The Department of Energy (DOE) is pushing for revisions in the guidelines that must be followed by power plant owners and operators so they can prospectively limit the testing and commissioning of their facilities within a two-month span – a phase that the electric generating units would have to go through before reaching commercial operations.

The proposed amendments target to harmonize the timeframes as well as the systems and processes before injecting the capacity of newly built power projects into the grid, that way supply disruption and service interruptions to consumers can be avoided.

The DOE said the policy re-tooling is a necessary step because the Market Surveillance Committee of the Wholesale Electricity Spot Market (WESM) reported that within March to April this year, “97.1-percent of instances of imposition of over-riding constraints (in the spot market) can be attributed to test and commissioning of generating units.”

As proposed in the guideline tweaks, the maximum period for generation facilities to conduct test and commissioning shall be for two (2) months – and such must be carried out for purposes of securing certificate of compliance (COC) from the Energy Regulatory Commission.

The COC is the license that a generating facility developer or operator will need to obtain from the regulatory body before it could declare commercial operation of its power plant.

The DOE cited that based on data from the Independent Electricity Market Operator of the Philippines (IEMOP), about 38 plants “were recorded to be on test and commissioning status in the WESM for more than two months” – and the longest so far had been for five (5) years. And from those testing and commissioning activities, there had been instances that these instigated ‘overcrowding’ in the system.

The energy department explained that “the extended test and commissioning of generating facilities pose material effect to WESM outcomes by dispatching scheduled generators while not being required to comply with the mandatory requirements in the submission of offers or projected outputs.”

The DOE added “determining the definite status of power plants intending to transition to commercial operations is crucial information in planning for short- and medium term supply.”

The department thus stipulated “there is a need among various agencies involved in the processing of requirements for commercial operations of generation companies to harmonize their procedures and monitoring activities.”

In carrying out the pre-commercial operation activities, it was prescribed that the generation company must first secure certificate to conduct test and commissioning (CTCTC), and this has to be issued also by the ERC.

And before pursuing that activity in the power facility, it is mandated that the generation company must advise all relevant stakeholders at least six months prior to its target date of testing and commissioning.
“A generation company shall commence test and commissioning only upon attainment of electromechanical completion of its generation facility,” the propounded guidelines stated.

It was further noted that “at the minimum, the generation company shall submit a certification under oath to the DOE signifying that electromechanical completion has been achieved.”

Electromechanical completion entails that the generating unit, including all substation and other facilities for grid or distribution system connections are in place but not yet connected – and that the generating unit is ready for testing and commissioning.