THE National Grid Corporation of the Philippines (NGCP) has strongly urged the Department of Energy (DOE) to withdraw two circulars that effectively allow other entities to build transmission facilities, arguing that allowing transmission projects outside the official transmission grid plan disrupts network coordination and design.
Furthermore, the grid operator maintained that allowing other entities to build grid facilities would not resolve regulatory, permitting and right-of-way constraints affecting transmission projects. This was the position sent by the NGCP to the DOE.
DOE circular no. 2026-01-0001 allows power generation companies (gencos) to finance and/or construct associated transmission projects while DOE circular no. 2026-02-0007 allows the National Transmission Corp. (TransCo) to finance and/or construct transmission lines and facilities critical to the country’s energy transition.
Citing the February 2025 arbitral award, the NGCP said it has the exclusive responsibility to prepare the Transmission Development Plan (TDP) during the concession period which is set to end in 2034.
The ruling distinguished NGCP’s planning role from the government’s regulatory authority: the DOE reviews and approves the overall plan, while the Energy Regulatory Commission (ERC) approves or disapproves individual projects. The TDP should align with the wider Philippine Energy Plan and Power Development Plan. TransCo retains a right to be consulted, rather than a right of prior approval, the NGCP claimed.
‘The ruling could be seen as supporting a unified approach to planning and development, with clear responsibilities and government oversight. From a project-delivery standpoint, adding overlapping planning and review layers could prove counterproductive, potentially multiplying coordination requirements, complicating accountability and introducing further delays rather than accelerating construction,’ the NGCP said.
Further, the NGCP raised this point: ‘Allowing projects to proceed outside the Transmission Development Plan raises questions about how their timing, design and integration would be coordinated with other network investments.’
It also pointed out that regulatory rules prevent NGCP from proactively building infrastructure for uncertain power projects that lack system impact studies. This leaves transmission planning dependent on the readiness and location of proposed power plants, as well as the approvals needed to develop the infrastructure serving them.
As such, the NGCP said power developers must synchronize their timelines with the availability of transmission infrastructure, just as grid expansion relies on power plant progress and approvals.
The NGCP argued that the DOE circular oversteps by expanding a genco’s reach beyond basic plant connections into general grid infrastructure, including new or expanded transmission lines, substations and other facilities. NGCP is concerned that associated transmission projects are allowed to move forward even if they fall completely outside the official TDP.
This, NGCP claimed, effectively forces it to share technical data and modify its existing facilities, such as control rooms and switchyards, to accommodate third-party equipment.
‘In seeking the withdrawal of both circulars, NGCP proposed addressing transmission development concerns through coordination with the company and the ERC under the existing planning and regulatory process. It also reserved its right to pursue legal remedies,’ the NGCP said.