I INTRODUCTION

On 25 November 2015, the Prime Minister approved 'Vietnam's Renewable Energy Development Strategy up to 2030 with an outlook to 2050' (the Strategy), which sets out an ambitious plan for the country to achieve by 2050: total power generated from renewable sources to account for 44 per cent of total generated electricity.2

The Strategy recommends that the government:

  1. initiate a renewable energy market;
  2. introduce reasonable feed-in tariffs (FITs) and investment protection policy;
  3. set out applicable renewable energy standards;
  4. regulate the net-metering mechanism;
  5. grant incentives for development and use of renewable energy (e.g., import duty, corporate income tax and land use rights); and
  6. impose an environmental protection fee on energy projects using fossil fuels, to provide a fund for the development of renewable energy.

Over the past year, legal reforms on renewable energy have continually been pursued to create a more stable and profitable investment environment in this field. The year 2019 is a transitional year in which numerous regulations will be replaced by new energy policies, promising to attract more foreign investors to Vietnam and gradually completing the national mission on renewable energy as stated in the Strategy.

II THE YEAR IN REVIEW

On 18 March 2016, the Prime Minister issued Decision No. 428/QD-TTg (generally referred to as the Revised Power Development Master Plan VII (the Revised PDP 7)). The Revised PDP 7 contemplates that the total installed capacity of electricity generated from hydroelectric plants will be up to 21,600MW by 2020 and 27,800MW by 2030; from wind it will be 800MW (2020) and 6,000MW (2030); and from solar it will be 850MW (2020) and 12,000MW (2030). The ratios of hydroelectric, wind, biomass and solar power in relation to total power generated in 2030 will be 15.5 per cent, 2.1 per cent, 2.1 per cent and 3.3 per cent respectively. On 9 August 2018, the Prime Minister implemented Decision No. 995/QD-TTg, directing the Ministry of Industry and Trade (MOIT) to prepare the power development plan for the period from 2021 to 2030 with an outlook to 2050 (the PDP 8). At the time of writing, the MOIT is working on preparing a draft PDP 8. Predictably, renewable energy will constitute a greater proportion of the total installed capacity.

Notably, the second half of 2018 witnessed a sharp increase in the number of solar power projects. According to MOIT data, by the end of 2018, investors registered a total of 10,000MW of solar power, of which 8,100MW, in 121 projects, were included in the Revised PDP 7 and over 100 projects have had power purchase agreements (PPAs) executed.3 However, the market development of wind, biomass and solid-waste power projects has been poor in comparison with that of solar power projects. Overall, the power generated from green energy sources amounted to 2.1 per cent of the total power produced in 2018.4

III THE POLICY AND REGULATORY FRAMEWORK

i The policy background

Vietnam has not completed a national master plan for the development of renewable energy.

Under the current energy regime, the provincial people's committees propose plans for renewable energy projects in their province. Given the lack of transparency and the low management capability at local government level, this decentralised planning procedure has resulted in a short-term and limited local approach to renewable energy in Vietnam. In some regions, the short-term and incomplete nature of planning for wind and solar power projects leads to an overlap between land planned for energy and areas planned for mining activities. Some individuals have abused this loophole to exploit mineral sources, using renewable energy projects to disguise their true intentions.5

In general, Vietnam grants ordinary but not special incentives for renewable energy projects, in the same manner as it does to encourage other investment projects in other sectors. This policy of 'ordinary incentives' does not make the project viable from the developers' and lenders' point of view. Renewable energy projects are governed by laws at two levels: general requirements for all types of energy projects and specific regulations for each type of renewable energy.

Like other energy projects, renewables projects are obliged to comply with regulations on (1) power development plans, (2) the power purchasers and power purchase agreement (PPA) execution process, and (3) approvals and consents from the authorities.

Grid-connected renewable energy projects must be included in a regional or national power development plan before reaching the implementation stage. This step is required to ensure that there is enough land for the project. Furthermore, depending on the installed capacity of the project, the Prime Minister, or the MOIT, has to approve the project for inclusion in the relevant power development plans. For example, solar and wind power projects with capacity equal to or greater than 50MW will be approved by the Prime Minister, while those with capacity below 50MW will come under the authority of the MOIT. The regulatory body authorised by the MOIT to deal with renewable energy projects is the Electricity and Renewable Energy Authority of Vietnam.

Vietnam Electricity (EVN) remains the sole offtaker for all renewable energy projects, and Vietnam still operates a monopoly 'single-buyer' electricity market, subject to certain exceptions. However, the situation is likely to change as of 1 July 2019.

ii The regulatory framework

There are the following specific pieces of Vietnamese legislation on renewable energy:

  1. Decision No. 37/2011/QD-TTg (issued on 29 June 2011, and effective as of 20 August 2011), Decision No. 39/2018/QD-TTg (issued on 10 September 2018, and effective as of 1 November 2018), and Circular No. 02/2019/TT-BCT (issued on 15 January 2019, and effective as of 28 February 2019) on wind energy;
  2. Decision No. 24/2014/QD-TTg (issued on 24 March 2014, and effective as of 10 May 2014), Circular No. 44/2015/TT-BCT (issued on 9 December 2015, and effective as of 25 January 2016), and Circular No. 54/2018/TT-BCT (issued on 25 December 2018, and effective as of 18 February 2019) on biomass power;
  3. Decision No. 31/2014/QD-TTg (issued on 05 May 2014, and effective as of 20 June 2014) and Circular No. 32/2015/TT-BCT (issued on 8 October 2015, and effective as of 7 December 2015) on solid-waste power; and
  4. Decision No. 11/2017/QD-TTg (issued on 11 April 2017, and effective as of 1 June 2017), Decision No. 02/2019/QD-TTg (issued on and effective as of 8 January 2018), Circular No. 16/2017/TT-BCT (issued on 12 September 2017, and effective as of 26 October 2017), and Circular No. 05/2019/TT-BCT (issued on 11 March 2019, and effective as of 25 April 2019) on solar power. Decisions No. 11/2017/QD-TTg and No. 02/2019/QD-TTg expire on 30 June 2019.

In addition to this specific legislation, renewable energy projects fall within the scope of legislation applicable to all types of energy projects in Vietnam – that is, laws on electricity, construction, environment and so on – and in the adoption of such laws Vietnam has scope to develop a distinct legal framework for renewable energy projects.

Regulators

The main regulator for renewable energy is either the MOIT (via the Electricity and Renewable Energy Authority (EREA)) or the provincial departments of industry and trade, subject to the capacity of the projects. While the Electricity Regulatory Authority of Vietnam manages the development of all power projects, the EREA has authority and responsibility for regulating FITs for renewable energy.

The Ministry of Natural Resources and Environment (MONRE) and the provincial departments of natural resources and environment approve environmental impact assessments.

The provincial people's committees and district people's committees are heavily involved in not only the provincial renewable-energy development plans, but also the whole development of the projects.

Investment incentives

Overall, renewable-energy projects in Vietnam have been granted incentives as follows:

  1. exemption from import duties applicable to the imported materials, equipment and facilities forming the fixed assets of the renewable-energy project;
  2. the same corporate income tax exemptions or incentives as those applicable to projects in other investment priority sectors in accordance with prevailing tax laws and regulations;
  3. solar power projects, transmission lines and substations connected to the power grid are exempted from or subject to the same reduced land-use fees, land rent and water surface rent as those applicable to projects in other investment priority sectors in accordance with prevailing tax laws and regulations;
  4. capital mobilisation will be made in accordance with prevailing laws and regulations; and
  5. in addition to the aforementioned incentives, each particular type of renewable-energy project enjoys distinct and special treatment (see below for details).

EVN offtake obligation

As stated above, subject to certain exceptions, at present, EVN is the sole offtaker for all renewable energy projects, and Vietnam still operates a monopoly single-buyer electricity market. Under the latest draft of the Decision replacing Decisions No. 11/2017/QD-TTg and No. 02/2019/QD-TTg (the Draft Decision on Solar), the term 'electricity purchasers' also includes individuals and organisations other than EVN. This may be a critical change to comply with the development orientation of Vietnam's electricity market, which will transition into a wholesale electricity market in 2019 and a retail electricity market in 2025.6 It is to be hoped that when the Draft Decision on Solar is officially introduced, this provision will remain the same.

Power purchase agreements

The model PPA for renewable energy projects is mandatory, with different kinds of projects using the same template with minimal changes to specific incentives for each type of project. Furthermore, the bankability of these model PPAs is another critical issue that developers must consider carefully.

Corporate renewable-energy PPAs, subject to certain exceptions, are technically not possible at present, although petitions have been raised on a number of occasions. Nevertheless, under the Draft Decision on Solar, the model PPA only applies to transactions with EVN as a power purchaser.

Solar power

Solar power is the latest renewable source to be promoted by specific legislation, and assurances have been given that it will be the focus of further attention in the future.

Currently, the complete legal framework on solar power projects includes Decision No. 11/2017/QD-TTg (Decision No. 11), Circular No. 16/2017/TT-BCT, Decision No. 02/2019/QD-TTg (Decision No. 02) and Circular No. 05/2019/TT-BCT. As Decision Nos. 11 and 02 will expire on 30 June 2019, the new decision is being drafted to be officially effective from 1 July 2019. At the time of writing, the MOIT had circulated the third version of the Draft Decision on Solar for public comments.

As noted above, 2018 was the year of solar power projects. In addition to the 121 projects already included in the Revised PDP 7, there are approximately 220 projects waiting to be included. In March 2019, a 100MW solar plant in Dak Lak commenced commercial operation.7 Numerous projects are in the process of completing the steps necessary to start operation before 30 June 2019 to enjoy the FIT at 9.35 US cents/kWh.

The following are highlights from the specific regulations on solar power projects.

Types of solar PV projects

The current legislation regulates solar power projects that generate electric power through the use of solar panels to directly convert energy from sunlight into electricity (i.e., the conventional solar photovoltaic (PV) power system). Other types of solar power generation, such as thermal or concentrated solar power or hybrid solar power systems, are not included in this regime.

Decision No. 11 classifies two types of solar PV projects: (1) roof-mounted and (2) grid-connected solar projects. Roof-mounted projects are clarified as those that use solar panels made up of PV cells installed on the rooftops of residential or commercial buildings, or around the premises of those buildings, and that connect to the national grid or the EVN electric grid. Projects that are connected to the national grid or the EVN electric grid but are not roof-mounted projects are classified as grid-connected projects.

The Draft Decision on Solar continues to classify two types of solar PV projects, as applies under Decision No. 11, but with more detailed forms of each project type; for example, grid-connected projects now include floating solar projects (i.e., projects with panels installed on water surfaces) and ground-mounted solar projects (i.e., (1) projects with panels installed on the ground, and (2) roof-mounted projects with a capacity of over 1MWp). Furthermore, roof-mounted projects include the following use models: (1) using power (power generated from the panels will be used by the seller, with any excess being sold to the national grid); (2) selling excess (power generated will be sold to purchasers, with any excess being sold to the national grid); (3) selling all (power generated will be sold entirely to the national grid); and (4) direct power purchasing (power generated will be sold entirely to other individuals or organisations, without using power from the national grid).

FIT

For grid-connected solar projects with solar-cell efficiency greater than 16 per cent or solar-module efficiency greater than 15 per cent, a FIT will be fixed at 2,086 Vietnamese dong/kWh (equivalent to 9.35 US cents/kWh excluding VAT) for generating electricity at the delivery point.

Regarding roof-mounted solar projects, a FIT of 2,086 dong/kWh (equivalent to 9.35 US cents/kWh excluding VAT) theoretically applies. The power generated will be calculated separately by different meters at delivery and receipt points.

However, the FIT price for both types of solar project is applicable only to projects with a commercial operation date (COD) before 30 June 2019, and this price remains in effect for 20 years from the COD. The Prime Minister agreed to extend to the end of 2020 the COD for solar power projects (2,000MW) in Ninh Thuan province that have already been included in the Revised PDP 7, so that they can benefit from the FIT at 9.35 US cents/kWh. In fact, there is a possibility that many solar projects will not reach their COD by 30 June 2019, although they are qualified to be connected to the grid. This is because the national grid has no adequate capacity left for these projects, and EVN has insufficient resources to conduct acceptance tests. Therefore, the question is whether these projects will still benefit from the FIT of 9.35 US cents/kWh or will have to accept a new FIT for the period commencing 1 July 2019. At the time of writing, the government had not issued clear instructions, so the situation remains uncertain.

The Draft Decision on Solar introduces a mechanism in which applicable FITs for projects shall be determined on the basis of four radiation regions and three solar power technologies. A total of 63 provinces and cities would be divided into four regions, with projects in Region 1 enjoying the highest FIT rate, and those in Region 4 receiving the lowest.8 The FIT rate would also differ according to the form of the solar power project, namely floating, ground-mounted or roof-mounted. The following table sets out the FITs proposed under the current Draft Decision on Solar.

Region 1 FIT Region 2 FIT Region 3 FIT Region 4 FIT
Solar technology Dong/kWh Equivalent US cent/kWh Dong/kWh Equivalent US cent/kWh Dong/kWh Equivalent US cent/kWh Dong/kWh Equivalent US cent/kWh
Floating solar projects 2,281 9.98 1,963 8.59 1,758 7.69 1,655 7.24
Ground-mounted projects 2,102 9.20 1,809 7.91 1,620 7.09 1,525 6.67
Roof-mounted projects 2,486 10.87 2,139 9.36 1,916 8.38 1,803 7.89

The proposed FITs are planned to apply for projects reaching COD from 1 July 2019 to 31 December 2021. The MOIT is considering applying an auction mechanism after this period.9

Other requirements

Both types of solar PV projects whose capacity is equal to 1MW or higher must comply with the national or regional power development plans and are required to fulfil the MOIT licensing requirements. Additionally, the land used must not exceed 1.2ha/1MW.

Wind power

As with solar projects, wind power projects in Vietnam possess huge potential for growth. According to a report by the Vietnam Energy Association, coastal cities and provinces in Vietnam have recognisable development potential for wind power installations on land of a capacity of up to 40,000 to 50,000MW. When counting in the installation of offshore wind power projects, this could increase to 100,000MW of total installed capacity.10 Additionally, the MOIT has approved master plans for wind power developments in some regions in Vietnam. For instance, by 2030, the Ca Mau wind power installation is tentatively expected to be developed to a capacity of 3,607MW;11 and the projected figure for Binh Thuan province is 2,500MW.12

Following the introduction of Decision No. 37/2011/QD-TTg (Decision No. 37), seven years ago in 2011, the government has now amended the policy on wind power to attract more investors with the implementation of Decision No. 39/2018/QD-TTg (Decision No. 39) to amend Decision No. 37, and Circular No. 02/2019/TT-BCT to replace Circular No. 32/2012/TT-BCT.

The huge potential for wind, together with the incentives, has encouraged developers to undertake large-scale projects, such as the Ke Ga project (3,400MW), Bac Lieu (Cong Ly Phase 1 and Phase 2) project (with total installed capacity of over 99MW), Huong Linh 2 project (30MW) and Dam Nai Phase 2 (40MW in total).

The most notable incentives and the requirements for wind power are as follows.

FIT

The government has set new FITs for wind power projects based on the project type. Specifically, Decision No. 39 classifies wind power projects into two types: onshore plants and offshore plants. Onshore power projects are grid-connected wind power projects with wind turbines constructed and operated onshore and on coastal land areas whose outer border is at the lowest average sea edge (averaged over 18.6 years), while offshore projects are grid-connected wind power projects with wind turbines constructed and operated off the coast beyond the lowest average sea edge (averaged over 18.6 years). The FIT for onshore wind power projects is 1,298 dong/kWh (8.5 US cents/kWh) and for offshore projects it is 2,223 dong/kWh (9.8 US cents/kWh). The tariffs are exclusive of VAT.

The FITs under Decision No. 39 apply to part or whole grid-connected wind power projects reaching COD before 1 November 2021 and remain in effect for 20 years from COD. For the period after 1 November 2021, the government has clearly instructed the MOIT to study auction mechanisms and prepare a new FIT policy.

Requirements

Wind turbines deployed in projects must not have been used before and their production date must not be more than five years old; if used turbines are proposed, the developer must apply to the MOIT for review and approval.

The construction of wind power plants may only be commenced when the project owner has (1) satisfied all construction conditions pursuant to the relevant laws, (2) signed a PPA with a power purchaser, (3) signed a grid-connection agreement with the power distribution or transmission entity, and (4) had wind measurement assessments conducted consecutively for at least 12 months.

The land used for the project must not exceed 0.35ha/MW (0.3ha/MW for temporary land use).

Biomass power

As a developing agricultural country, Vietnam produces a vast number of agricultural products, such as rice, sugar cane and coffee. As a result, millions of tons of waste are created, such as straw, rice husks, bagasse, coffee husks, coir, wood or wood residues, and other agricultural or industrial by-products, and these constitute a very valuable biomass resource. On 24 March 2014, the Prime Minister promulgated Decision No. 24/2014/QD-TTg on Support Mechanisms for Development of Biomass Power Projects in Vietnam (Decision No. 24), which was followed and facilitated by Circular No. 44/2015/TT-BCT on Biomass Power (Circular No. 44) and Circular No. 54/2018/TT-BCT (Circular No. 54) on Biomass Power.

Types of biomass power projects

Circular No. 44 classifies biomass electricity projects into two types, based on whether the biomass project is built and connected to the national power grid or not. A grid-connected biomass project can supply power partially or wholly to the national grid. Distinct from grid-connected biomass electricity projects, a non-grid-connected biomass power project is a biomass power plant project built to supply its entire power output to households in certain areas not connected to the national power grid, and the pricing of the electricity from these non-grid-connected projects is not strictly regulated by the Vietnamese authorities.

Electricity and heat cogeneration, or combined heat and power (CHP), is another type of biomass power project that falls within the remit of the MOIT. Defined as biomass power projects that simultaneously provide heat and electricity, CHP projects are sometimes called co-firing biomass power projects. This type of biomass electricity project is widely expected to be deployed in future not only in new biomass projects, but also in existing thermal electric power plants in Vietnam.

FIT

Decision No. 24 sets out the electricity selling price for grid-connected biomass power projects as follows:

  1. for combined heat and power projects: 1,220 dong/kWh (5.8 US cents/kWh excluding VAT). Electricity selling prices are adjusted according to fluctuations of the dong/US$ exchange rate; and
  2. for other biomass power projects: according to the Avoided Cost Tariff (ACT) for biomass power projects issued by the MOIT annually.

A new ACT is announced annually. Where the tariff applicable to biomass power projects has not yet been announced, the previous year's tariff shall be used temporarily, until the tariff applicable to the new biomass power projects is announced. The difference between the calculation under the old tariff and the new tariff shall be refunded to buyers or sellers, whichever is appropriate, in the first payment following application of the new tariff.

Since 18 February 2019 (i.e., the effective date of Circular No. 54), the electricity price for non-grid-connected biomass power projects has ceased to be government-assisted.

Solid-waste power

Given that Vietnam's population, as at 17 April 2018, stands at over 97 million, the country generates a huge amount of solid waste. The amount of solid waste generated nationally is estimated at about 70,000 tons per day. In large cities such as Hanoi and Ho Chi Minh City, this figure can be over 9,000 tons per day.13 Therefore, Vietnam has great potential for solid-waste power (or waste-to-energy).

The government has also identified solid waste as a source of renewable energy to be promoted. According to plans scheduled up until 2050, most of Vietnam's urban solid waste will be used to produce electricity.14 On 5 May 2014, the Prime Minister issued Decision No. 31/2014/QD-TTg (Decision No. 31) on the Support Mechanism for Development of Power Generation Projects Using Solid Waste in Vietnam. Then, on 8 October 2015, the MOIT promulgated Circular No. 32/2015/TT-BCT to clarify provisions under Decision No. 31 and issue a model PPA. Together, they constitute a legal framework to promote the development of solid-waste energy projects in Vietnam.

Types of solid-waste power projects

Under the laws of Vietnam, there are two types of solid-waste power whose development the government is promoting. In the first type of project, solid waste is directly incinerated to produce electricity. The second type produces electricity from combusted gas collected from solid-waste landfill sites.

FIT

For projects producing electricity by directly incinerating solid waste, the FIT price is at 2,114 dong/kWh (10.05 US cents/kWh excluding VAT). For combusted-gas projects, the FIT price is at 1,532 dong/kWh (7.28 US cents/kWh excluding VAT). The above prices are adjusted with the fluctuation of dong/US$ exchange ratios.

IV RENEWABLE ENERGY PROJECT DEVELOPMENT

In Vietnam, most power projects have to be financed. Overall, senior debt is the most common type of financing for renewable energy projects. Currently, there are numerous stakeholders from various sectors interested in renewable energy projects in Vietnam, such as development banks, commercial banks, funds, governments and strategic investors.15 The specific mechanisms for solar and wind projects legally require developers to maintain equity percentage of at least 20 per cent of the total project capital (i.e., the debt or other finance support must not exceed 80 per cent of the total investment capital).

Additionally, the development of distributed and residential renewable energy in Vietnam is in the early stages and requires more incentives. Although there is huge potential, the capacity of roof-mounted solar projects is only 8.18MWp, with 850 projects, according to the EVN data as at 12 January 2019.16

V RENEWABLE ENERGY MANUFACTURING

The government exempts taxes for imported goods that are used to constitute the fixed assets of renewable-energy projects. Therefore, imported wind turbines, solar panels, etc. for project construction are exempted from tax.

Domestic manufacturers of renewable-energy products also enjoy government incentives, similar to incentives for preferred and promoted investment, such as incentives on taxes and land.

However, the interpretation of tax regulations may vary in different provinces, albeit under the same laws. Therefore, whenever inconsistencies occur, guidelines and official instruction from the state's tax authority are required to provide clarification.

VI CONCLUSIONS AND OUTLOOK

Going forward, we believe that renewable energy will form an essential part of a diverse energy mix of available low-carbon generating technologies in Vietnam.

However, the support system for the deployment of renewables generation (including solar energy, onshore and offshore wind, and biomass energy) has left a lot to be desired from the perspective of project developers and financiers. FITs and critical PPA contractual terms are the principal issues to be resolved to facilitate the development and financing of long-term utility-scale renewable energy resources. In addition, the insufficient transmission and distribution capacity of the national grid is also a hindrance for the development of the renewable energy projects.

Although renewable energy mechanisms have been adopted, the development of projects and fulfilment of the 2030 target are facing numerous challenges.

Regarding solar projects, the high demand for the land used is a problem. A solar plant normally requires a large area for the construction and installation of the solar panels, which leads to planning difficulties. In addition, although there are numerous solar power projects registered for development, most are in Ninh Thuan and Binh Thuan, whose infrastructure systems are now overloaded.

In respect of wind power, the actual installation of wind power projects has not reached the projected goal because of the pace of the installation work; therefore high input costs lead to high calculated electricity prices while the FIT is fixed.

Although Vietnam has potential for the development of solid-waste power projects, the number of investors keen on this type of project is minimal. This is because the investment costs are high, especially the costs for technology and waste classification. Therefore, only developers with strong financial capacity are able to invest in solid-waste power plants. As at January 2019, the total installed capacity of solid-waste plants was 9.03MW.17

The government is finding ways to deal with these challenges. The Draft Decision on Solar can be seen as an effort by the government to solve the problems that solar projects are facing. It is evident that, in reviewing the proposed FIT mechanism, the government is granting more incentives for projects not using land (i.e., floating and roof-mounted) and promoting investment in solar plants across the country, instead of focusing on only a few areas.

The government is considering the suitability of wind energy auctions as a support mechanism for Vietnam. Using the auction mechanism, the energy market would be more competitive, if also more complicated and with increased risks for investors. However, although using the auction mechanism would provide an increased measure of control in the planning and deployment of renewable energy, this is not a primary objective in Vietnam and lower electricity procurement costs would be the most significant benefit. In the case of Vietnam, an immediate shift from FITs to auctions is not recommended as it is necessary to first establish certain preconditions in the coming years. FITs could continue to be used for onshore wind energy (a mature technology). However, auction-based support can be used for near-shore wind energy projects, since calculating costs for these types of projects and setting FIT rates is more challenging. A suggested timeline for introducing auctions is:

  1. 2018–2020: amending the FIT system;
  2. 2018–2023: preparing for auctions implementation; and
  3. 2020–2023: parallel use of FITs and auctions for existing projects.

Meanwhile, solutions for solid-waste and biomass are still in question. We expect that the government, in cooperation with international experts, will find the best way to develop renewable-energy projects in Vietnam, contributing both to the development of a new era of the economy and taking a new generation another step closer to a widespread application of renewables technologies.


Footnotes

1 Nguyen Viet Ha and Nguyen Hong Hai are partners at Lexcomm Vietnam LLC.

2 Decision No. 2068/QD-TTG of the Prime Minister dated 25 November 2015.

3 Anh Minh, Việt Nam đang chứng kiến làn sóng đầu tư vào năng lượng tái tạo (12 March 2019), VnExpress, https://vnexpress.net/kinh-doanh/viet-nam-dang-chung-kien-lan-song-dau-tu-vao-nang-luong-
tai-tao-3893420.html accessed on 17 April 2019 (Vietnamese).

4 ibid.

5 Vietnam Energy Magazine, Không được lợi dụng dự án điện gió để khai thác titan (27 April 2018),
http://nangluongvietnam.vn/news/vn/dien-hat-nhan-nang-luong-tai-tao/khong-duoc-loi-dung-du-an-dien-
gio-de-khai-thac-titan.html accessed on 17 April 2019 (Vietnamese).

6 Decision No. 63/2013/QD-TTg of the Prime Minister dated 8 November 2013 on the schedule, conditions and structure of the electricity sector for the formulation and development of electricity market levels in Vietnam.

7 Anh Minh; see footnote 3.

8 According to the previous version of the Draft Decision on Solar, Region 1 is understood to contain the areas that receive the lowest levels of solar radiation (mostly Northern provinces, such as Son La and Tuyen Quang), while the provinces in Region 4 (such as Phu Yen, Ninh Thuan and Binh Thuan) benefit from the highest solar radiation levels.

9 ibid.

10 Vietnam Energy Magazine, Thông tin mới nhất về tiềm năng điện tái tạo Việt Nam (14 August 2017), http://nangluongvietnam.vn/news/vn/dien-hat-nhan-nang-luong-tai-tao/nang-luong-tai-tao/thong-tin-
moi-nhat-ve-tiem-nang-dien-tai-tao-viet-nam.html accessed on 16 March 2018 (Vietnamese).

11 Decision No. 1402/QD-BCT dated 11 April 2016 providing masterplan for wind power development of Ca Mau province until 2020/2030.

13 Phuong Nhung, Điện rác kén nhà đầu tư (5 January 2019), Labour newspaper (Vietnamese).

14 Quyen Luu, Việt Nam còn nhiều tiềm năng biến rác thải thành nguyên liệu cho sản xuất năng lượng (19 August 2017), MOIT Official Website, http://moit.gov.vn/tin-chi-tiet/-/chi-tiet/viet-nam-con-nhieu-
tiem-nang-bien-rac-thai-thanh-nguyen-lieu-cho-san-xuat-nang-luong-5992-16.html accessed on 19 March 2018 (Vietnamese).

15 Aurélien Agut, Tran Truong Han, Vu Chi Mai, Peter Cattelaens, Wind Power Investment Guidelines for Vietnam (July 2016), MOIT/GIZ Support to the Up-Scaling of Wind Power in Viet Nam.

16 Chi Nhan, Bỏ cơ chế bù trừ điện mặt trời trên mái nhà (12 January 2019), Thanh Nien newspaper,
https://thanhnien.vn/tai-chinh-kinh-doanh/bo-co-che-bu-tru-dien-mat-troi-tren-mai-nha-1042725.html accessed on 18 April 2019 (Vietnamese).

17 Phuong Nhung, Điện rác kén nhà đầu tư (5 January 2019), Labour newspaper (Vietnamese).