The Philippine Energy Regulatory Commission (ERC) has published a consolidated matrix of stakeholder comments on the draft Philippine Grid Code (PGC) 2026 Edition under ERC Case No. 2025-015 RM, marking an important step in the ongoing review of the country’s grid regulations. The document brings together feedback from a wide range of power sector stakeholders, including distribution utilities, generation companies, transmission network operators, and government agencies, highlighting key concerns and recommendations aimed at improving the proposed code.
One of the main areas of discussion is the governance framework, enforcement mechanisms, and derogation procedures outlined in the draft Grid Code. Several stakeholders, including MERALCO, AboitizPower, and NAC Energy, expressed concerns over regulatory definitions that they believe are unclear and may create confusion during implementation. They also questioned how responsibilities should be divided between the ERC and the Grid Management Committee (GMC), calling for clearer guidance to avoid overlapping roles.
Derogation procedures, which allow entities to request temporary or permanent exemptions from specific Grid Code requirements, received significant attention. Industry participants emphasized the need for a more transparent and efficient approval process. NAC Energy and AboitizPower specifically recommended removing provisions that require prior endorsement from the Transmission Network Provider (TNP) or the System Operator (SO) before applications can proceed. According to the stakeholders, these requirements could give network operators excessive influence over other grid users and may unnecessarily delay approvals.
Technical standards and operational performance requirements also generated extensive feedback. Power generation companies recommended retaining the existing market definitions for Ancillary Services, including Regulating Reserve, Contingency Reserve, and Dispatchable Reserve. They argued that the proposed replacement categories of Primary, Secondary, and Tertiary Reserves have not yet been implemented in actual electricity market settlements and could create uncertainty if adopted prematurely.
Distribution utility CEPALCO identified several technical inconsistencies within the draft code. These include conflicting response time requirements for Fast Frequency Reserve and overlapping voltage transient limits. The utility suggested presenting technical parameters in tabular format to improve readability, reduce confusion, and help regulated entities comply with the requirements more effectively.
Several renewable energy developers and generation companies also requested greater clarity on compliance obligations for existing power facilities. AboitizPower and ACEN proposed adding a formal definition of “Legacy Plants,” referring to facilities that were energized before the implementation of the 2016 Philippine Grid Code. They argued that such a definition would prevent older plants from being required to comply retroactively with new technical standards that could involve substantial additional investment.
The stakeholder comments also reflect the growing importance of integrating renewable energy technologies into the Philippine power system. Companies including ACEN, SNAP, and CEPALCO sought further clarification on technical requirements covering frequency withstand capability, reactive power performance, and the role of Grid-Forming (GFM) inverters in maintaining system stability as renewable energy capacity continues to expand.
In addition, transmission and distribution utilities raised operational concerns related to System Impact Studies, standardized timelines for grid interconnection approvals, emergency transformer replacements, and the scope of cybersecurity requirements governing SCADA and telemetry systems. The consolidated feedback is expected to help the ERC refine the Philippine Grid Code 2026 Edition before its final adoption, ensuring that the updated framework supports grid reliability, operational efficiency, and the country’s transition toward a more modern and renewable-based electricity system.
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