SINGAPORE Law and Practice Contributed by: Adam Moncrieff, Karthik Kumar, Lynette Lim and Kelly Choo, Orrick, Herrington & Sutcliffe LLP
prices, reserve prices, regulation prices, wholesale electricity prices and price cap parameters, are pub- lished on EMC’s NEMS prices platform. The EMA has introduced a Temporary Price Cap (TPC) mechanism as a “circuit breaker” activated during high and sustained periods of extreme price volatility in the wholesale electricity market. The TPC was intro- duced from 1 July 2023 and is expected to apply only for short durations when triggered. The EMA states that the TPC does not affect the fundamentals of the wholesale electricity market or the operations of gen- eration companies. The TPC activates when the mov- ing average price exceeds the moving average price threshold and deactivates when the moving average price falls to or below the threshold after being active for at least 48 periods. Bi-weekly TPC parameters can be found on the EMA’s website. High-load consumers, including data centres, are generally addressed through Singapore’s contest- ability and demand-side participation frameworks rather than through a special wholesale price catego- ry. Contestable consumers may buy electricity from a licensed retailer, directly from the wholesale market, or indirectly through SP Services, and a direct market consumer must register with the EMC, purchase only for its own consumption, and enter into the necessary arrangements with the Power System Operator, the Market Support Services Licensee and SP PowerAs- sets. Large business consumers can also participate in demand-side programmes. Under the EMA’s Demand Response programme, eligible business consumers may voluntarily reduce consumption when wholesale prices are high and receive a share of the resulting savings, while the Interruptible Load programme com- pensates eligible consumers for being on standby to reduce demand when needed for system reliability. 2.2 Electricity Imports and Exports There has been no export of electricity from Singa- pore to any other jurisdiction to date. The export of electricity is a licensable activity under the Electricity Act and no electricity exporter electricity licence has been issued by the EMA.
The import of electricity into Singapore from other jurisdictions is a licensable activity under the Electric- ity Act as well, and three entities have been granted such a licence – Keppel Electric Pte Ltd (expiring in January 2028), Sembcorp Cogen Pte Ltd (expiring in September 2026) and Sembcorp Power Pte Ltd (expiring in December 2026). These licences are in relation to the following import trials/pilot schemes. • Lao PDR-Thailand-Malaysia-Singapore Power Integration Project – launched in June 2022, the first phase allowed for up to 100 MW of renewable hydropower being imported from Lao PDR to Sin- gapore through Thailand and Malaysia via existing interconnectors, and the second phase, which is what Keppel Electric Pte Ltd’s current electricity importer electricity licence covers, allows for up to 200 MW of electricity imported from Lao PDR and Malaysia. • 100 MW Malaysia ENEGEM Pilot – launched on 15 April 2024 by Malaysia’s Ministry of Energy Transi- tion and Water Transformation, for the purchase of green electricity from Malaysia’s electricity supply system to be supplied to Singapore via the Energy Exchange Malaysia (ENEGEM) Platform. The foregoing are precursors to Singapore’s journey to reach its goal of 6 GW of low-carbon electricity imports by 2035. Singapore started this process in July 2022, when the EMA invited interested compa- nies to submit proposals for importing up to 4 GW of electricity into Singapore. That initial target of 4 GW has been subsequently increased to 6 GW, in view of the “continued strong interest from credible parties to participate” in such projects. To date, the EMA has issued Conditional Approvals to 11 projects to import low-carbon electricity from Australia, Cambodia, Indo- nesia, Sarawak (Malaysia) and Vietnam. Six projects have made substantive progress and were awarded conditional licences. However, no electricity importer electricity licence has been awarded for any of these projects as yet. 2.3 Supply Mix of Electricity Singapore has historically been heavily reliant on nat- ural gas imported from Malaysia and Indonesia via pipelines, and remains so (albeit with a slight decrease over the past five years or so). In the first half of 2025,
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