective governments of theexporters shall be added to the coal Base Price of eachsupplier/exporter under the CSC's while any applicable andrelated taxes, duties, and other charges imposed by anyGovernment Authority having jurisdiction over either of theparties shall be added to the blended Base Price as ofcurrent quarter (BPn)
• The coal Base Price for each shipment of coal suppliedby the supplier CFR hereunder to the Seller's deliverypoint at the Cebu Power Plant shall be the Base Price,as applicable to that shipment and adjusted in
5 Initial BPn-1 for the current esc as of 4th Q 2011: USD42.38
" ERC Case No. 2014-116 RCNOTICE/October 22, 2014Page 9 of 22
accordance with the immediately preceding formulaunder this Annex F of the PSC (Base Price); provided,however, that if such coal Base Price is less than theapplicable Coal Reference Price, the coal Base Priceshall be equivalent to the applicable Coal ReferencePrice
Adjustment of Transportation Base Price (TBPn)
TBPn = shall be adjusted quarterly to reflect the increaseor decrease of the price of Marine Diesel Oil as of thefirst day of loading as per the formula stated below:
Where:
TBPn
TBPn-1
BBPn-1
BBPn-2
750/0
250/0
=
=
=
=
=
=
TBP as of current quarter
TBP as of preceding quarter6. In caseof a new Coal Supply Contract, theinitial TBPn-1 shall be the blendedtransportation rate (transportation +wharfage) of the new Coal SupplyContracts
Bunker Basis Price in US cents as ofpreceding quarter
Bunker Basis Price in US cents as ofpreceding quarter to BBPn-1
Fixed Cost
Variable Cost
6 Initial TBPn_tfor the current esc as of 4th Q 2011: USD21.14
c' ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 10 of 22
• The quarter shall refer to a calendar quarter
• Bunker Basis Price shall be the quarterly average of thePertamina Publicly Listed Price Index for Marine Diesel Oilposted in PI. Pertamina. website (www. pertamina-bunker.com). For the reference, the initial BBPn-2 shall beUS 0.8018 per liter
• The initial price adjustment shall be made on the FirstDelivery Date and which shall be effective until the end ofthe quarter on the First Delivery Date
• The next price adjustment after the First Delivery Date willbe on the next calendar quarter and the price shall beadjusted on the first day of every quarter thereafter
• The Transportation Base Price for coal shall include thecost of wharfage
12. Below is a comparison of the change in the Fuel andTransport Prices brought about by the change in theIndonesian CRP:
Fuel Base and Transport Price, $/IVITPrevious Contract New Contract
RemarksTermination of CSCwith PT Kasih due topassage of MEMRregulations and non-compliance;termination ofMGMEC CSC dueto inability ofMGMEC to deliverbecause ofproblems with theirmine operations
Base Price for nowis now required tobe equal to or higherthan the coalreference priceissued by the MEMRof Indonesia as ofthe execution dateof the coal supplycontract and everyanniversary thereof
ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 12 of 22
DeliveryTerms
Laycan days nowallowed (numberof days when thevessel is allowedto arrive beforeBuyer has theoption ofcancelling aparticulardelivery)
14. The new base coal price under the new coal supplycontracts are as follows:
As referred PSC Heat Rate of 4,165kcal/kWei hted Avera e New Contract
FOB42.12
Heat RateTotal62.51 4,165
FOB + Insurance; Trans 0 + wharfa eFOB Trans o. Fuel Total42.38 21.14 63.52
15. Details of the procurement process of fuel. KSPCprocured its supply contracts through international publicbidding. Its procurement process is attached to theapplication;
ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 13 of 22
Abstract of the APSC and Related Information
16. Executive Summary. The Executive Summary of theAPSC is, likewise, attached to the application.
Additional terms in the APSC:
"CFR" means, with respect to a destination port, "Costand Freight" as defined under INCOTERMS 2010.
"Coal Reference Price" or "CRP" means a coal price.including any and/or all price changes. imposable taxes,fees, imposts, charges. others associated costs, asrequired by the MEMR of Indonesia or any otherGovernment Authority of any country affecting theSeller's coal supply contracts.
"First Delivery Date" has the meaning given to that termin the coal supply contracts entered into by the Sellerwith its coal suppliers; provided, that where there aredifferent First Delivery Dates under such coal supplycontracts, the latest of such dates shall be the FirstDelivery Date for purposes of the PSC.
"Governmental Authority" means the Republic of thePhilippines, any province, city, municipality or otherpolitical subdivision, agency, authority, board, bureau,commission, court, department, instrumentality of anycountry or any other foreign Governmental Authorityhaving jurisdiction or relation over either of the Parties,their respective property and assets, the performance ofobligations under the PSC or having the power orauthority to affect any aspect of the PSC.
"Ministry of Energy and Mineral Resources" or"MEMR" means the political subdivision, agency, board,bureau, commission, department, instrumentality orGovernmental Authority in Indonesia, having jurisdictionover the coal supply arrangements between the Sellerand its coal suppliers and the performance of theirrespective obligations under said coal supplyarrangements, or any other successor Governmental
" ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 14 of 22
Authority having the same jurisdiction or exercising thesame powers.
New Paragraph in the "Monthly Payment" Provision:
A new paragraph in the Amendment to the PSC isadded to Article 7.2, as Article 7.2((i)] as follows:
"The Monthly Payment shall be subject to any and/orall adjustment on the Base Price for coal. In case anyprice changes, taxes, fees, imposts, charges or otherassociated costs is implemented under any newcontract, or under any other law, ordinance or regulationby any Government Authority or any agency orinstrumentality of any country affecting the Seller's coalsupply contracts or the application of and computationapplicable to the coal price, such price changes, taxes,fees, imposts, charges, and other associated costs shall,upon the giving of notice by the Seller to the Buyer, bedeemed incorporated to this Power Sales Contract andshall entitle the Seller, without need of any further noticeor action to, or any approval or consent by, the Buyer toadjust the Monthly Payment in accordance with thisparagraph and under Annex F (r) based on suchchanges; provided further, that the Base Price for coalshall include the shipment's insurance cost while theTransportation Base Price for coal shall include the costof wharfage."
New Annex F (Annex F[r]) on the KSPC PriceAdjustment Formula. Annex F of the PSC and thePSC IA in each case hereby replaced in whole by AnnexF (r) as attached to the APSC.
Effect of Amendment
"Except as specifically modified by this Amendment, allterms and provisions of the Power Sales Contract, aspreviously amended and supplemented, shall remain infull force and effect. From and after the date hereof, allreferences in the Power Sales Contract to "thisContract," "hereof," "herein," and other words of similarimport shall be deemed to refer to the Power Sales
ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 15 of 22
Contract, as previously amended and supplemented,and as modified by this Amendment, and the PowerSales Contract with all its subsequent amendments andsupplements shall be read and construed with thisAmendment as one integrated document incorporatingthe amendments effected hereby."
Change in Circumstance. The Parties hereto agreethat "Except as specifically provided in Section 2(b)hereof (APSC), if, as a result of any Applicable Lawcoming into effect after the signing of this Amendment,or as a result of any such Applicable Law (including anyofficial interpretation thereof which the Seller has reliedupon in entering into this amendment) in force at thedate hereof being amended, modified or repealed, theinterest of the Seller in the Site, the Project or the CebuPower Plant or the Seller's economic return on itsinvestment is materially reduced, prejudiced or otherwisematerially affected, or when the amended contractmaterially affects the interest of the Buyer due to greateffect of the fuel base factor, the Parties hereto shallmeet and endeavor to agree on the necessaryamendments to the PSC, and if after 60 days no suchagreement has been reached then either Party may,upon giving to the other not less than 30 days' notice,terminate the PSC".
17. Adoption of the PSC and the Decision of theCommission.
All terms and conditions in the PSC between the partiesand as approved by the Commission, shall be in fullforce and effect except as specifically modified by theAPSC;
Rate Implications of the PSC
18. The following table shows the impact of the new FuelBase Price on the generation rates paid by thedistribution utilities in the Visayas:
.' " ERC Case No. 2014-116 RCNOTICE/October 22, 2014Page 16 of 22
Current NPC
Generating Company Charges Rate Proposed(as of June KSPC Rate
21. Board Approval. APSC and the joint filing of the instantapplication have been approved by the board ofdirectors of applicant CEBECO I. A copy of CEBECO I'sResolution on the approval of the APSC and the jointfiling of this application is attached to the instantapplication;
Motion for the Issuance of Provisional Authority toAdopt the New Fuel Base Price and the Fuel Factor
in the KSPC Price Adjustment Formula
22. The APSC will not terminate, suspend or in any wayaffect their PSC as approved by the Commission and asimplemented and continue to be implemented by them,save for the new fuel base price and the fuel base pricefactor brought about by the Indonesian MEMR, which isthe subject matter of the instant application. It is in thisregard that, pending the final approval of the instantapplication, they request that they be allowed to adoptthe new fuel base price and the fuel base price factor inthe KSPC price adjustment formula;
ERC Case No. 2014-116 RCNOTICE/October 22, 2014Page 19 of 22
23. Since the implementation of the Indonesian MEMR,KSPC has been incurring losses since September 2011.As of October 25, 2013, it already incurred a total loss ofPhPB42,362,546.51 and it will continue to incur morelosses without the proper intervention of theCommission. Below is the table showing the effect ofthe Indonesian MEMR on it without adopting the newfuel base price and the fuel base price factor for all beingcustomers;
TOTAL 149,065,100,00 1.5111 225,901,718.26 276,801,103.93 82% Total Loss
ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 21 of 22
24. Without provisional authority prayed for, KSPC willcontinue to incur losses. Thus, they are constrained torequest for a provisional authority to adopt andimplement the new fuel base price and the fuel baseprice factor in the KSPC price adjustment formula toavoid further losses detrimental to the continuedoperation of KSPC. Moreover, being a base-load energysupplier of CEBECO I, it would be in the best interest ofboth parties to acquire the requested provisionalauthority at the earliest possible time; and
25. Thus, they pray that:
a) Their motion for the issuance of provisionalauthority allowing KSPC to adopt and used thenew fuel base price and the fuel base price factorin its Price Adjustment Formula be approved priorhearing and issuance of final authority; and
b) Their APSC be approved by the Commission.
The Commission has set the application for jurisdictionalhearing, expository presentation, pre-trial conference andevidentiary hearing on November 21, 2014 (Friday) at nine-thirtyin the morning (9:30 A.M.) at the CEBECO I Multi-Purpose Hall,Main Office, Bito-on, Dumanjug, Cebu.
All persons who have an interest in the subject matter of theproceeding may become a party by filing, at least five (5) days priorto the initial hearing and subject to the requirements in the ERC'sRules of Practice and Procedure, a verified petition with theCommission giving the docket number and the title of theproceeding and stating: (1) the petitioner's name and address; (2)the nature of petitioner's interest in the subject matter of theproceeding, and the way and manner in which such interest isaffected by the issues involved in the proceeding; and (3) astatement of the relief desired.
• ERC Case No. 2014-116 RCNOTICE/October 22,2014Page 22 of 22
All other persons who may want their views known to theCommission with respect to the subject matter of the proceedingmay file their opposition to the application or comment thereon atany stage of the proceeding before the applicants conclude thepresentation of their evidence. No particular form of opposition orcomment is required, but the document, letter or writing shouldcontain the name and address of such person and a concisestatement of the opposition or comment and the grounds reliedupon.
All such persons who may wish to have a copy of theapplication may request the applicants, prior to the date of the initialhearing, that they be furnished with a copy of the application. Theapplicants are hereby directed to furnish all those making suchrequest with copies of the application and its attachments, subject toreimbursement of reasonable photocopying costs. Likewise, anysuch person may examine the application and other pertinentrecords filed with the Commission during the usual office hours.
WITNESS, the Honorable Chairperson, ZENAIDA G. CRUZ-DUCUT, and the Honorable Commissioners, ALFREDO J. NON,GLORIA VICTORIA C. YAP-TARUC, and JOSEFINA PATRICIA A.MAGPALE-ASIRIT, Energy Regulatory ommission, this 22nd dayof October, 2014 at Pasig City.