Compliance, Coordination, and Conflict: Examining Renewable Energy Policy Mechanisms in the Philippine Energy Plan

Abstract

The Philippines, a country with abundant natural resources, has set a high 35% renewable energy (RE) share target by 2030. However, progress is slow with the implementation of its key policy mechanisms. Through the years, the Department of Energy has slowly increased the goals from 30% to 35% by 2030 and even up to 50% by 2050%. The key legal framework for the Philippine Renewable Energy sector is the Renewable Energy Act of 2008, which outlines key policy mechanisms: Renewable Portfolio Standards (RPSs), Net Metering, the Green Energy Auction Program (GEAP), and the Green Energy Option Program (GEOP). This paper analyzes the implementation and enforcement of the key policy mechanisms along with factors affecting their intended rollout. Along with the policy mechanism issues, this paper highlights key institutional and structural issues for the stakeholders of the RE sector. The main issues can be attributed to the incoherence of government agencies such as the Department of Energy (DOE), the Energy Regulatory Commission (ERC), and the National Grid Corporation of the Philippines (NGCP). Other issues include insufficient transmission infrastructure, resistance from Distribution Utilities (DUs) and Electric Cooperatives (ECs), and weak Local Government Unit (LGU) participation. The paper provides recommendations on the key issues of policy mechanisms and structural and institutional bottlenecks. The main recommendations that will help achieve the intended purpose of the drivers of RE are to strengthen the National Renewable Energy Board (NREB) and other agency capabilities, provide financial incentives to utilities, streamline permitting and other processes, and prioritize grid development for areas with RE development. For the targets of the DOE to be achieved, the main drivers for the RE sector must be revisited and fixed at their core. Achieving the RE targets of the DOE will need strong leadership and sustained focus on renewable energy development led by the government.

1. Introduction

The Philippines, with its geographic landscape, has considerable renewable energy growth potential, but it has been facing hurdles in development and sustainability. The Philippine Energy Plan (PEP) by the Department of Energy (DOE) is a national framework made of long-term energy goals. In the 2012–2030 PEP, goals were set to 30% by 2030. In the next 2016–2030 PEP, the targets were raised to 35%, as highlighted in Figure 1. The current PEP 2023–2050 aims to achieve a 35% RE generation share from 22.1% in 2022 [1]. This development goal is aligned with the Philippines’ Nationally Determined Contributions (NDCs) to reduce greenhouse gas emissions by 75% by the year 2030 [2]. The Philippines has great policy goals, but its implementations are hampered. The ASEAN Post shows that power generation in 2018 is primarily from coal at 52% while RE is only 22% [3]. The gap between actual implementation and policy goals shows how policy implementation is currently lagging behind the country’s objectives.

Moreover, aligned with contributing to the NDCs, the Philippines’ action toward higher renewable energy targets is also brought about by extreme climate vulnerability. The Philippines is among the most vulnerable, ranking 17th in the world in the 2021 Global Climate Risk Index [4]. The Philippines commonly experiences floods and typhoons, prompting the need for the improvement of resilient and improved energy systems. Another commitment that drove the change to higher targets is the country’s commitment to the UN SDGs, specifically SDG 7, which aims to provide citizens with affordable, reliable, and sustainable energy [5]. With the increased RE targets, expanding RE capacity will help reduce emissions, reduce reliance on coal, and provide better energy access and reliability. Furthermore, the constant pressure from the public and civil society has affected and continues to affect national energy discourse for the betterment of the country. Campaigns done by NGOs such as the Center for Energy, Ecology, and Development (CEED) and WWF-Philippines called for reduced reliance on fossil fuels. They pushed for the shift to renewable energy [6,7]. Attention from such advocates raises awareness about renewable energy and helps pressure stakeholders to increase long-term targets.

Table 1. Electricity generation mix 2024.

Source	Percentage
Coal	62.5%
Gas	14.1%
Other Fossil Fuels	1.7%
Hydropower	8.6%
Wind	1%
Solar	2.9%
Geothermal	8.2%
Biofuels	1%

shows the Philippines’ electricity generation mix as of 2024 [8]. The figure shows how the Philippines mainly uses fossil fuels, with coal dominating the energy mix at 62.5% despite the goals of the Renewable Energy Act of 2008. In totality, fossil fuels cover 78.3% while renewable energy only covers 21.7% far from the 2030 goals in the PEP of a 35% RE share. The electricity generation mix shows how hydropower and geothermal sources account for most of the RE share, with solar lagging behind. The Philippine electricity generation mix shows the continued dependence on coal and fossil fuels despite RE efforts.

The percentage of different types of electricity generation from 2003 to 2024 based on DOE power statistics can be seen in Figure 2 [9]. It can be seen that coal has been increasing in share while RE is decreasing from 33.4% to 22.2%. A moratorium was placed on coal in 2020, but the data shows how coal is still increasing while the share for RE is stagnant, indicating that the development of RE is failing to keep up with the development of coal.

The electricity generation in GWh from coal and RE sources from 2003 to 2024 from DOE power statistics is shown in Figure 3 [9]. Coal electricity generation grew from 14,939 GWh to 79,359 GWh with a total growth of 431%, while RE only increased from 17,692 GWh to 28,193 GWh for a total growth of 59%. The data shows how the developments of coal significantly outpace RE developments. RE developments are slowly ramping up as seen in the years 2020 to 2024. This can be attributed to the inflow of RE developments and the rollout of GEAP 1 and 2.

Figure 4 and Figure 5 show the increase in electricity generation per type of renewable energy from 2015 to 2024 based on DOE power statistics [9]. The graph shows solar leading the change towards RE, with hydro sources coming in second. For percentages, solar has the most growth with a total growth of 2642%. Hydro, despite being the second-highest in terms of GWh, only grew 26% because of the already existing hydro projects. The growth in solar developments can be attributed to the improvements in solar energy and the availability of locations for solar farms as compared to the limited locations for hydro, wind, and geothermal plants.

The development of renewable energy in the Philippines is covered by legal and institutional frameworks such as the Republic Act No. 9513 or the Renewable Energy Act of 2008, which covers the necessary legalities in promoting RE development through policy mechanisms. The policy mechanisms covered in RA 9513 are Renewable Portfolio Standards (RPSs) through DC2017-12-0015, the Net Metering Program under the 2013 Implementing Rules and Regulations of RA 9513, the Green Energy Auction Program (GEAP) through DC2021-06-0015, and the Green Energy Option Program (GEOP) through DC2018-07-0019. The policies aim to accelerate RE generation, adoption, and development. The four policy mechanisms mentioned are key in driving the shift to RE, which helps achieve the goals of the Philippine Energy Plan.

On paper, the policy mechanisms seem like forward drivers for renewable energy. However, in reality, the implementation of such policy mechanisms shows a multitude of obstacles. Compliance with RPS is low, with only a few electric cooperatives (ECs) and distribution utilities (DUs) following the required RE percentage due to limited available RE sources, with the DOE calling on RE developers to start increasing the development of new projects [10]. Net metering is not being adopted well due to issues such as resistance from DUs, flawed application processes, and low incentives, as seen in Iloilo City, where only 72 have qualified for the program as of 2023 [11]. GEAP showed initial potential through more than 2 GW in RE projects for 2022 but raises concerns due to underdevelopment, with only around 3.5 GW out of 11.6 GW in 2023 [12]. GEOP also shows low adoption due to limited knowledge of the program and the required processes and regulations [13]. The policy mechanisms all show poor implementation and enforcement of what was supposed to be the driving force for RE adoption and development.

The issues in the implementation of RE policy mechanisms go beyond financial and technical issues, highlighting a bigger problem lying within the Philippine energy framework. The International Renewable Energy Agency (IRENA) and the Institute for Climate and Sustainable Cities (ICSC) covered structural and institutional issues with agencies like DOE, ERC, and NEA [14,15]. Oversights from agencies resulted in weak implementation and enforcement of the mandated RE policies, as well as changing power dynamics with private and local government. Moreover, the Philippine Energy Plan emphasizes the role of private investments in achieving RE goals but overlooks the role of regulations and institutional coordination. With this, the poor implementation and enforcement of RE policy mechanisms is an effect of the wide range of structural and institutional issues caused by incoherence in governance.

This study is limited to qualitative analysis on available data and reports from different government agencies and non-governmental organizations. A comprehensive examination of information has been conducted, but several constraints have been identified, including transparency issues and inconsistent reporting. As a result, some key figures are not available, such as DU RPS compliance data, GEAP development reports, LGU permit data, and real-time RESC and REC figures. Furthermore, no interviews and surveys were conducted during this study, focusing primarily on available data. This study does not include quantitative simulations such as economic forecasting, as it focuses on policy review.

This study applies a novel three-dimensional root cause framework on technical, political, and institutional aspects to assess the slow RE progress of the Philippines toward PEP 2023–2050 targets. A deep dive on key policy mechanisms is explicitly done on Renewable Portfolio Standards (RPS), Net Metering, the Green Energy Auction Program (GEAP), and the Green Energy Option Program (GEOP). Understanding the issues hindering the proper rollout and adoption of key policy mechanisms meant as drivers for RE development and adoption highlights the root causes behind the slow progress of the Philippines. Other structural and institutional issues are also explored and cross-referenced with policy mechanisms issues to better identify deep-rooted issues through qualitative policy analysis, document reviews, stakeholder mapping, and descriptive data analysis. This study aims to identify the core issues hampering the implementation and enforcement of RE policy mechanisms, examine connections of mechanism issues with structural and institutional issues, and develop an integrated view of the complex core issues along with possible solutions. The main contribution of this study is the use of a novel three-dimensional root-cause framework and comprehensive coverage of issues in policy mechanisms and structural issues, along with targeted reforms to remove the barriers and bottlenecks hampering RE development from reaching the 2030 PEP RE targets.

2. Materials and Methods

The primary materials of this study are legal policy documents, such as laws and department circulars, which provide legal and institutional information on the Philippine RE sector and its specific policy mechanisms. Secondary materials, such as review reports, provide technical information and report progress and performance. The sources used provide the foundation for qualitative analysis of RE development performance. The materials are outlined in

Table 2. Materials.

Material	Topic
Republic Act No. 9513—Renewable Energy Act of 2008 [16]	RE legal framework
Republic Act No. 9136—Electric Power Industry Reform Act of 2001 [17]	Electric power industry reform
Republic Act No. 11234—Energy Virtual One-Stop Shop Act of 2019 [18]	Energy permit platform
Implementing Rules and Regulations (IRR) of RA 9513 (2013) [19]	Net Metering
Department Circular (DC) 2017-12-0015 [20]	Renewable Portfolio Standards (RPS)
Department Circular (DC) 2022-09-0030 [21]	RPS increase to 2.52% annual increase
Department Circular (DC) 2021-06-0015 [22]	Green Energy Auction Program (GEAP)
Department Circular (DC) 2018-07-0019 [23]	Green Energy Option Program (GEOP)
Philippine Energy Plan (PEP) 2023–2050	National energy targets
Nationally Determined Contribution (NDC) Implementation Plan 2020–2030	Climate RE commitments
Transmission Development Plan (TDP)—latest edition	Grid Development Targets
Center for Energy, Ecology, and Development (CEED)—Energy Policy Review Reports (2019)	Philippine RE progress review
CEED—Corporate Shift to RE: Philippine Private Sector Demand for Green Power (2024)	Private sector demand review
WWF-Philippines—Towards Transformational Renewable Energy Policy in the Philippines (2020)	Roadmap for RE transition
WWF-Philippines—Monitoring Renewable Energy Implementation in the Philippines (MoRE) Project: Policy Brief (2024)	RE implementation review
International Renewable Energy Agency (IRENA)—Renewables Readiness Assessment: The Philippines (2017)	RE readiness assessment
IRENA—Southeast Asia Energy Transition Report (2023)	Southeast Asia RE trend report
Institute for Energy Economics and Financial Analysis (IEEFA)—Barriers to Clean Energy Financing in the Philippines (2021)	RE financial barriers review
Asian Development Bank (ADB)—Philippines Energy Sector Assessment, Strategy, and Road Map (2023)	RE integration review
Organisation for Economic Co-operation and Development (OECD)—Clean Energy Finance and Investment Roadmap of the Philippines (2024)	RE investment growth plans

along with the topics they cover. The primary materials show the long-term goals of the nation and the respective set targets, such as those included in the Philippine Energy Plan (PEP) 2023–2050, the Nationally Determined Contribution (NDC) Implementation Plan 2020–2030, and the Transmission Development Plan (TDP). The primary targets that are analyzed are the RE targets covered in the PEP 2023–2050. Furthermore, the key drivers to meet such targets are covered in the legal documents which include RA 9513 Philippine Renewable Energy Act of 2008, RA 9513 Implementing Rules and Regulations (IRR), and department circulars that cover key policy mechanisms by the DOE for Renewable Portfolio Standards (RPS), Green Energy Auction Program (GEAP), and Green Energy Option Program (GEOP). The secondary materials in the form of review reports by different advocacy organizations and international development agencies provide insights into the progress of development and issues that are inferred from such progress. The leading organizations that provide these reviews are the Center for Energy, Ecology, and Development (CEED), WWF-Philippines, the International Renewable Energy Agency (IRENA), the Institute for Energy Economics and Financial Analysis (IEEFA), the Asian Development Bank (ADB), and the Organisation for Economic Co-operation and Development (OECD). Different reviews provide insights and validate findings in this study. The review reports fill in the gaps of data and transparency of RE development in the Philippines, allowing researchers to see critical issues and insights on RE policy performance, bottlenecks, and possible solutions.

To conduct the comprehensive review, this study uses a three-dimensional root cause framework, analyzing technical, political, and institutional factors that are hampering RE progress in the Philippines. The framework guides the identification of issues and relationships between such issues, allowing for core pertinent issues to be recognized. The research design for this study is qualitative, based on the primary and secondary materials previously mentioned, and is supplemented by other reported articles and reports. This critique uncovers the institutional barriers and gaps, along with stakeholder issues, that are slowing the implementation and enforcement of RE policy mechanisms in the Philippines. The paper investigates the progress toward the Philippine Energy Plan in Renewable Energy, as well as an assessment of the provided framework of RA9513 for renewable energy policy mechanisms. Findings from the materials are reviewed for similar issues to help determine relationships and pinpoint bottlenecks. Where data is available, descriptive statistics based on DOE data are used to analyze trends to help understand the performance and progress toward the 2030 RE goals. Furthermore, stakeholder mapping is conducted to understand the roles of different stakeholders along with their overlaps and conflicts. The results from this comprehensive analysis highlight the interconnected issues and possible solutions to improve the performance of RE policy mechanisms and help fast-track progress toward the PEP 2023–2050 goals. Findings from policy documents were cross-referenced with insights from review reports to identify policy design flaws, implementation gaps, and institutional constraints. Limited stakeholder mapping was conducted to outline the leading actors in policy implementation and their interactions. Where available, descriptive statistics from DOE and other official datasets were used to provide contextual evidence, though quantitative data use was minimal. The results from these analyses were synthesized within the three-dimensional root cause framework to highlight interconnected barriers and to propose targeted reforms to improve policy mechanism performance and accelerate progress toward the PEP RE targets.

3. Discussions

3.1. Policy Background

The legal framework for Philippine Renewable Energy is the Republic Act No. 9513, or the Renewable Energy Act of 2008. To drive the adoption and development of renewable energy, RA 9513 provides necessary policy mechanisms to promote the use of renewable energy. Incentives are also included, such as grid priority for renewable energy generators, duty-free renewable energy equipment importation, along with other policy mechanisms. The act helps shift the energy usage from fossil fuels, lessens environmental damage, and improves access to energy, aligning with the Philippine Energy Plan and other socio-economic goals. The Department of Energy (DOE) has enacted RA 9513 with department circulars (DCs), creating the policy mechanism to aid further RE adoption, such as Renewable Portfolio Standards (RPS), the Green Energy Auction Program (GEAP), Net Metering, and the Green Energy Option Program (GEOP), as shown in Figure 6.

The Renewable Portfolio Standards (RPS), enacted in Department Circular DC 2017-12-0015, require electricity cooperatives (ECs) and distribution utilities (DUs) to acquire a portion of their supply from renewable energy sources. The requirement is used to increase RE demand in a guaranteed way, providing an available market for potential providers. With RPS, DUs, and ECs, along with other suppliers, must increase usage from renewable energy sources by 1% every year as mandated by DOE. Department Circular No. 2022-09-0030 mandates that the previously set 1% annual increase is increased to 2.52% starting in 2023. This increase aims to create the required demand to reach the 35% RE share target for 2030. IEEFA forecasts that the increase to a 2.52% annual increase will result in a 37% RE share by 2030, with the supply being filled by GEAP [24]. Even with the mandate from DOE, RPS compliance is put into question due to the lack of compliance data and transparency. Many also argue that compliance difficulties are further aggravated by the lack of technical and financial capabilities to source RE [25]. Furthermore, there are also concerns about the enforcement of the ERC on the penalties for non-compliance. Although penalties are properly outlined, there have been no reports on the imposition of such penalties, highlighting the need for transparency in enforcement. Furthermore, the penalties are assigned to be enforced by the DOE even when ERC is the designated governmental body for regulation under RA 9136, the Electric Power Industry Reform Act, which shows the overlap and fragmentation of authority.

The Net Metering program, established through the 2013 Implementing Rules and Regulations (IRR) of RA 9513, allows consumers to produce their renewable energy (commonly through solar panels) and lower their electricity consumption by returning excess electricity to the grid. From 2015 to 2024, the number of producers has increased from 200 to 13,189, with a total capacity peak of 116,292 KW [26]. To understand its impact on the annual RE share, it is multiplied by 8760 h per year and a capacity of 0.15 for solar panels. This results in roughly 152.93 GWh/year while the total power generation for RE in 2024 is 28,193 GWh. With this, net metering only contributes 0.54% to the total RE production, indicating that although there has been an increase in uptake, its contribution to the total RE share is very minimal. The program looks good on paper, allowing consumers to also produce electricity and reduce the load on grids, but adoption is limited. Some challenges that may cause low adoption are low rates for returned electricity and lengthy paperwork and processing.

The Green Energy Auction Program (GEAP), established through DC2021-06-0015, aims to increase the renewable energy supply by allowing bidding from interested parties. GEAP is the primary driver for RE development, driving the needed supply to help achieve the 2030 RE targets. The first auction in 2022 was successful in almost achieving its target of 2000 MW, awarding a total of 1966.93 MW, with the majority being 1390 MW from solar projects. In 2023, GEA 2 was conducted with a target of 11.6 GW but only awarded 3.43 GW, with 1.88 GW from solar and 1.46 GW from wind [27]. The second auction showed challenges in achieving the targets. The recent GEA 3 conducted in 2025 showed success, awarding 6.677 GW, exceeding the targets of 4.65 GW. GEA 3 offered projects in pumped-storage hydropower, impounding hydropower, and run-of-river hydro [28]. The following auctions are scheduled in 2025, with the GEA 4 tentative auction date on 2 September 2025, with a target of 10 GW. GEA 5 is expected to be conducted towards the end of 2025 with a focus on offshore wind projects. GEA 1 and 3 show successes in awarding RE development projects, while GEA 2 shows concerns in market structure and pricing. IEEFA reports that initial targets by NREP were an additional 15.3 GW by 2030 but were increased to 20 GW from 2018 levels [24]. DOE power statistics show total dependable RE capacity in 2018 as 6.592 MW, which means that a total of around 26.6 GW RE capacity should be met by 2030. In 2022, when GEA-1 was first conducted, the total dependable capacity was 7.151 GW. The total capacity awarded by GEA 1, 2, and 3 is 12.07 GW. Adding the capacity in 2022 and the total awarded GEA capacity yields around 19.22 GW, still not meeting the needed 26.6 GW. This means that there is still a need to award at least 7.38 GW RE capacity in the following GEA. With the target capacity nearing achievement, the question lies in whether the developed projects will be finished on time and within the awarded capacity.

The Green Energy Option Program (GEOP), established through DC2018-07-0019, allows consumers with more than 100 kW to directly avail renewable energy from suppliers instead of the local utility providers. GEOP aims to provide consumers with direct options for more environmentally sustainable energy choices. However, limited adoption has been shown due to poor marketing and awareness, complicated switching processes, and few RE suppliers [13]. GEOP is another promising mechanism that is hampered by poor implementation. Six years after the implementation of GEOP in 2018, there are only 451 registered end users and 18 suppliers as of September 2024 [29]. The market is dominated by large companies such as the Ayala Group through ACEN and the Energy Development Corporation (EDC), covering around 48% and 30% of all GEOP switchers, respectively [30]. Furthermore, out of the 18 suppliers, the Aboitiz Group controls 7 [30]. This shows how, despite being started in 2018, there has been limited uptake and participation from suppliers. Furthermore, the market is dominated by large companies, making it more difficult for smaller companies to compete in the market, highlighting structural concerns.

Overall, the Philippines has a legal framework for renewable energy, along with its policy mechanisms (RPS, net metering, GEAP, and GEOP) through RA 9513, supporting the RE goals highlighted in the PEP, aiming to increase RE supply and demand. Even with the available legislative infrastructure, there are persisting operational hurdles. These operational challenges include inadequate infrastructure, limited enforcement, progress and compliance transparency, limited uptake, market structure issues, and stakeholder overlaps, all of which hamper the policy mechanisms from driving both supply and demand for renewable energy. The following sections of this critique dive deeper into the mentioned issues, highlighting the disparity between the planned and actual implementation of the policy mechanisms.

3.2. Critique of Renewable Energy Policy Mechanisms

Renewable Portfolio Standards (RPS) as covered in Department Circular DC2017-12-0015 require electricity cooperatives (ECs), distribution utilities (DUs), and other electricity suppliers to source renewable energy with an annual increase of 1%, later increased to 2.52%. The mechanism aims to increase demand and provide a consistent market for RE suppliers. The design of the RPS is inherently good, aimed at creating market and demand for RE; however, its implementation faces many hurdles shown in

Table 3. Policy mechanism issues.

Policy Mechanism	Issue
Renewable Portfolio Standards (RPSs)	Compliance transparency
	Market structure
Green Energy Auction Program (GEAP)	Auction structure Pricing concerns
	Grid constraints
Net Metering	Lengthy bureaucratic processes Limited incentives
Green Energy Option Program (GEOP)	Limited RE suppliers
	Long accreditation processes Market concerns

. There is no available data on RPS compliance, which raises questions about DOE transparency and whether DUs comply with RPS. Although penalties for non-compliance are set, there are also no reports on DUs being penalized for non-compliance, which further highlights the concern for transparency. Regarding enforcement of penalties, ERC is the assigned regulatory body, but the DOE is assigned for the enforcement of RPS penalties, resulting in an overlap in responsibilities that complicates matters. A report by the WWF states that DUs face further difficulties in meeting RPS targets due to limited financial and technical capabilities, as they must source from a limited number of suppliers, depending on their area. Furthermore, in a report by the ASEAN Centre for Energy, the Renewable Energy Certificate (REC) shows that shortcomings are expected from 2024 to 2032, making RPS compliance more difficult, considering that RPS compliance is regulated through the number of retired RECs [25]. In 2025, a projected 5.4 million REC shortfall is expected by the DOE [31]. Each REC is worth 1 MWh traded through the Renewable Energy Market (REM). The REM was fully operational as of 26 December 2024. Operations are ongoing with data showing that a total of 46,634 RECs were traded as of 3 February 2025 [32]. This shows how the operations are still showing slow progress, far from the expected shortfall of 5.4 million RECs. Overall, key issues for RPS are the lack of compliance and enforcement transparency, stakeholder overlap in responsibilities, technical and financial constraints, upcoming shortfall, and a still-developing REM.

The Green Energy Auction Program (GEAP), covered under DC2021-06-0015, aims to auction RE development projects, creating a market for RE providers. GEAP is the main driver for RE supply to help achieve the 2030 RE targets. GEAP has seen success in the first and third auctions, with the second one falling short. To understand the shortcomings of the second auction, Cruz-Capellan, CEO of SunAsia Energy, reported that the auction framework caused limited participation. The set price cap was too low for many participants, leading to underbidding, and thus, projects were not awarded. As price caps were supposed to act as a ceiling, the ERC set the price cap too low, and Cruz-Capellan stated that “It seems, however, that the regulators are setting a floor price” [33]. Additionally, the 2024 report of Aurora Energy Research found that the auction structure resulted in low bids because of the lack of a cost-pass-through mechanism or the ability to change service prices due to an increase in development costs [34]. The set prices by the ERC for GEA 2 were P4.4043 per kilowatt hour for ground-mounted solar, P4.8738 per kWh for rooftop solar, P5.3948 per kWh for floating solar, P5.8481 per kWh for onshore wind, P5.4024 per kWh for biomass, and P6.2683 per kWh for biomass waste-to-energy. No cost-passed-through mechanism means that the developers cannot offer the resulting capacity at higher prices, which puts them in a position of uncertainty if they face any oversight in costing. Furthermore, IEEFA states that developers are having a hard time securing finances for GEAP projects due to unclear cost recovery mechanisms and limited incentives [24]. With the GEAP being the main driver for RE capacity, this means that there is a call for an increase in infrastructure capacity as well. The Asian Development Bank expresses that there is a lack of grid capacity, even in priority areas of Luzon and Visayas, exacerbating the issue of accommodating the increase in RE capacity, increasing curtailment risks [35]. The Philippines Daily Inquirer (2024) reports that delays in transmission projects have long-lasting impacts on energy security, placing electricity affordability and grid capacity at risk [36]. Another challenge that GEAP faces is the limited time to finish developing projects, as 2030 is only 5 years away. The DOE has not released any development or enforcement updates despite the projects being contracted to finish on time strictly. This raises questions about the actual development of the awarded capacity before 2030. Overall, GEAP has had its successes and failures, and challenges are present in its auction structure, technical infrastructure, and development transparency.

Net metering, covered under section 10 of RA 9513 and 2013 Implementing Rules and Regulations, provides consumers with the ability to lessen electricity bills through selling excess RE generation, commonly through solar panels. Reports show that there is a total of 13,189 producers with a capacity peak of 116,292 KW [26]. As previously discussed, this only accounts for 0.54% of total RE production, indicating that its contribution is very minimal. Some issues that can be linked to poor adoption include lengthy paperwork and processes, strict standards, and confusing rules from utility providers [37]. Solar Install Ph identifies administrative complexity as one of the challenges, stating that complex processes and lengthy procedures discourage adoption [38]. Solaric outlines the steps for net metering, which are document preparation, distribution impact study, yellow card issuance, service disconnect installation, electrical permit application, and net metering application and meter swap, adding that the whole process can take months [37]. Solviva describes this process as long and tedious, spanning around 6 months to a year [39]. Solviva then explains why they think net metering is not worth it yet and attributes it to financial pricing, stating that buying electricity from Meralco is around 13 pesos per kWh, but exporting is only around 5–6 pesos per kWh. Albay (2025) reports that although solar energy seems attractive in the Philippines because of high electricity prices, surveyed households in Metro Manila have concerns about the high initial costs of solar energy setups [40]. Farias-Rocha et al. computed the payback period for net metering to be around 7.8 years, highlighting a long payback period for the upfront costs [41]. With that, the main issues for net metering are its lengthy processes and limited financial incentives.

The Green Energy Option Program (GEOP), covered in section 9 of RA 9513 and DC2018-07-0019, allows consumers with a usage of over 100 kW to source from RE suppliers directly. The mechanism aims to provide direct choices and allow a free market, promoting market competition. Some obstacles include limited accredited suppliers, slow supplier accreditation, opposition from utility providers, and unclear switching procedures [13]. GEOP adoption is limited, with only a few consumers directly contracting with providers. Fernandez reports that there were only 451 end users and 18 suppliers as of September 2024 [29]. The RE Energize PH Survey found that the limited uptake in GEOP is caused by the public’s lack of awareness of such a program, hindering its growth and adoption [29]. Capongcol, director of the Renewable Energy Management Bureau under DOE, admitted that the switching and application process for GEOP is long and tedious, often reaching six months [42]. Many are hesitant with concerns about their ability to supply 100% renewable energy as they cannot guarantee supply, along with the ability to back up power due to the intermittency of RE sources such as solar and wind [30]. Furthermore, the market is dominated by large companies such as Ayala, accounting for 48% of switchers, EDC, accounting for 30% of switchers, and Aboitiz owning 7 out of 18 suppliers [30]. With large companies dominating the market, smaller energy suppliers face significant barriers to entry and capturing market share. GEOP’s main concerns are its limited uptake associated with poor program awareness and lengthy processes, and market difficulties such as RE intermittency and the market being dominated by large companies.

The compiled reports of renewable energy service contracts show a yearly increase from 2012 to 2024, showing growth in renewable energy development in the country in Figure 7. The actual influence of renewable energy policy mechanisms can be seen through the pace of the increase in renewable energy service contracts. The initial increase from 2013 to 2017, from 334 service contracts to 872, can be attributed to the implementation of net metering and groundwork for the release of RPS in 2017, showing good initial growth with the uptake of net metering and anticipation for RPS implementation [14,43,44,45]. Between 2017 and 2021, RPS and GEOP were implemented but had limited growth from 872 to 932 RESCs; the data follows the reports of minimal compliance of RPS and limited GEOP uptake [46,47]. For the years 2021 to 2024, there is an increase from 959 to 1447, which follows the reported initial success of GEAP auctioning of renewable energy projects to developers along with the other implemented policy mechanisms [48,49,50]. Overall, the number of renewable energy service contracts shows the influence of policy mechanisms on the renewable energy development rate and validates the reviews on the policy mechanisms, such as initial successes of net metering and GEAP, and the minimal compliance of RPS and limited GEOP uptake.

3.3. Stakeholder Analysis

Different stakeholders with different mandates, interests, and capacities shape the Philippines’ renewable energy (RE) policy mechanisms, as shown in Figure 8. Some notable stakeholders include the Department of Energy (DOE), the Energy Regulatory Commission (ERC), and the National Grid Corporation of the Philippines (NGCP). Other stakeholders include electric cooperatives and distribution utilities (DUs), RE developers, local government units (LGUs), consumers, and civil society organizations or non-government organizations (NGOs). Knowing how the power dynamics work among these stakeholders is important in addressing the problems rooted in RE policy execution.

Of the notable stakeholders, the key policymaker and coordinator in energy planning and implementation is the DOE. Their roles include RE initiatives such as the Renewable Portfolio Standards (RPS), the Green Energy Auction Program (GEAP), and the Green Energy Option Program (GEOP). However, the DOE is often constrained by limited enforcement mechanisms and the need for cooperation from regulatory and operational entities [14]. Another stakeholder is the ERC, which is responsible for regulating pricing and grid access. They play an important role in gatekeeping. However, their inefficiency in releasing regulatory disbursements and clarifications affects the rate of policy execution [51]. Lastly, the NGCP is responsible for transmission planning and interconnection, which holds significant power in permitting or interrupting RE projects. An example is utility-scale projects that require grid updates or connections.

Distribution utilities and electric cooperatives are both implementers and gatekeepers. They are implementers in the sense that they are the ones delivering electricity to regular consumers. Conversely, they are gatekeepers in the sense that their interests often oppose rapid RE adoption, such as when mechanisms like net metering or RPS require additional operational adjustments and jeopardize their revenue models. Several DUs have delayed submitting their RPS compliance plans or expressed concerns about diluted obligations, arguing that they lack the technical and financial capacities to comply with mandates and integrate distributed generation [52]. Net metering adoption is also restricted by procedural delays and technical barriers imposed by DUs. The reasons clearly show a discrepancy between policy intent and utility incentives.

On the other hand, RE developers that are eager to go through policy mechanisms are held back by barriers such as permitting, financing, and infrastructure. The World Bank reports that due to lengthy bureaucratic processes and incoherence, along with overlapping mandates, the permitting processes for renewable energy projects reach 3 to 5 years [53]. Concerns regarding GEAP auctions favoring a lack of project readiness, unworkable and low bids, and a lack of grid interconnection guarantees have been raised. Additionally, NGCP’s delays in issuing transmission development plans and LGUs’ delays in granting permits have further held back project plans [54]. Overall, the lack of a streamlined permitting process further emphasizes developer risk and discourages broader participation, especially in smaller and newer players.

Consumers and producers are critical in energy transition efforts but are often under-supported. Net metering and GEOP are intended for end-users; however, most remain unaware or are unable to access them due to financial costs, tricky requirements, and poor consumer education. Apart from consumers, prosumers tend to face obstacles from utilities, while GEOP customers encounter difficulties in transferring suppliers due to confusing processes and limited retail competition. Moreover, LGUs are vital in advocating for local RE efforts but are often tied by limited technical capacity and unclear roles in energy planning.

NGOs and civil society organizations, such as the Institute for Climate and Sustainable Cities (ICSC), Center for Energy, Ecology, and Development (CEED), and Institute for Energy Economics and Financial Analysis (IEEFA), are advocates of transitions towards sustainable energy. They help expose accountability gaps and act as middlemen between communities and state institutions. However, their influence is heavily limited by difficult-to-understand institutions and unclear policies. The same organizations have also raised concerns regarding transparency and the effectiveness of RE policy implementation.

The stakeholder map shows the potency of relationships between different stakeholders in Figure 9. The arrows represent the two-way relationship between stakeholders. The darkness of the arrows signifies the potency of their influence, with the darker arrows being more potent. For the DOE and ERC connections, DOE is the policymaker setting different RE targets and market mechanisms, while ERC is the regulatory body that operationalizes DOE plans. DOE has a significant influence on ERC, as it mandates the implementation of its plans for ERC to regulate. A specific example of this is the Energy Efficiency and Conservation Act by the DOE, where the ERC is assigned to price in the rates for investor investment recovery mechanisms. On the other hand, ERC, with the ability to dictate rates and tariffs, can act as gatekeepers who are responsible for whether DOE’s plan is executed under proper market conditions. An example of ERC’s influence on DOE is an instance in 2025 where there was a delay in the approval of procurement agreements by the ERC, which slowed down DOE’s advances for RE integration [55]. For the DOE and NGCP relationship, NGCP makes the TDP, but DOE can modify and approve the final plans. A specific recent example is the Mindanao-Visayas Interconnection Project proposed in the TDP, which the DOE reviewed and approved [56]. With the NGCP drafting the technical plans, they are essential for the DOE to facilitate their developments in RE, especially in the transmission infrastructure. This relationship means that delays in NGCP plans and development lead to delays with DOE plans, such as the Cebu-Negros-Panay Transmission Project, which faced delays affecting DOE solar plans in Negros, including curtailment issues [15,57]. Another key relationship to developing RE projects is the DOE and LGU relationship. DOE approves and grants RESC authorization for projects in LGU locations, such as in 2018, where DOE approved a wind farm [58]. With the DOE’s endorsement, the LGU was able to process requirements and proceed immediately. Conversely, the LGU has the executive ability, somewhat like a hidden veto, if they do not want projects to push through in their territory. A specific example of how LGU influenced DOE plans is a project in Mindanao where a geothermal plant development was stalled due to opposition from local communities despite DOE development plans [59]. A key stakeholder in delivering RE to end users is DUs. Understanding their relationship with the DOE helps define their influence among themselves. The DOE outlines the responsibilities of DUs, including compliance with RPS and guidelines, for executing programs like net metering and DOE. An example of this is the respective department circulars outlining the policy mechanisms and how DU must comply with them. Inversely, the performance and challenges faced by DUs affect the DOE’s mandates, such as DC No. 2025-06-0008, where the National Electrification Administration is tasked with facilitating bidding and sourcing processes to help DUs and ECs comply with RPS targets [60].

With the stakeholder relationships for DOE already covered, it is essential to explore the other relationships with ERC, given their important role in ensuring that development targets are met. With transmission infrastructure acting as the backbone for delivering RE, understanding the relationship between ERC and NGCP is important. The ERC regulates the plans of the NGCP, approving capital expenditure for different projects and adjustments for tariffs. The ERC approves the capabilities of the NGCP to collect the funds required for transmission development. A specific project example is the Mindanao-Visayas project, which the ERC approved for 52 billion pesos, allowing the NGCP to begin development [61]. Similarly, NGCP, being the sole developer for transmission infrastructure, can request ERC to approve proposals. NGCP can request emergency capital expenditure, which the ERC has to review or can provide fast-track approval [62]. For the ERC and DOE, the ERC regulates the performance of DUs, setting limits on customer charges and imposing penalties in cases of infractions. DUs submit tariff applications, reports, and other legal documents that shape regulatory plans and timelines. This shows the relationships between the ERC and other stakeholders.

One prime barrier across all entities would be the constant overlapping and poorly coordinated mandates among stakeholders. As an example, when the DOE sets a policy direction, the ERC should release regulatory issuances before utilities and developers can act. However, due to delays or variabilities in the ERC’s action, such as finalizing net metering rules or clarifying GEOP terms, bottlenecks have been created. Moreover, no single entity is responsible for coordinating transmission planning by the NGCP, policy objectives by the DOE, and regulatory approvals by the ERC, resulting in disorganization.

As a result of the lack of coordination between different stakeholders, a fragmented energy governance is created, wherein RE policies struggle to be implemented. In order for us to avoid these bottlenecks, a revised energy governance that has a shared goal of streamlined procedures, aligned incentives, and highlights accountability from all entities and stakeholders is called for.

3.4. Root Causes and Policy Gaps

The Philippines has been underperforming in terms of renewable energy (RE) policy mechanisms. It is rooted in systemic, technical, economic, and political changes. Although efforts to close the gap between legislation and implementation through the presence of the Renewable Energy Act of 2008 and other Department Circulars, structural weaknesses can still be seen. The vulnerabilities of the institutions, such as the Department of Energy (DOE) and Energy Regulatory Commission (ERC), are highlighted in these gaps seen in

Table 4. Stakeholder and institutional issues.

Issue	Description
Interagency Incoherence	Overlapping and misaligned plans between DOE, ERC, and NGCP.
DUs and ECs Resistance	High costs developing RE programs and limited incentives.
Transmission Infrastructure Constraints	Delayed and insufficient development of transmission systems.
Permitting and Regulatory Delays	Lengthy and confusing permitting processes.
Limited LGU Involvement	Minimal and unclear roles on RE development projects.

. The DOE cannot enforce compliance or penalize negligence, while the ERC has been underperforming in enforcing regulations. Consequently, a fragmented policy environment results in unsystematic and untimely development.

A persistent bottleneck in the advancement of the Philippine RE sector is the incoherence between key government agencies, DOE, ERC, and NGCP. DOE dictates the direction and framework for RE development, and ERC regulates the development through the approval of expenditures and tariffs. It imposes penalties, while NGCP constructs the much-needed transmission infrastructure to cover the influx of RE capacity. The incoherence lies within how the agencies operate as solo entities and not in coordination, leading to overlaps and misalignments. The incoherence between DOE and NGCP is seen in the mismatch of the development plans of the DOE and the TDP of the NGCP, where the DOE calls for cooperation to fix the mismatch between the plans in 2025 [63]. They specifically cited mismatches such as the need to connect Visayas and Mindanao to facilitate the influx of RE capacity. For DOE and ERC, the incoherence can be seen in the implementation and enforcement of the RPS and REC markets. The misalignment is seen in the implementation of the ERC on the REC market, which resulted in it not meeting DOE’s RPS requirements with an expected shortfall in 2025 [64]. Furthermore, the DOE is tasked with the regulation of RPS compliance, but ERC is the overall regulatory body, creating an overlap. Another project that showed incoherence was in 2023 in which the NGCP notified the ERC of possible power outages requiring extensions for ancillary services, which the ERC denied. The regulatory decision of the ERC was not aligned with the operational requirement of the NGCP, leading to power interruptions [65]. The different examples show the cases of incoherence between different stakeholders, highlighting the need for such entities to work as a group rather than as a solo entity.

DUs and ECs have been showing resistance to RE programs for several reasons, such as disincentives, operational concerns, and subsidy dependence. According to the IEEFA, one example of a financial disincentive is the missionary electrification fund, which is meant for rural areas where electricity generation is costly, thus requiring an electrification fund for end users to avail at affordable prices [24]. The disincentive lies in switching to RE, although it results in lower costs. The allocation of the missionary electrification fund decreases, but this does not lead to actual savings for the DUs and ECs; instead, it only shows savings for the fund with no benefit to DUs [66]. Solar Install PH reports that resistance is evident with some ECs conducting more rigorous testing than required, such as distribution impact studies, and reserving the right to disconnect solar setups if generation is too much, citing alleged network stability concerns. For the end users or net metering producers, this adds another level of technicalities, requiring careful sizing and optimization of systems to ensure that ECs do not have reason to cut off their setup [67]. With the financial requirements of improving systems to handle RE developments, DUs and ECs often rely on government subsidies and aid. This reliance results in stagnancy with limited motivation to improve handling of policy mechanisms like net metering and GEOP. Reports from Manalo state that some DUs and ECs enjoy preferential treatment and subsidies, which have become lax, resulting in inefficiencies and poor performance [68]. These examples show the reasons behind resistance or limited motivation for DUs and ECs to advance RE development and implementation further.

The backbone of Philippine RE development is the transmission infrastructure development of the NGCP. Considering the ambitious goals of adding a total RE capacity of around 20 GW by 2030 requires upgrades in technical infrastructure to facilitate the influx of capacity and limit curtailment risks. Despite the importance of transmission infrastructures, the RE development of the nation is facing persistent delays and limitations. In a House committee hearing, it was reported that only 29% of projects are completed as of 2025 and that 75% of projects are delayed [69]. This shows how there are severe delays in transmission infrastructure, which would also result in the delay of overall national RE development. A report by Delilan attributes Right of Way issues as one of the main barriers for the NGCP transmission project completion, describing such issues as a 15-year-old hurdle dating back to 2009 [70]. Furthermore, Lackovic and Bawalan report that the current transmission infrastructure is decades old and is geared more towards stable fossil fuel generation, not equipped for the intermittent RE nature, which requires two-way flexible flows [71]. Moreover, it is noted that the transmission line length growth of the Philippines has been less than 0.6% per year since 2009. The IEA forecasts a huge 25 trillion-dollar investment requirement solely to improve transmission infrastructure to accommodate the 2050 net-zero goals, highlighting the scale of infrastructure upgrades needed by the country [71]. With RE development being reliant on transmission infrastructure, this places heavy pressure on the NGCP to deliver the necessary upgrades and development on the transmission infrastructure of the country.

Another aspect slowing down the development of RE in the Philippines is the lengthy interagency permitting processes that lengthen timelines. The WWF reports that the permitting processes required for RE in the Philippines need meticulous navigation through different government agencies, acting as a barrier to development [7]. This lengthy process is acknowledged by the DOE, as highlighted in an example for wind projects, where there are more than 80 required permits across more than 25 different agencies that must be processed before development starts. Tribdino reports this regulatory challenge through the awarding of 92 wind service contracts in December 2024, with only five of which have started to have their permits processed as of January 2025, showing bottlenecks in permitting processes [72]. Actions are being taken to streamline the RE permit processing through the Energy Virtual One-Stop Shop (EVOSS) enacted under RA 11234. However, as of September 2024, only 56 out of 103 energy permitting processes are incorporated. This shows that despite efforts, permitting issues have yet to be addressed, showing the persisting complexity of acquiring necessary permits for RE development [73].

LGUs, being one of the key stakeholders to ensure the proper rollout of RE development projects, have poorly defined roles in RE due to insufficient technical capabilities and inconsistencies in policies. The decentralization of LGUs from the DOE results in a misalignment in plans, as the DOE must rely on LGU implementation. UNDP’s DREAMS (Development for Renewable Energy Applications Mainstreaming and Market Sustainability) project addresses the issues of limited LGU involvement with its mid-term review, highlighting the need to improve LGU RE capabilities through methods such as RE trainings and a call for better local policies and planning for RE [74]. Lelis reports that DOE projects, such as the green lane, which aims to fast-track cooperation with LGUs, encounter problems, such as some LGUs still having complex and lengthy processes despite green lane status, leading to delays [75]. Furthermore, the DOE calls for better cooperation with the LGUs to ensure the successful rollout of RE projects. Moreover, Power Philippines highlights the lack of a nationwide policy regulating the fees for LGU approval, citing a project that spent 153,000 pesos in Rizal but only 16,000 in Laguna for the same capacity [76]. With this, the challenges with LGUs are multifaceted, showing that there is a need for a more comprehensive national policy outlining the roles and responsibilities of LGUs in the rollout of RE technology.

In conclusion, the root cause of policy issues stems from weak implementation, conflicts of interest between entities, and insufficient institutional reforms. The Philippine Energy Plan’s RE targets have a lot to tackle before becoming successful. These include stronger governance, better coordination between stakeholders, and more inclusivity. Focusing on building better infrastructure and aligning political dynamics is one step they can take in bridging the gap between policy making and implementation.

4. Recommendations

4.1. Renewable Energy Policy Mechanisms Recommendations

To achieve the targets set in PEP 2023–2050 of 35% RE share, the intended policy mechanisms to drive development and adoption must be restructured with proper implementation and enforcement to bring about real change. With this, updating the existing policy mechanism is mandatory. Renewable Portfolio Standards (RPS) enforcement policies should be properly outlined along with appropriate penalties. The Department of Energy (DOE) should mandate clear penalties for non-compliance. A periodical and transparent reporting process should be accessible with proper monitoring to streamline compliance and checking of requirements. Additionally, incentives or aid should be given to lessen resistance from distribution utilities (DUs) and electricity cooperatives (ECs), and tax incentives or lowered quotas should be explored for areas with minimal RE suppliers. This is possible through proper coordination between the DOE, Energy Regulatory Commission (ERC), and National Grid Corporation of the Philippines (NGCP), ensuring that necessary mandates, enforcements, and technical capabilities are considered.

The current main challenges for RPS are the lack of available data on its compliance and enforcement of penalties—making it unclear whether RPS is successfully operational—and the still-developing REM. Recommendations to tackle the issues met with the RPS are to increase DOE and ERC transparency, strengthen DOE and ERC cooperation, and improve REM, as outlined in

Table 5. RPS recommendations.

Recommendation	Cost	Benefit
Increase DOE and ERC transparency	Creation of reporting platforms Data monitoring staff training	Allows compliance to be tracked Improves investor confidence Data trend studies
Strengthen DOE and ERC cooperation	Formation of joint task force and guidelines Process and procedural restructuring	Streamlines cross agency enforcement Minimizes regulatory overlaps
Improve Renewable Energy Market (REM)	Platform and system upgrades Market participant training	Easier REC trading Improves investor confidence

. For DOE and ERC transparency, compliance platforms can be created to streamline compliance tracking. The compliance platforms can be posted quarterly in reports or real-time setups. This would require websites and additional staffing, along with the required training. The compliance platform and reporting will help data trend studies to be conducted and improve investor confidence. A working example for a compliance platform is California’s REM, which uses an online tracking platform to track RPS compliance and produce quarterly mapping DUs that comply with the requirements [77]. Another recommendation is to strengthen DOE and ERC cooperation; this can be done through initiatives like an interagency task force or process and procedural restructuring. With this, enforcement is streamlined, and overlaps are minimized. For REM improvements, continued efforts to upgrade the platform and systems to facilitate a larger number of RECs will help market liquidity, making it easier for DUs to trade and acquire RECs for RPS compliance. Furthermore, market participant training will help transition DUs to new technology. The improvements in the REM will help REC trade more easily, allowing DUs to meet RPS compliance targets and improve investor confidence.

Net metering encounters challenges in its lengthy processes and unattractive rates. The recommendations to tackle such issues are to streamline processes through digital platforms and explore repricing, as shown in

Table 6. Net metering recommendations.

Recommendation	Cost	Benefit
Streamline processes	Investment in digital platforms Staff training Re-evaluation of procedures	Convenient document submission and progress tracking Less barriers to entry help avoid frustration
Explore repricing	Possible short-term financial disincentive for DUs Stakeholder consultations Tariff adjustments	Improves solar payback rates Promotes adoption through attractive rates Stimulates solar market and jobs

. Investing in digital platforms would require capital, along with staff training and reevaluation of procedures to remove redundant steps. Streamlining processes through digital means allows for convenient document submission and progress tracking, removing barriers that discourage participants from adopting the net metering program. California has adopted digital platforms to streamline its processes, as reported by the California Public Utilities Commission (CPUC) [78]. With end users expressing concerns regarding net metering prices being less than 50% of the DU price, repricing studies can be conducted to explore increasing prices to improve adoption. The price increase may become a financial disincentive for DUs, but government incentives may be of use. Exploration of repricing needs further studies, but the feedback from end users shows the need to do so.

The GEAP has seen successes in its first and third auctions, falling short in its second one. The issues in the second auction were attributed to the high floor price and the large capacity target. This setup does not promote competitiveness because of the large amount of supply. The pricing for auctions is supposed to act as a ceiling price, where participants bid lower and lower, but it acted as a floor price, with most not being able to match it. With this, the suggestions for upcoming auctions are smaller capacity targets to limit supply and increase demand, promoting competitiveness and participation, as shown in

Table 7. GEAP recommendations.

Recommendation	Cost	Benefit
Auction smaller targets but more frequent	Increased workload planning and managing auctions	Steady gradual capacity developments instead of large simultaneous developments Promotes competition through lower supply per auction round
Re-evaluate pricing	Regulatory cost studies Stakeholder consultations	Improved project sustainability Attracts capable quality developers
Coordinate GEAP with NGCP development timelines	Grid planning studies Auction timeline and transmission development adjustments	Transmission development focused on awarded capacity Lessen risks of delay

. Smaller and more frequent auctions allow for gradual development, making it easier to oversee and track development. India has implemented a methodology of reduced capacity targets, as exemplified by the IEEFA’s 2019 RE and thermal project, which was supposedly reduced from 5000 MW to 2500 MW to increase competition [79]. Furthermore, pricing should be reevaluated through cost studies and stakeholder consultations to determine the prices needed for developers to develop projects sustainably. Proper pricing allows quality investors to participate in improved project sustainability. With 2030 nearing, project delays should be minimized. With this, coordination between NGCP and GEAP is key to ensuring that the needed transmission infrastructure is available upon project completion. This is achieved through grid planning studies and matching auction and transmission development timelines. This results in transmission development focused on GEAP, ensuring that needed infrastructure is met upon completion, reducing the possibility of delay.

GEOP faces adoption issues with only 18 suppliers and 451 end users. These issues can be remedied through streamlined supplier accreditation, the GEOP market, and allowing grouping of smaller RE suppliers. Recommendations are outlined in

Table 8. GEOP recommendations.

Recommendation	Cost	Benefit
Streamline supplier accreditation	Procedural reevaluation Digital and tracking system investment	Reduces accreditation time Encourages participation Increases number of suppliers
Create a GEOP market	Institutional and technical setups Regulation and policies for GEOP market Market participant training	Improves competition through price tracking Allows smaller suppliers to be noticed Easier switching to GEOP
Allow grouping of smaller RE suppliers	Grouping framework Grouping platform	Promotes participation of smaller suppliers RE capacity increase

. Streamlining accreditation processes reduces the time and barriers to entry, making it easier for new suppliers to join. This is done through procedural reevaluation and investing in modern methods such as digital and tracking systems. Germany has implemented a digital platform for supplier registration, switching, and decommissioning, streamlining processes for both supplier accreditation and switching [80]. Another issue with the GEOP is that large market players dominate it. Creating a GEOP market allows smaller suppliers to be seen and makes the switching process easier. This is done through the needed regulations and policies for a GEOP market, accompanied by necessary supplier and end-user training. Furthermore, allowing for the grouping of smaller RE suppliers would help boost the number of suppliers, also increasing RE capacity. For this to be possible, a grouping framework is needed, and a grouping platform would help facilitate the aggregation of smaller suppliers to ensure that minimal financial obstacles are placed by utility providers.

4.2. Stakeholder and Institutional Recommendations

To address agency incoherence issues, the recommendations are to create interagency bodies or committees, align DOE and NGCP plans, and establish joint DOE and ERC RPS and REC compliance monitoring, as shown in

Table 9. Agency incoherence recommendations.

Recommendation	Cost	Benefit
Create interagency bodies	Legislative and executive mandates Additional training Time, effort, resources to setup and maintain	Aligns policies and timelines Reduces overlaps. Improves collaboration
Align DOE development plans and NGCP TDP	Frequent meetings and reviews Data sharing and transparency	Ensures on time transmission infrastructure development Prevents delays Solves infrastructure bottleneck
Establish joint DOE and ERC RPS/REC compliance monitoring	Mandates Manpower for monitoring and enforcement	Improves transparency and enforcement of RPS Improves RPS and REC market credibility for investors.

. The creation of interagency bodies requires the necessary legislative and executive mandates, along with training and the time, effort, and resources to set up and maintain such bodies. Vietnam has adopted this methodology of creating inter-ministerial committees such as the Vietnam Energy Partnership Group (VEPG), which includes major stakeholders such as the Ministry of Industry and Trade, the Electricity Regulatory Authority of Vietnam, the Ministry of Natural Resources and Environment, and the Ministry of Planning and Investment [81]. For DOE and NGCP alignment, frequent meetings and reviews to align plans and development, along with data sharing and transparency, are required. This will help prevent delays and ensure that sufficient transmission infrastructure is available upon completion of development projects, reducing the risks of curtailment. For DOE and ERC compliance monitoring, additional mandates and workforce are required to track and report RPS and REC compliance. The improved transparency enhances investor confidence and allows for data studies to be conducted to pinpoint other issues in compliance.

The resistance from DUs and ECs boils down to a financial disincentive, not providing motivation or benefit for DUs and ECs to be proactive in RE participation, as shown in

Table 10. DU and EC resistance recommendations.

Recommendation	Cost	Benefit
Provide RE performance-based incentives	Government aid and funding Mandates and regulation policies Data tracking	Proactive DUs/ECs are rewarded, also promoting RE participation Improves cooperation for long term upgrades

. Focusing efforts to conduct financial studies to provide necessary aid and funding would promote RE involvement for DUs and ECs. This may be costly in the short term, but it will help ensure proper rollout of programs, given the tight deadline for achieving 2030 RE targets. Better incentives for DUs and aid in the costly shift toward RE will remove barriers causing the resistance of DUs and ECs. Malaysia has outlined the importance of financial mechanisms and performance-based incentives in their Malaysia Renewable Energy Development Roadmap 2021, showing the impact of how such policies drive them toward their RE development goals [82]. With this, DUs and ECs can become more proactive to achieve incentives, thereby improving cooperation between DOE, ERC, and DUs.

NGCP has faced persistent delays in infrastructure development projects due to right-of-way disputes, as outlined in

Table 11. Transmission infrastructure development recommendations.

Recommendation	Cost	Benefit
Fast-track right-of-way (ROW) acquisition	Land acquisition cost Legal amendments and fund allocations	Reduces land acquisition delays. Improves investor confidence. Enables on time completion for transmission development projects.
Prioritize grid upgrades toward RE	High costs Skilled workers and specialized training	Increases grid stability and reduces curtailment of RE output. Allows for increased integration of RE technologies. Equips the nation with robust infrastructure for future developments.

. With this, it is essential to have a fast-track framework for ROW acquisition. This will require additional funding and legal amendments, but it reduces delays and expedites land acquisition for transmission infrastructure development. Accelerated developments help investor confidence, especially RE developers who have concerns about infrastructure capacity. Solving ROW issues enables infrastructure projects and RE development projects to be completed on time. Indonesia has taken the steps to fast-track land acquisition through Indonesian Presidential Regulation No. 71 of 2012 concerning Land Procurement of Development in the Public Interest [83]. The presidential regulation streamlines processes and cites limits, showing that the land acquisition limit is 583 days. The Philippines can implement similar legal mandates to minimize ROW disputes. Furthermore, concerns were highlighted on the outdated infrastructure of the Philippines, designed for stable fossil fuel electricity generation and not for the modern RE two-way flexible requirements. Proactive upgrades in infrastructure allow for easier developments and upgrades for RE in the future. This approach would require high costs and investments, along with skilled workers and specialized training. Achievement of an upgraded grid allows for better integration of RE technologies and provides a strong foundation for future projects over having to retrofit older infrastructures.

Lengthy and complex permitting processes are prevalent in different sectors of the Philippines but can be addressed through the recommendations in

Table 12. Lengthy permitting processes recommendations.

Recommendation	Cost	Benefit
Integrate all RE permits into EVOSS	Digital system upgrades Cooperation between agencies Implementation, training, and management costs	Streamlines and centralizes permit processing Improves developer certainty Provides feedback and accountability
Prioritize high-impact RE projects	Creation of strict eligibility requirements Legal and executive mandates	Accelerates RE capacity Improves investor confidence through government efforts

. EVOSS was established as an attempt to streamline permitting, but not all permits are integrated yet. A push to integrate all permits and improve processes can be done through digital system upgrades, but it requires cooperation between agencies, particularly in permit coordination. Additional implementation, training, and management costs are required to ensure the successful rollout of EVOSS. With this, the permit process is streamlined, reducing the barriers for supplier accreditation and permitting. This also provides applicants with feedback on other requirements and accountability for the status of permits. This improves developer certainty by allowing them to see permitting progress. The Indonesian Ministry of Energy and Mineral Resources explains the Online Single Submission (OSS) platform that makes licensing easier for applicants, as confirmed by an official [84]. Successfully implementing the EVOSS may yield the same results as Indonesia’s OSS. Additionally, considering the limited time to achieve the 2030 targets, there is a need to prioritize high-impact RE projects. This can be done through necessary legal and executive mandates and strict eligibility requirements to correctly identify key projects that will help achieve RE targets for 2030. Prioritizing such projects allows for accelerated RE capacity development and improves investor confidence through the government’s showing involvement and initiative for the RE sector.

LGUs have limited involvement and capabilities but are key to realizing RE targets. Cooperation between government agencies and LGUs is essential in the processing of permits and ensuring timely development. Some ways to improve involvement and capabilities are national polices outlining the LGU processes and responsibilities for RE, along with the implementation of RE programs such as trainings and consultations with LGUs, as shown in

Table 13. LGU involvement recommendations.

Recommendation	Cost	Benefit
Develop national policies outlining LGU processes	Legislative and executive mandates LGU cooperation	Reduces cost differences Ensures fairness and uniformity Encourages investment
Implement RE programs for LGUs	Funding and manpower LGU initiative	Improves LGU technical expertise Improves cooperation with LGUs Builds foundation for long term RE developments

. Developing national policies would require legislative and executive mandates along with LGU cooperation, but this would help reduce differences, such as in fees previously discussed, and promote uniformity and fairness. Furthermore, with better outlined LGU involvement, investors can gauge the risks and assess investments better. In the implementation of RE programs such as training and consultations, this would require funding, workforce, and expertise. Just like with national policies, this also relies on LGU initiative and participation. This will help build a long-term foundation for future RE development and improve overall cooperation. Thailand’s Department of Local Administration (DOLA) partnered with the Asian Development Bank (ADB) for LGU capacity-building programs for energy efficiency plans and energy-saving mechanisms. Through this partnership, effective implementation was successfully achieved [85]. These efforts remedy the disconnect between LGUs and government agencies, reducing friction in operations and development timelines.

This study provides a comprehensive foundation in tackling core issues implied and derived from available data. Future studies for capable organizations can develop such issues further through coordination with different government agencies to acquire specific data, such as that from LGUs, DUs, and RE developers. Financial studies and simulations can also be explored by institutions with the skills and capabilities to forecast trends with the different policy mechanisms and RE development. The comprehensive data on the issues and current progress of RE in the Philippines can be built upon by other Southeast Asian countries in comparative research to explore possible patterns that help or hamper the development of RE.

5. Conclusions

The existing renewable energy policy mechanisms in the Philippines, such as the Renewable Portfolio Standards (RPS), the Green Energy Auction Program (GEAP), Net Metering, and the Green Energy Option Program (GEOP), are essential tools at the forefront of driving the change to renewable energy. Created to promote development and adoption through creating a market for both producers and consumers, these mechanisms are key in helping the nation achieve the PEP target of 35% RE share by 2030. However, there are many challenges in implementing such policy mechanisms to achieve their intended goal of driving development and adoption in the RE sector, as this critique has shown. A multitude of problems for each policy mechanism, as well as general structural and institutional issues, must be fixed in order to ensure the proper implementation and enforcement of policy mechanisms. With this, an understanding of the core issues and possible remediation techniques is needed to move forward with the nation’s shift to RE.

Generally, for the policy mechanisms, it has been shown that weak agency oversight and cooperation lead to incoherence and overlaps. Specifically, RPS is hampered by non-compliance, poor enforcement, and opposition from utilities. Net metering has also shown opposition from utilities. These oppositions are brought by conflicts of interest in promoting said policy mechanisms because of the extra costs and loss of financial gain. Furthermore, there is a need for improvements in infrastructure or additional sourcing that is unavailable to some utility providers. For GEAP, it has shown promising initial results. Currently, it shows underdevelopment, which is attributed to aggressive underbidding due to poor company screening, raising concerns about project sustainability and viability, leading to more delays instead of its intended expedited development of RE capacity. GEOP, supposedly bridging consumers directly to suppliers, creating more of a market for retail, has seen low adoption due to lengthy accreditation and switching processes, along with a lack of awareness for both consumers and suppliers.

The specific issues for each policy mechanism can be attributed to more complex institutional issues, such as overlapping requirements, coordination issues, and a need for more political spearheading. Agencies like the Department of Energy (DOE), the Energy Regulatory Commission (ERC), and the National Grid Corporation of the Philippines (NGCP) have shown to have limited coordination, with plans not designed in unison. Because of this, bottlenecks exist, such as poor enforcement by the ERC, lack of transmission infrastructures by the NGCP, and the need for more transparent, streamlined processes and mandates by the DOE. Furthermore, utility providers often operate with a conflict of interest when it comes to policy mechanisms, as promoting such would mean sacrificing their financial interests. Local Government Units (LGUs) also lack the necessary capabilities and support to fund or pour more resources into developing and enforcing RE programs further.

To successfully achieve the shift to renewable energy, existing structural issues must be tackled. The policy mechanisms should be implemented and enforced in a manner that is both technically and economically viable. The policy mechanisms must also include all stakeholders, including utility distributors, beyond just suppliers and consumers. Agencies should improve processes promoting transparent procedures, clearly outlined regulations, and regular consultation to bridge the developers, utilities, consumers, and agencies. Without proper cooperation and dialogue between different stakeholders, alignment cannot be achieved, and the created policy mechanisms will not be able to drive the change to RE, thus making it harder to achieve the PEP targets.

Furthermore, it should be highlighted that the shift to renewable energy is not only a complex technical task but also a significant governance challenge. Improving institutional capabilities, ensuring proper regulatory compliance, and providing the necessary knowledge to citizens to participate in the shift towards RE, helping achieve the targets set in the PEP. With this, the changes in the future should be centered on long-lasting institutional frameworks that can span multiple political changes and ensure long-term, sustainable nation-building towards clean energy.

Overall, the Philippines has a comprehensive legal framework for renewable energy through RA 9513 and its policies, but issues lie within its implementation, which hamper its desired intent. RPS, Net Metering, GEAP, and GEOP are all well-designed tools that can drive the shift to RE. However, their potential is overshadowed by the cascade of implementation and enforcement issues. A committed and long-term initiative is essential to ensure improvements in enforcement, cooperation between agencies, and empowerment of participants. Through concerted efforts, the nation will be able to successfully put the policy mechanisms in place as drivers for RE. The time to act is slowly narrowing down as the year 2030 is nearing, with slow development in the RE field.