Memorandum Circular No. MC2020-05-0001 FAQs

Published on Friday, 7 May 2021

Directing All Designated Establishments under Commercial, Industrial, and Transport Sectors to Submit Energy Consumption Reports

(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.

Memorandum Circular No. MC2020-05-0001 FAQs

Published on Tuesday, 23 February 2021

Directing All Designated Establishments under Commercial, Industrial, and Transport Sectors to Submit Energy Consumption Reports

(As of February 2021)

1. Who are covered by the Memorandum Circular (MC)?

  • All Designated Establishments (DE) from Commercial, Industrial, and Transport (CIT) Sector who have an annual energy consumption of not less than 100,000 kWh re required to comply with the Memorandum Circular.


2. Which Sector does my Designated Establishment belong to?

  • The following are the generic clustering of the Sectors:
Commercial (C) Industrial (I) Transport (T)
Communication and
(Sugar, Cement, Steel and Metal,
Chemical, Pulp & Paper)

Air Transport

  • Commercial Air Passenger
  • Commercial Air Cargo
Construction Companies
and Land Developers
Mining and Quarrying Hauling/Delivery Services
Event Centers Oil Refining Land/Road Transportation
Food Chains/ Restaurants PEZA Locators Railway Transport
Hotels and Other
Power Generation Public Transportation
Malls Power Transmission

Sea Transport

  • Passenger Ships
  • Cargo Ships
Semi-conductor Facilities  
Museums Water Concessionaire  
Other Corporate,
Tech- and Social-Support
Power Distribution    
Private Hospitals and
Medical Services
Real Estate and Renting    
Recreational and Health &
Wellness Facilities
Wholesale and
Retail Trade

3. What are the documents that we need to submit?

  • All CIT DEs are required to submit their Annual Energy Efficiency and Conservation Report (AECR) (Form 3) and their Annual Energy Utilization Report (AEUR) (Form 4). The DE shall choose from Form 4A, 4B, and 4C based on the sector where they belong. This shall be accompanied by an endorsement letter from the head of the office or its equivalent. Form 4 (AEUR) shall cover the last five (5) years of operation of the company. Each year shall have a separate file.

4. How do I identify the type of Designated Establishments?

  • The Classification for designated establishment shall be based on the annual energy consumption threshold express in kWh equivalent (for this purpose DOE will use kWhE) as the standard unit of energy. The DE Types are as follows:
Classification of
Designated Establishments
Annual Energy Consumption
threshold for the Previous Year
Other Designated Establishment 100,000 kWh but less than 500,000 kWh
Type 1 Designated Establishment 500,000 kWh to 4,000,000 kWh
Type 2 Designated Establishment More than 4,000,000 kWh


5. What are the obligations of a Designated Establishment?

  • Designated Establishments are reminded of the following obligations:
  1. Integrate an energy management system policy into the business operation based on ISO 50001 or any similar framework.
  2. Set up programs to develop and design measures that promote energy efficiency, conservation, and sufficiency that may include installation of renewable energy technologies.
  3. Set up annual targets, plans, and methods of measurements and verification for the implementation of energy efficiency and conservation projects.
  4. Keep records on monthly energy consumption data and other energy-related data.
  5. Improve average specific energy consumption in accordance with the annual reduction targets to be established by the DOE in the National EE&C Plan,
  6. Conduct an energy audit once every three (3) years by engaging either a certified energy auditor or an accredited ESCO and submit an energy audit report to the DOE upon completion of the energy audit.
  7. Employ a CECO for Type 1 designated establishments, and a CEM for Type 2 designated establishments. The CECO and the CEM may be chosen from within the organization or hired through external recruitment.
  8. Duly notify the DOE in writing on the appointment or separation from the service of their respective CECOs or CEMs with ten (10) working days from the effectivity of these personnel action.

6. Are we required to be certified for ISO 50001?

  • No, DEs are not required to be certified by ISO. However, any similar Energy Management System can be adopted by the DE. The designated or appointed CECO or CEM is in the best position to recommend the right EnMS for the company.

7. As a replacement for ISO 50001, is it acceptable if the company is already an ISO 14001: 2015 certified?

  • If you have an energy management system in place for the building, any certification will not be necessary. You may consult your ECO or EM in addressing the need for a certification. DOE encourages every DE to be ISO certified but this is not mandatory for DEs.

8. For the report submission, can we submit it to DOE Field Offices?

  • The submission of reports is through the identified online platform. This will ensure that all submissions are being accounted in one system. Also, submissions made online are real-time and can be easily monitored by EUMB-EPMPD. The DOE is currently developing on Online Database Platform which will supersede the existing submission of DEs using Excel Forms and Google Forms. We are expecting for full implementation in 2022.

9. For the Transport Sectors, what is the threshold on the fuel consumption to be identified as a Designated Establishment?

  • Entities with an annual consumption of 28,500 L of combined fuel are mandated to comply with the issued memorandum circular. The following fuel consumption threshold for the Transport Sector shall be observed:
(in Liters)
(Below the
indicated values)
(in range of the
indicated values)
(above the
indicated values)
Gasoline 30,817 30,817 1,232,666 1,232,666
Diesel 28,249 28,249 1,129,944 1,129,944
Fuel Oil 26,103 26,103 1,044,114 1,044,114
Kerosene 29,895 29,895 1,195,815 1,195,815
LPG 40,274 40,274 1,610,954 1,610,954
AVGAS 30,998 30,998 1,239,926 1,239,926
AVTURBO 29,895 29,895 1,195,815 1,195,815

10. For the Transport Sectors, are we going to report our offices as Commercial Establishments?

  • You must identify your sector based on the nature of your business operation. If your operation or main business falls under transportation, then all energy consumptions from buildings and vehicles must be reported using the designated EEC Form.

11. What is a Certified Energy Conservation Officer (CECO)?

  • Certified Energy Conservation Officer or CECO refers to a professional who demonstrates high levels of experience, competence, proficiency, and ethical fitness in the energy management profession.

12. What is a Certified Energy Manager (CEM)?

  • Certified Energy Manager or CEM refers to a licensed engineer or its equivalent who demonstrates high levels of experience, competence, proficiency, and ethical fitness.

13. What is a Certified Energy Auditor (CEA)?

  • Certified Energy Auditors or CEA refers to an individual or entity with proven credibility and competence to conduct an energy audit.

14. How do we determine the qualifications of an CECO?

  • The CECO must have at least two (2) years of continuous hands-on experience in the installation, operation, and maintenance of energy-consuming machines and equipment in facilities with energy consumption for Type I Designated Establishments, proof of which shall be submitted to the DOE.

15. How do we determine the qualifications of an CEM?

  • The CEM must be a licensed engineer or a graduate of a four (4) year course or its equivalent with at least three (3) years of continuous hands-on experience in the installation, operation, and maintenance of energy-consuming machines and equipment in facilities with energy consumption for Type 2 Designated Establishments, proof of which shall be submitted to the DOE.

16. How do we determine the qualifications of an CEA?

  • At least one (1) year of continuous experience on energy audits (ASHRAE Level 3)

17. Do I need to get a Certified Energy Conservation Officer and Certified Energy Manager?

  • The EEC IRR states that Type 1 DE should engage a Certified Energy Conservation Officer while Type 2 DE should engage a Certified Energy Manager. The identified personnel will eventually be certified by the DOE upon the availability of the training modules. The Designated Establishment may choose from their current pool of professionals within the organization or may engage a third-party service provider duly recognized by the DOE. The third-party service provider should be an Energy Service Company (ESCO) which provides energy management services.

18. In case we do not have skilled employees with the number of years’ experience as required by the MC, can we nominate someone with less than that requirement?

  • Yes, if the employee is competent enough to comply with the requirements under this MC. The qualifications shall be enforced once the certification is available. The DOE shall issue a separate guidelines/advisory on the certification of CECO and CEM.

19. What are the obligations of the CECO and CEM?

  • The CECO and CEM shall manage the energy consumption of facilities, equipment, and devices. They shall also administer the implementation and improvement of energy efficiency measures, the conduct of regular energy audit, conduct of energy monitoring and control, and preparation of periodic energy consumption and energy conservation program reports.

20. Can an CECO/CEM be assigned to more than one (1) establishment?

  • Yes, if the CECO/CEM can still deliver and comply with the reportorial requirements of the DOE. Also, the CECO/CEM should work under the umbrella of the same company/organization if they are employed by the DE. However, if the DE chooses to engage an ESCO to provide the services of a CECO/CEM, the ESCO may accommodate more one than establishment.

21. How do we register our CECO/CEM?

  • You can have your CECO/CEM registered through this online form:



22. How many designated establishments can we assign to a single CECO/CEM?

  • The number may depend on the capacity of the CECO/CEM to competently handle. The CECO/CEM must abide by the obligations and responsibility state in the MC and in the EEC IRR. Also, CECO/CEM shall physically be able to visit the DEs as the need arise.

23. Does the CECO/CEM have to be certified by the office?

  • As stated in the EEC IRR, the CECO and CEM shall be employed by the company.

24. What if the DE has no energy efficiency projects, can we skip this portion?

  • There are no issues if the DE has no energy efficiency projects, however, the DE may develop their own energy efficiency and conservation programs which does not require investment when being implemented. Moreover, as required by the EE&C act, all DEs are required to undergo an energy audit every three (3) years. From there, the DE may be able to identify any possible energy efficiency projects.

25. How will the tenants for multiple-dwelling buildings comply with the MC?

  • The tenants are not required to report to the DOE. It is the responsibility of the building management or administrator to comply with the provisions of the MC for the common facilities and areas.

26. My energy consumption is below 500,000 kWh, what are my responsibilities?

  • For DEs that has an annual consumption ranging from 100,000 kWh but less than 500,000 kWh, they shall be required to submit an annual energy consumption report to the DOE and integrate an energy management system policy into their business operations based on ISO 50001 or any similar framework on such other standard identified by the DOE.

27. We are already submitting quarterly reports to DOE in compliance with MC93-03-05, do we still need to submit both quarterly and annual reports?

  • All DEs complying with MC No. 93-03-05 is now governed by MC 2020-05-0001 which means that the requirement is for the submission of an annual energy consumption report in EEC Form 3 and EE Form 4.

28. We provide services to designated establishments in terms of improving their energy consumption, are we going to reflect their savings in our report?

  • The services must become a certificate of registered and certified ESCO under ESCO Guidelines. The savings and energy efficiency measure or project will be reported by the DE who avail your services. The ESCO’s own in its operation of your own company.

29.  What does “consumption” mean in the forms?

  • This is the energy consumption of the facility both while producing, generating, and/or operating, and during the standby mode. The DE shall indicate all fuel for each activity at the "Product Line/Activity" of the form. The conversion factors are available in the forms.

30. What does “Product/Activity” mean?

  • These are the products that are being produced or the activities that are being conducted by the facility which requires the consumption of energy to operate. This includes the facilities that provide support on the operation of the DE.

31. Does the number of employees include utility services like janitorial and security?

  • No, this shall only cover permanent, regular, and/or contractual employees that are involved in the technical or administrative operation of the DE. Outsourced services such as janitorial and security are not included in this.

32. Our company can be categorized as Type 2 Designated Establishment. However, this may change if we will report our facilities that are not physically attached to the main office. Some of the facilities may fall into Type 1. What should we do?

  • Designated Establishment are categorized as entities. However, the consumption of each facility varies from one another. The DE should disaggregate the information in their submissions for independent facility outside the main compound/office.

33. Are Local Government Units (LGUs) and National Government Agencies (NGAs) covered by the MC2020-05-0001?

  • The LGUs and NGAs are covered by the Government Energy Management Program (GCEMP). However, the thresholds under MC2020-05-0001 for identifying the DE Type shall be used as the same reference.

34. The DE is under one (1) compound with a single Electric Meter, can we submit a disaggregated electric consumption report?

  • Yes. The DE should however provide enough information for its disaggregation.

35. Our facility is undergoing renovation since last year. This is expected to be finished by next year, are we still covered by the MC? What documents are we required to submit?

  • Yes, you are still covered by the MC if you have an annual consumption of at least 100,000 kWh. You still need to submit your Annual Energy Utilization Report for the last five (5) years or regardless if you have lesser consumption during the time of your facility’s renovation.

36. We are under the umbrella of a corporation; do we need to have the documents signed by the head of the corporation?

  • The person handling the facility as DE shall be the one who will sign the document.

37. Our company have several vehicles that are issued to the employees, do we need to report their fuel consumption?

  • That will depend if the fuels are being paid by the company as a DE. Only consumed fuels that are being shouldered by the DE and being paid under the DE’s name must be reported. The same case shall be applied if the vehicle is owned by the employee, but the DE provides allowance for fuel. The fuel is still under the DE’s name, so this must be reported along with the fuel consumption of other vehicles used in the operation of the DE.

38. How do we convert the energy sources into kWh?

  • The conversion table is provided with the forms.

39. Do we need to include the used oil for cooking?

  • Only need to report the oil used for energy shall be reported.

40. How are we going to submit our reports?

41. When is the deadline for the submission?

  • The deadline for submission of the reports is every 15th of April.

42. For guidance in accomplishing the forms, you can download the General Instructions at the DOE website through or via Google Drive through the link

43. For further inquiries and clarifications, you can contact EUMB – EPMPD at (02) 8840-2243 or you can reach us by sending an e-mail at