MEMORANDUM CIRCULAR 2020-05-0001
Directing All Designated Establishments under Commercial, Industrial, and Transport Sectors to Submit Energy Consumption Reports
FREQUENTLY ASKED QUESTIONS (FAQs)
(As of May 2021)
1. How many Form 3 do we need to submit? Is it for the last 5 years or 2020 only?
- For the Annual Energy Utilization Report (AEUR Form 4) the reports must cover the following Calendar Year (CY) period:
CY 2015, CY 2016, CY 2017, CY 2018, CY 2019, and CY 2020
- For the Annual Energy Efficiency & Conservation Report (AEECR Form 3) the report must cover only the CY 2021.
- For the Registration of Energy Conservation Officer (ECO) or Energy Manager (EM), Use Form 1 for ECO (Type 1 DE) and Form 2 for EM (Type 2 DE)
DE – Designated Establishments
Type 1 DE – Annual Energy Consumption of 500,000 kWhe to 4,000,000 kWhe
Type 2 DE – Annual Energy Consumption of more than 4,000,000 kWhe
2. For establishment that open for example January 2016, what should be the fiscal year that will be submitted to DOE for the form 4?
- Based on the recent DOE Advisory, we will no longer use Fiscal Year (FY) instead it will now be Calendar Year (CY). CY refers to the months of January to December of the year being reported.
- If the establishment started just only in 2016, then it must have to submit the Calendar Year reports as follows: CY 2017, CY 2018, CY 2019, CY 2020
3. As commercial, for the past five years, do we need to submit one set of filled up forms every year? Or one set of form for the whole 5 years?
- As required under RA 11285 and its governing IRR, MC2020-05-0001 and DOE Advisories; Des are required to submit one set of filled-up Forms (3&4) every year.
Submit filled up Form 4 or the Annual Energy Utilization Report (AEUR) covering the period CY 2015, CY 2016, CY 2017, CY 2018, CY 2019, CY 2020
Submit filled up Form 3 or the Annual Energy Efficiency and Conservation Report (AEECR) for the CY 2021.
4. In the distribution utility, is it the RES or DU to declare?
- RES and DUs must first submit to DOE using Forms 1 or 2 for their designated/appointed Energy Conservation Officer (Type 1) or Energy Manager (Type 2), respectively, as the case maybe. RES and DUs must fill-up Form 3 (AEECR) and Form 4 (AEUR), declaring the Energy consumption and other data sets of information of their Office Building and facilities. For this reporting period, the AEECR must cover the period CY 2021 and for AEUR, it must cover the periods CY 2015, CY 2016, CY 2017, CY 2018, CY 2019, and CY 2020.
5. For a mixed-use building Hotel and Condominium how are we going to submit the report? Should it be a separate form? How about the CEM?
- For Building use FORM 3 or the Annual Energy Efficiency & Conservation Report (AEECR) reporting for CY 2021. Use Form 4 or the Annual Energy Utilization Report (AEUR) when reporting for the last five years starting CY 2015, CY 2016, CY 2017, CY 2018, CY 2019, and CY 2020.
- For mix use building, report only the common areas in the condominium including the entire Hotel covered floor area which is directly controlled by the developer’s property management services.
- For the CEM, use the registration Form 2 when the energy consumption threshold is above 4 million kWh per year or Type 2 DE.
6. If no on-going project this year, does Target and Projected will be the same?
- If there is no on-going project, then leave the field blank or put remarks no on-going projects.
- The Target and Projected is meant for your EE&C Plan for the calendar year reported. If there is nothing to write it means your establishment has no EE&C Plans in place for the rest of the months of 2021. The EE&C Plan must be developed by the DE’s appointed Energy Conservation Officer or by the Energy Manager. The EE&C Plan Target is included in the requirement in Section 20 (c) of RA 11285 under the Obligations of the DEs.
7. How about if we already stop the usage of our boiler, do we still need to put it on the data? we did not use our boiler since 2018?
- No need to report the boiler, if said equipment was not anymore part of the process operation.
8. What is the basis when we say, “project is completed”?
- It means that after the project had undergone series of testing and ready for commissioning to the owner. The next step is the issuance of a project completion report that declaring it was already completed and ready for commercial operation.
9. What if your available data is starting 2018 until this year only? And how will DOE know if the reports submitted are true?
- The AEUR reports must be CY 2019 and CY 2020.
- There will be time when DOE personnel will conduct physical visit to the establishments and request for the energy data records and other related documents as required in the reports (Section 23 of RA11285). The ECO or EM has the responsibility to see to it that records of this kind must be readily available when DOE surveillance personnel arrived in the facility.
- In case there was a willful and real intention that the report being submitted are not true or spurious in nature, the DOE Legal Service will write to the highest Official of the company no less than the President of the company or CEO, to explain the reasons for providing such inaccurate information in the reports. Section 31, 32 and 33 of RA 11285 may possibly apply in this case (penalty clause provision of the Act).
10. How about we do not have sub metering on our production?
- The long terms solution is to install a sub-meter at the Main Distribution Panel (MDP).
- For now, you can go by the process of load computation for each equipment or devices used in the facility relative to the number of hours of operation.
11. How is the number of employees computed? 1 year or 1 month?
- It is not computed. Kindly refer to your Human Resource Office and request for the list of the company’s personnel working in the facility or building.
12. How to determine energy savings when you do not have separate metering for the target area or equipment? Can it be assumed or calculated based on rating or type, ex. inverter at 30%?
- Compute for the energy consumption of each equipment using the Name Plate Rating and get the KW capacity and multiply it by the number of hours of operation.
- Do not use assumption if you have no technical basis for the 30%.
- The long-term solution is to install sub meter in the Main Distribution Panel where this equipment terminates.
13. What should be included in the waste oil report?
- Waste oil includes those from the Diesel Engine of the Generator, service trucks and vehicles of the facilities, and from other similar machines that requires oil and regular oil change.
14. Do we need to include the number of employees of the mall’s tenant?
- Employees of the Tenant are not included.
15. We have 2-plant with separate Meralco meter per plant. Is it okay to have the total power consumption for our data?
1. If the two (2) plants are in a complex area and an integral part of the production process, then it can be reported as one in the report. For example, an Integrated Steel Mill plant which has all the primary functions for steel mill production: iron making, steel making, casting, roughing rolling/billet rolling, and product rolling.
Similarly, in the case of a Sugar Manufacturing their main production is raw sugar (muscovado and brown sugar) and white sugar. Another facility plant is integrated in the complex which is alcohol production or distillery.
2. However, if the plant is operated independently from each other with different Plant Manager managing its operation, then it is wise to report it separately.
3. However, if the Top Management opted to designate or appoint one (1) Energy Manager (EM) to manage these two (2) plants, then the EM can prepare one (1) enterprise report containing a disaggregated report for Plant 1 and Plant 2.
16. Is the coverage for the completed energy conservation program for five years only?
- Yes, at least in the last five years for the completed energy conservation programs and projects implemented.
17. Can I include downgrading of GMBD as my completed projects? For example, from 1200Kw to 500Kw? and my savings is 700kw per month, thank you
- You can include downgrading if it is part of the overall strategy to conserve and operate efficiently.
- Take note that the unit kW refers to the capacity of the equipment or devices, while kWh is the energy consumption of an equipment / device over a period (Hour) of its operation
18. For commercial sector/hotel, we have 3 buildings with different electric meter, 2 is being utilize as accommodations and the other 1 as function hall/events, do we have to submit 3 sets of form? Thank you.
- Option 1: If the hotels and the hall/event are located on different places or location then it must be reported separately.
- Option 2: If the 3 buildings are adjacent to one another and / or within in a complex area, it can be reported as one enterprise report containing disaggregated reports of these 3 buildings. Moreover, the Top Management can designate / appoint one (1) Energy Conservation Officer (ECO) if the establishments are a Type 1 DE (100,000 kWh – 4,000,000 kWh per annum) or and Energy Manager if the establishment is a Type 2 DEs (4,000,000 and above consumption annually)
19. In our company we do not have per activity area metering, we only have separate metering every tenant we have. I am going to declare it as Activity area every Tenant.
- Report only the common areas wherein the developer’s management property or administrator had controlled over these areas. Tenants are not required to be included in the report.
20. As per Schneider website, their power meters do not require periodic calibration, since they are calibrated before they left the factory only in extreme case, they had to be returned to the factory, do you agree?
- The operation manual and the calibration schedule of the power meter. Provide the next periodic calibration date of this equipment. If there is nothing in there, then request Schneider the results of its last calibration date to tack down when should be the next calibration date of this equipment.
21. Can we ask for definition of terms?
- Please refer to MC 2020-05-0001. Download at DOE website under Energy Efficiency under laws and issuances.